Privacy Policy

Effective: 14 May 2026

1. Data Controller

LudusNovus LLC
Marian van der Elst, Managing Member
1209 Mountain Road Pl NE, Ste N
Albuquerque, NM 87110, USA
Email: info@ludusnovus.com

Although our company is based in the United States, our services are directed in part at persons in the European Economic Area (EEA) and Switzerland. We therefore process personal data in accordance with the EU General Data Protection Regulation (GDPR) and the revised Swiss Federal Act on Data Protection (revFADP).

2. What Data We Collect

2.1 When Visiting the Website (Automatic)

When you visit our website, our hosting provider automatically collects and stores the following data in server log files:

  • IP address (anonymized)
  • Date and time of access
  • Page accessed
  • Browser and operating system used
  • Referrer URL

This data is used exclusively to provide the website technically and to ensure system security. It is not combined with other data sources.

Legal basis: Art. 6 (1) (f) GDPR (legitimate interest in providing a secure website).

2.2 When Submitting the Inquiry Form

When you submit our case inquiry form, we collect:

  • Name
  • Company
  • Email address
  • Phone number (optional)
  • Content of your inquiry (problem, attempts so far, consequences, timing)

This data is used exclusively to process your inquiry and to initiate a potential advisory engagement.

Legal basis: Art. 6 (1) (b) GDPR (pre-contractual measures) and Art. 6 (1) (a) GDPR (consent through form submission).

2.3 When Engaging Our Services

When you book a session or communicate with us in the course of an advisory engagement, we additionally collect:

  • Business information you share with us for the advisory work
  • Content of advisory conversations (in note form)
  • Billing address and payment information (processed by our payment providers)

Legal basis: Art. 6 (1) (b) GDPR (contract performance).

3. Third-Party Services and Data Processing

3.1 Hosting — Infomaniak

Our website is hosted by Infomaniak Network SA, based in Geneva, Switzerland. Infomaniak processes the data mentioned in section 2.1 on our behalf under a data processing agreement (Art. 28 GDPR). Infomaniak's servers are located in Switzerland and the company is ISO 27001 certified.

More information: infomaniak.com/en/legal/privacy-policy

3.2 Form Backend and Email Marketing — Encharge

The inquiry form embedded in our website is processed via Encharge (Encharge Inc., USA). When you submit the form, the data you enter is transmitted to Encharge and forwarded to us.

Legal basis: Art. 6 (1) (b) GDPR. Data transfer to the United States is based on the EU-U.S. Data Privacy Framework and EU Standard Contractual Clauses (Art. 46 (2) (c) GDPR).

More information: encharge.io/privacy-policy

3.3 Payment Processing — Wise, Payoneer, Stripe

For payment processing, we use one or more of the following providers, depending on the client's preference and location:

  • Wise (Wise Payments Limited, United Kingdom / Wise US Inc., USA)
  • Payoneer (Payoneer Inc., USA)
  • Stripe (Stripe Payments Europe Ltd., Ireland / Stripe Inc., USA)

When you make a payment, the data necessary for processing (name, email, billing address, payment data) is transmitted to the respective provider.

Legal basis: Art. 6 (1) (b) GDPR (contract performance). Data transfers to third countries are based on the EU-U.S. Data Privacy Framework where applicable, as well as EU Standard Contractual Clauses.

3.4 Email Communication — Proton and Infomaniak

Our business email communication runs through Proton Mail (Proton AG, Geneva, Switzerland) and/or Infomaniak Mail (Infomaniak Network SA, Geneva, Switzerland). Incoming and outgoing emails are processed and stored there. Both providers are based in Switzerland and known for high data protection standards.

3.5 Fonts

This website uses fonts hosted locally on our server. No connection to external font providers (e.g. Google Fonts) takes place.

4. No Cookies, No Tracking

Our website does not set cookies and does not use any tracking or analytics tools. We do not use Google Analytics, Facebook Pixel, or any comparable services. No profiling takes place.

5. Data Transfer to Third Countries

Since our company is based in the United States, personal data is transferred to the US. The United States has had an EU Commission adequacy decision since July 2023 (EU-U.S. Data Privacy Framework). Additionally, we base data transfers on EU Standard Contractual Clauses (Art. 46 (2) (c) GDPR).

Our hosting provider (Infomaniak) and our email providers (Proton, Infomaniak) are based in Switzerland. Switzerland has a corresponding adequacy decision from the EU, ensuring an adequate level of data protection.

6. Retention Period

We store your personal data only as long as necessary for the respective purpose or as required by statutory retention obligations.

  • Form data without contract: deleted after no later than 24 months
  • Contract data and invoices: in accordance with statutory retention periods, typically 10 years
  • Advisory notes: for the duration of the business relationship, then deleted upon request or no later than 5 years

7. Your Rights

You have the following rights at any time regarding your personal data:

  • Access (Art. 15 GDPR) — what data we have stored about you
  • Rectification (Art. 16 GDPR) — correction of incorrect data
  • Erasure (Art. 17 GDPR) — deletion of your data
  • Restriction (Art. 18 GDPR) — restriction of processing
  • Data portability (Art. 20 GDPR) — transfer of your data in a common format
  • Objection (Art. 21 GDPR) — objection to processing
  • Withdrawal of consent (Art. 7 (3) GDPR) — at any time with effect for the future

To exercise your rights, simply send an email to info@ludusnovus.com.

8. Right to Lodge a Complaint

If you believe that the processing of your data violates GDPR, you have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR). This can be done with the supervisory authority of your usual place of residence.

9. SSL Encryption

This website uses SSL encryption (recognizable by the lock icon in the address bar). All data transmitted through the website is encrypted.

10. Changes to This Privacy Policy

We reserve the right to amend this privacy policy as necessary to reflect changes in legal requirements or our services. The current version published on the website applies.