Ludo Genie Privacy Policy

Last updated: October 22, 2026

Ludo Genie is built so you can play without being tracked. No account, no password, no advertising, no advertising cookies, no sale of data. This policy explains, in plain terms, the little personal information we handle, why, for how long, with whom, and how to exercise your rights.

It applies to the ludogenie.com website, the web app and every game (the "Service"). It supplements the Terms of Use and the Purchase Terms.

1. Who is responsible

The controller is Ludo Genie, an operator established in Quebec, Canada ("Ludo Genie", "we", "us").

Ludo Genie's Person in Charge of the Protection of Personal Information oversees compliance with this policy and applicable laws. You can reach this person at privacy@ludogenie.com (or confidentialite@ludogenie.com, same inbox).

Laws covered: Quebec's Act respecting the protection of personal information in the private sector (as amended by Law 25), Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), the General Data Protection Regulation (GDPR) of the European Union and European Economic Area, the UK GDPR, and U.S. state consumer privacy laws, to the extent they apply.

2. In short

• No account: your player identity is a random identifier (your "Lamp", for example L-7KQ2-9XHM).
• We never store your email in readable form, only a cryptographic fingerprint.
• We never see or store your card number.
• We never see the content of your online games: they are end-to-end encrypted.
• No advertising, no tracking cookies, no profiling, no sale or sharing of personal information for advertising.
• You can erase everything with the "Delete my Lamp" button.

3. Information we process

3.1 Detailed table

3.2 Your email

During recovery, you enter the email on your receipt. We use it in memory just long enough to send a 6-digit code valid for 15 minutes, then we erase it. We keep only a salted cryptographic fingerprint, which serves only to recognize that email next time. It cannot be used to recover your address.

3.3 Your IP address

Your IP address is used to route communications. For statistics, we derive a country from it, then discard it without storing it. The anti-abuse fingerprint uses an approximate network, not your full address, and is then hashed.

3.4 What we do not collect

We do not collect your name, postal address, date of birth, phone number, card number, contacts, precise location, the content of your games, or your online nickname.

4. On your device

Some data stays only in your browser (local storage and IndexedDB) and is never sent to us:

• your preferences (language, sounds, theme);
• your personal game statistics and favourites;
• your lamp key, which is non-extractable.

These items are strictly necessary for the Service or requested by you. Ludo Genie uses no advertising cookies and no audience-measurement trackers. You can erase this data in your browser settings. Note: erasing the lamp key removes the device from your Lamp.

4.1 No-trace mode

No-trace mode lets you play without keeping statistics or history on the device. The minimal game bookkeeping needed for tokens remains on the server side if you use tokens.

5. Online play

• Online games go directly from one device to the other, end-to-end encrypted. Ludo Genie runs no game server and does not see your moves.
• To help your devices find each other, public meeting points (MQTT relays run by third parties) carry encrypted messages. They cannot read the content but, like any Internet service, they see the network address that connects.
• As with any direct connection, your device's network address may be visible to your opponent's device.
• Your nickname is sent only to your opponent. It is filtered and never stored on our servers.
• Our servers receive only the game bookkeeping (game, mode, times, status) to manage tokens.

6. Payments

Payments are processed by Stripe through Stripe Checkout with Managed Payments. Stripe, through its Link service, acts as merchant of record (reseller): it collects your payment details and email, collects taxes, issues receipts and invoices, prevents fraud and handles disputes.

Stripe processes this information as a separate controller, under its own privacy policy and that of Link (link.com). Ludo Genie receives from Stripe only the transaction, customer and subscription identifiers, the product purchased, the amount and the payment status. We never see your card number.

7. Disclosure to third parties

We do not sell, rent or share any personal information for advertising. We disclose information only:

Our providers are bound by contract or by their terms of service to protect your information and to use it only to provide their services to us.

8. Transfers outside Quebec, Canada and the European Union

Our commercial web host, MochaHost, operates servers that may be located in the United States. Stripe processes payment data in places including the United States, Ireland and Canada. Your information may therefore be processed outside Quebec, Canada, the European Union or the United Kingdom, where laws may offer different protection.

• Quebec: before disclosing information outside Quebec, we carried out a privacy impact assessment. It considers the sensitivity of the information (low, thanks to hashing and the absence of names and readable emails), the purposes, contractual protection measures and the legal framework of the receiving state.
• European Union and United Kingdom: transfers rely on the European Commission's standard contractual clauses (and the UK Addendum) or, where applicable, on the EU-U.S. Data Privacy Framework and its UK Extension when the recipient is certified.

You can request more information about these safeguards at privacy@ludogenie.com.

9. Retention and deletion

At the end of these periods, information is deleted or irreversibly anonymized.

9.1 Deleting your Lamp

The "Delete my Lamp" button in the app deletes your rights and your server-side data. Only the records the law requires us to keep (for example movements linked to a purchase) are retained, isolated, for the required period. You can also write to privacy@ludogenie.com. Deletion is permanent: an active Pass and purchased tokens will be lost. To delete your payment data at Stripe and your Link account, also contact Link (link.com).

10. Security

We protect your information with reasonable measures suited to its sensitivity:

• TLS encryption of all communications;
• non-extractable lamp keys and cryptographic signatures on every sensitive request;
• salted hashing of the email and the technical fingerprint;
• an audit log of sensitive operations;
• restricted administrator access protected by two-factor authentication;
• data minimization: we collect only what is needed.

No system is perfectly secure. Protect your devices and never share a pairing or recovery code.

11. Confidentiality incidents

We keep a register of confidentiality incidents. If an incident presents a risk of serious injury, we promptly notify the Commission d'accès à l'information du Québec and the affected persons. Where the law requires it, we also notify the Office of the Privacy Commissioner of Canada and, within 72 hours where required, the competent European or UK supervisory authority. Because we do not keep your email in readable form, a notice may be displayed in the app or posted on the website.

12. Automated decisions

Ludo Genie does no profiling. Some technical decisions are automatic, for example refusing a new free access period when the anti-abuse fingerprint matches a recent one, or enforcing device limits. If such a decision affects you, you can ask for the information used and the reasons for the decision, and submit your comments to support@ludogenie.com: a person will review the decision.

13. Your rights

13.1 All players

Wherever you live, you can:

• find out whether we hold information about you and get a copy (access);
• have inaccurate information corrected (rectification);
• receive your information in a structured, commonly used technological format (portability), and ask that it be sent to a third party;
• withdraw your consent or object to processing, subject to what is necessary for the Service or required by law;
• request deletion of your information or de-indexing, where the law provides for it;
• file a complaint (section 16).

13.2 Quebec and Canada

Under Quebec law and PIPEDA, you have in particular the rights of access, rectification, portability and withdrawal of consent, as well as the right to be informed of decisions based exclusively on automated processing.

13.3 European Union, European Economic Area and United Kingdom

You also have the rights to restriction of processing and to object to processing based on legitimate interest, as well as the right to set instructions for your data after your death (France). Ludo Genie has not appointed a representative in the European Union or the United Kingdom. For any question, write directly to the Person in Charge of the Protection of Personal Information at privacy@ludogenie.com.

13.4 United States (California and other states)

Depending on your state's law (for example the CCPA as amended by the CPRA in California, or the laws of Colorado, Connecticut, Virginia, Texas, Oregon and other states), you can request to know, correct and delete your information, and opt out of its sale, its sharing for targeted advertising and profiling.

• Ludo Genie sells no personal information and shares none for cross-context behavioural advertising. We have not done so in the past 12 months.
• We process no sensitive information for the purpose of inferring characteristics.
• You can designate an authorized agent and appeal a refusal by writing to the same address.
• We will never treat you differently because you exercised your rights.

13.5 How to exercise your rights

Write to privacy@ludogenie.com. Since there is no account, we may ask you to confirm the request from a device in your Lamp or with a code sent to the email on your receipt. We never ask for more than needed to verify your identity.

We respond within 30 days (one month in the European Union and the United Kingdom, 45 days in the U.S. states concerned), with a possible extension where the law allows it, in which case we will let you know. This service is free, except for a manifestly abusive request.

14. Privacy signals

Ludo Genie honours Global Privacy Control (GPC) and Do Not Track (DNT) signals. Since we neither sell nor share any data, these signals confirm what we already do. When one of these signals is detected, we do not record your visit in the usage statistics.

15. Children

Ludo Genie is a general-audience service. It is not designed for or directed at children under 13. We do not knowingly collect any information about a child beyond what is technically necessary for the anonymous operation of the Service, which asks for no name, email or age.

• Children under 13, under 14 in Quebec, and people below the digital age of consent in their country (up to 16 in some European Union countries) must have a parent's or guardian's permission to make a purchase.
• A parent or guardian who believes we hold information about their child can write to privacy@ludogenie.com. We will delete it promptly.

16. Complaints

Please write to us first: we want to resolve the situation. You can also contact an authority:

17. Changes

We may update this policy. The date at the top of the page shows the latest version. For any significant change, a notice will be displayed in the app before it takes effect. We will never make a new use of your information without your consent where the law requires it.

18. Contact

Ludo Genie's Person in Charge of the Protection of Personal Information

• Email: privacy@ludogenie.com (or confidentialite@ludogenie.com, same inbox)
• General help and purchases: support@ludogenie.com
• Recovery and pairing codes are sent from noreply@ludogenie.com, which does not receive replies.

Ludo Genie, an operator established in Quebec, Canada.