Version 1.1
Effective Date: July 21, 2026
I. Introduction
A. Scope
1. Welcome to the Privacy Policy (the “Policy”) of Ludlow Exchange, LLC and its
related, affiliated or subsidiary companies (collectively “Ludlow”, “we”, “us”,
“our”). This Privacy Policy applies to the Ludlow website (the “Site”), desktop
and mobile application (the “App”), and the Ludlow services (the “Services”
which includes the Site and App). “You/your/Member(s)” means you as a
Member of our Services.
B. Acknowledgement
1. By accessing the Services, you acknowledge this Policy and agree to be bound
by this Policy. If at any time you do not agree to this Policy, please do not use
the Services or provide us with any personal information.
C. Privacy Policy Changes
1. We reserve the right to modify this Policy at any time without notice. All
changes are effective immediately upon posting. Your continued use of the
Services after changes are posted constitutes your acknowledgement of the
modified privacy policy and agreement to abide and be bound by that privacy
policy. For reference, the effective date of this Policy is posted at the top of this
page. Therefore, it is important that you periodically check this page for changes
made to this Policy.
II. Information We Collect
A. Types of Information
1. Ludlow may collect information about you when you interact with our Services.
Information that we collect may depend on how you interact with Ludlow and
use the Services. A description of the types of information we may collect is
described in detail below.
a) Identifiers such as first name, last name, username or similar unique
personal identifier, online identifier, ID number, date of birth, copy of
government-issued ID, Social Security Number, email address, telephone
number, billing/postal address.
b) Profile Data such as username and password, user ID, and social media
account information such as identifiers and profile picture.
c) Legally Protected Characteristics such as age if you are over forty (40)
years of age.
d) Financial Information such as credit or debit card information, bank
account number, PayPal, Apple Pay or other third-party payment
information, payment details, or other payment information.
e) Commercial Data such as nature, frequency, and duration of Member
visits.
f) Internet and Other Electronic Network Activity such as device
fingerprint, internet protocol (IP) address, time zone setting and location,
operating system and platform and other technology on the devices used
to access the Services.
g) Usage Data includes information about how Members use the Services,
such as statistics regarding the opening and clicking on emails sent by
Ludlow, and activity on the App (including, for example, Member’s
activity, time spent, Member stats, referring/exit pages, and clickstream
data).
h) Marketing and Communications Information such as marketing
campaign data, click-throughs, Member consent and preferences,
Member habits, and marketing phone, text, email and webchat
communications.
i) Audio and Visual Information such as selfie photographs.
j) Biometric Information such as a faceprint (i.e., face geometry of a
person’s facial features).
k) Geolocation Data such as the approximate location information
associated with your IP address, Wi-Fi, or cellular signal and precise
geolocation of your device.
l) Inference Data including inferences drawn from the personal
information identified above.
B. Sensitive Personal Information
1. We collect personal information that may be considered sensitive personal
information or sensitive data under state privacy law, including social security
number, driver’s license, passport, or other government-issued ID, biometric
information, and precise geolocation. We do not use or disclose sensitive
personal information for any business purposes other than as permitted by law,
including providing goods and services, verifying your
identity, processing payments, ensuring security and integrity of the Site and the
App, complying with applicable legal requirements and/or as permitted by
further regulations.
C. Information You Provide to a Third Party
1. The Services may include links or plug-ins to websites operated by third parties
such as TikTok, Discord, Instagram, LinkedIn, and X (“Third-Party Sites”).
Ludlow does not control any Third-Party Sites and is not responsible for any
information they may collect. The information collection practices of a
Third-Party Site are governed by its privacy policy. It is your choice to enter any
Third-Party Site. We recommend that you read its privacy policy if you choose
to do so.
D. Retention
1. For each of these categories of personal information, we will retain the
information as long as is reasonably necessary to fulfill the purpose for which it
was collected, to comply with applicable laws and regulations, and/or to support
any claim, defense, or declaration in a case or before a jurisdictional and/or
administrative authority, arbitration, or mediation panel.
III. Biometric Information
A. Description
1. Ludlow uses third-party technology through its vendors to collect, store, and use
biometric and other personal information, such as your faceprint, a selfie, and
government-issued identification.
B. Consent
1. By using our Services, you consent to Ludlow, our identity verification vendors,
and each of our contracted service providers, collecting, storing, and using your
biometric information for the purposes identified below.
C. Purpose for Collecting Biometric Information
1. Ludlow and its vendors may use biometric information for the following
purposes:
a) To verify your identity;
b) To prevent fraud;
c) To improve products and services, including improving artificial
intelligence models;
d) To comply with legal obligations.
D. Data Retention
1. This information is retained for as long as necessary to achieve the original
purpose for collecting it, or until three (3) years after your last interaction with
us, whichever happens first, provided we have no other legal obligation to retain
such information for any longer period.
IV . How We Collect Your Personal Information
A. Information You Provide To Us
1. Ludlow may collect personal information from you that you voluntarily provide
to us in various ways, including, but not limited to:
a) Registering for an account with us;
b) Trading in any of our markets;
c) Subscribing to receive updates and promotional offers;
d) Sending us an email or other communication; and
e) Following or joining any of our social networking channels.
B. Information We Collect When You Use Our Services
1. We also collect information, some of which may be personal information,
through automated means when you use our Services.
a) Automated technologies or interactions. As is true of most websites,
we receive and store certain types of personal information whenever you
interact with us online. This information may include IP addresses,
browser type, internet service provider (ISP), referring/exit pages,
operating system, date/time stamp, and/or clickstream data. When you
use the App from your mobile device, we receive data from that mobile
device. This may include your device ID, location data, IP address, and
device type. You may manage how your mobile device and mobile
browser share location information with us, as well as how your mobile
browser handles cookies and related technologies by adjusting your
mobile device privacy and security settings. Please refer to instructions
provided by your mobile service provider or the manufacturer of your
device to learn how to adjust your settings. In some of our email
messages or push notifications (“Messages”) we may use a click-through
URL linked to content on our Services. When you click one of these
URLs, you will pass through our web server before arriving at the
destination web page. We track this click-through data to help us
determine interest in particular topics and measure the effectiveness of
our Services. If you prefer not to be tracked through our Messages,
simply avoid clicking text or graphic links in the Message.
b) Cookies and Tracking Technologies. We and our service providers may
use cookies, pixels, and other tracking technology to recognize your
browser or device and to capture and remember certain information
about your activities on the Site or App. For example, cookies gather
information about how long you spend on a web page so that we can
understand what web pages are of interest to Members. If you prefer, you
can choose to have your computer warn you each time a cookie is being
sent, or you can choose to turn off cookies by adjusting your browser
settings. If you turn off your cookies, some of the features of the Site or
App may not function properly. Pixel tags generally work in conjunction
with cookies, registering when a particular device visits a particular
page. You cannot decline pixel tags; however, if you turn off cookies the
pixel tag will simply detect an anonymous visit. In addition, we use pixel
tags in our HTML-based emails to let us know which emails have been
opened by the recipients. This allows us to gauge the effectiveness of
certain communications and the effectiveness of our marketing
campaigns. If you prefer not to be tracked through our emails, most
email services will allow you to turn off pixels by disabling external
images in settings.
c) Analytics. We use third-party providers to assist us in better
understanding how Members use our Services. For example, we use
Google Analytics to help us understand how our Members use our
website and our apps. For more information on Google Analytics, visit
Google’s Privacy and Terms. You can access the Google Analytics Opt
Out Browser Add-on, currently located here. You can also opt out of
advertising cookies using the Google Ad Settings.
d) Your ‘Do Not Track’ Browser Setting. Some web browsers incorporate
a Do Not Track (“DNT”) feature that signals to the websites that you
visit that you do not want to have your online activity tracked. At this
time, the Site and the App do not respond to DNT signals. Ludlow may
allow certain third-party advertising partners to place tracking
technology, such as cookies and pixels on our Services. This technology
allows us and/or third-parties to collect personally identifiable
information about your online activities over time and across different
websites.
C. Information We Collect From Third Parties
1. We collect personal information from various third parties, including those listed
below. The collection, use, and disclosure of personal information received from
third parties is governed by the privacy policies listed on the website where the
information was submitted by the Member. Third parties may send their own
cookies and pixel tags to you, and may collect information and use it in a way
inconsistent with this Policy. Please carefully review these third-party privacy
policies to understand how your information may be collected, used and
disclosed by these third parties.
a) Third-Party Service Providers. We collect personal information from
service providers including payment processors, geolocation providers,
identity verification providers, marketing and communications service
providers, and business intelligence providers.
b) Social Media Services. When you create an account using your Apple
or Google login, we receive personal information from those third-party
social media websites, which may include your public profile
information and email.
c) Third-Party Advertising Partners. We collect personal information
received from third-party advertising partners, including partners who
host and manage various online advertisements and ad platforms. This
may be combined with the website analytics data described above.
d) Account Linking Providers. We use a third-party provider to let you
securely link your bank account for deposits and withdrawals. When you
link an account, we receive information from that provider, such as
confirmation of account ownership, bank account details, and
verification results, as reasonably necessary to enable funding and
payouts. The provider’s collection and use of your information is
governed by its own privacy policy.
V . How We Use Your Personal Information
A. Business Purposes
1. Our primary purpose in collecting personal information is to provide you with
the products and services that you have ordered or requested with a safe,
smooth, efficient, and customized experience. We may also use your personal
information for the following business purposes:
a) Provide you with our Services and to operate our business.
b) Verify your identity and account information in connection with our
Services you request.
c) Comply with our legal and regulatory obligations, including those
applicable to us as an entity regulated by the Commodity Futures
Trading Commission (CFTC) and as the operator of a CFTC-designated
contract market, such as identity verification, recordkeeping, reporting,
market surveillance, and anti-money-laundering and
know-your-customer requirements.
d) Provide you with required notices, updates about our content, products
and services as well as other important information.
e) Provide you with recommendations for content, products, and services
that we believe would be of interest to you.
f) Assist you with setting up and managing your account with us.
g) Resolve disputes and/or questions about our Services.
h) Problem troubleshooting, data analysis, testing, system maintenance,
support, reporting and hosting data.
i) Enforce the terms for use of our Services and the terms of this Policy.
j) Customize, measure, and improve our Services and content, including
improvement and customizations to artificial intelligence models owned
by us and our third-party service providers.
k) For our own internal business purposes.
l) Communicate with you about content, products, services, updates,
events, promotional offers, research, insights, and other information that
may be of interest to you from us and our trusted partners.
m) Protect our interests, including establishing, exercising, and defending
legal rights and claims.
n) As necessary to comply with legal requirements, to prevent fraud, to
co-operate with law enforcement and regulatory authorities, and to stop
other prohibited, illegal, or harmful activities.
o) For purposes disclosed at the time you provide/we request your
information or as otherwise set forth in this Policy.
VI. How We Disclose Your Personal Information
A. Disclosure to Third Parties
1. We disclose your personal information to third parties as described in this Policy
and to our business partners, suppliers and sub-contractors in order to provide
you with our goods and services and perform any contract we enter into with
them or you.
a) Service Providers. We may use third-party service providers to perform
certain business services and may disclose your information to such
service providers as needed for them to perform these business services.
Business services provided include but are not limited to: hosting
services; account authentication and identity verification services; billing
and accounting services; payment processors services; marketing,
promotional and email services; and customer and technical support
services.
b) Internal Third Parties. We may share your information with our
affiliated entities, parent company, subsidiaries, successors,
predecessors, assigns, or licensees, who may use the information for the
purposes described above.
B. Categories of Personal Information Shared for a Business Purpose
1. Categories of personal information that have been shared with service providers
and internal third parties for a business purpose in the past twelve (12) months
include identifiers, profile data, financial information, commercial data, usage
data, legally protected characteristics, internet or other electronic network
activity information, marketing and communications data, audio and visual
information, geolocation data, inference data, and sensitive personal
information, including biometric information.
C. Other Circumstances Personal Information May Be Disclosed
1. In certain circumstances, we may also share your personal information as
follows:
a) SMS Messages for Multifactor Authentication. We use a third-party
service provider to send SMS text messages for multifactor
authentication (“MFA”) during the Member sign-in process. For
Members that opt-in to receive SMS messages for MFA, the third-party
service provider processes personal information, specifically your phone
number and message metadata, on our behalf and under our instructions.
The verification codes in the authentication messages are temporary and
expire shortly after they are issued. We do not use SMS messages for
marketing or promotional purposes, and text messaging originator opt-in
data will not be shared with any other third parties except as may be
required by legal process or in connection with a business transaction as
described below.
b) Business Transactions. If we seek investors or go through a business
transition, including but not limited to, an acquisition of another
business, merger, acquisition by another company, or a sale of all or a
portion of our assets, your information will likely be shared as part of the
negotiation of the transaction and will likely be among the assets
transferred to the new owners in the event of a change in our business.
c) Legal Process. Subject to applicable law, we may also disclose or share
your information when required to do so by law, regulation or legal
process, to cooperate with law enforcement authorities, banking
providers or payment service providers and/or in connection with
investigations or other legal proceedings of suspected or actual unlawful
activity, when we believe disclosure is necessary or appropriate to
protect against misuse or unauthorized use of the Services, to limit our
legal liability and protect our rights or to protect the rights, property or
safety of Members of the Services or the public.
d) Profiles. Members may make their profile and stats publicly available to
other players of the Services.
e) Member Disclosures. Some personal information is disclosed as a
matter of course as a result of your use of our Services. Any personal
information shared via any shared or public forum using our Services,
such as, when sharing your experience on another website (such as
TikTok, Discord, Instagram, or X) may become public information. You
should exercise caution when disclosing information in these areas,
especially your location data, and be careful how you disclose your
personal information. YOU ASSUME ALL RESPONSIBILITY FOR
ANY LOSS OF PRIV ACY OR OTHER HARM RESULTING FROM
YOUR OWN VOLUNTARY DISCLOSURE OF PERSONAL
INFORMATION IN SHARED AND PUBLIC FORUMS.
D. Personal Information Sold or Shared for Targeted Advertising
1. Ludlow does not sell any personal information for monetary compensation and
has no actual knowledge of any sales or sharing of personal information of
minors under sixteen (16) years of age. We have shared personal information
with our third-party advertising partners to serve ads to you about our Services
as you browse the Internet (aka targeted advertising). This means that these
third-party service providers may use their own cookies or tags to track your
online activities and purchases in order to deliver targeted advertising based on
your interests. Additionally, as part of this advertising activity, we may also
share a common identifier (such as a hashed email address or user ID) with our
third-party advertising partners to customize advertising campaigns and ensure
existing customers are not served targeted ads. These activities may be
considered “selling” or “sharing” under certain privacy laws. You can opt out
using the Your Privacy Choices link. Additionally, if your browser supports it,
you can turn on the Global Privacy Control (GPC) to opt out of the sharing of
your personal information for targeted advertising. Learn more at the Global
Privacy Control website.
VII. Communications and Opt-Out
A. Marketing Communications
1. Depending on your marketing settings and preferences, we may use your
information to let you know about our products, services and offers or other
initiatives that may be of interest to you and we may contact you to do so by
email or push notification. Additional information about these marketing
activities, including options for opting out are described below.
a) Email. We may send you emails concerning our products and services,
as well as those of third parties. You may opt out of promotional emails
by following the unsubscribe instructions in a promotional email. This
opt-out will not apply to operational or informational emails related to
your account such as correspondence providing information about your
purchases or other such communications for which we have a legal
obligation to inform you and/or to prevent fraud or harm to our Services,
our business, and/or third parties. You may continue to receive
promotional email messages for a short period while we process your
request.
b) Push Notifications. Where you have chosen at a device level to begin or
continue receiving push notifications from us, we may send you push
notifications relating to our products, services, offers and other
marketing initiatives. You can choose to stop receiving push notifications
from us at any time by changing your preferences on your mobile device.
VIII. Your State Privacy Rights
A. Applicability
1. Please note that state privacy laws do not apply to certain entities or categories
of personal information. Because we are a financial services provider, much of
the personal information we collect about you is nonpublic personal information
subject instead to other financial privacy laws. As a result, certain state privacy
laws may not apply.
B. Your Rights
1. Depending on your jurisdiction of residence, you have certain rights with
respect to your personal information. This section describes your privacy rights
and explains how to exercise those rights.
2. Right of Access and Portability.
a) You have the right to confirm whether we are processing your personal
information and to access such personal information we process. You
may exercise this right not more than two (2) times per calendar year.
This includes the right to know: (i) the categories of personal
information we collected about you; (ii) categories of sources from
which the personal information is collected; (iii) the categories of
personal information sold or shared for purposes of cross-contextual
advertising to a third party, as well as the categories of third parties to
whom such personal information was sold or shared; (iv) the categories
of personal information that the business disclosed about the consumer
for a business purpose and the categories of persons to whom it was
disclosed for a business purpose; (v) our business or commercial purpose
for collecting, selling, or sharing for purposes of cross-contextual
advertising your personal information; and (vi) the specific pieces of
personal information we collected about you.
b) You also have the right, to the extent the information is available in a
digital format, to obtain a copy of your personal information in a
portable and, to the extent technically feasible, readily usable format that
allows you to transmit the data to another controller without hindrance.
3. Right to Correct. You have the right to correct inaccurate personal information
that we maintain about you, though we may need to verify the accuracy of the
new data you provide to us.
4. Right to Delete. You have the right to request that we delete personal
information that we collected about you under certain circumstances. Please
note, that some information may not be eligible for deletion based upon
applicable law or requirements of contracts.
5. Right to Limit the Use or Disclosure of Sensitive Personal Information. You
have the right to request that we limit the use and disclosure of sensitive
personal information to specific business purposes. Our use of sensitive personal
information is already limited to the approved business purposes identified
above.
6. Right to Opt-Out. You have the right to opt out of processing personal
information for the purposes of: (i) targeted advertising, (ii) the sale of personal
information, or (iii) profiling in furtherance of a decision that produces a legal or
similarly significant effect.
7. Right to Withdraw Consent. You have the right to withdraw your consent at
any time where we are relying on consent to process your personal information.
If you withdraw your consent, we may not be able to provide certain products or
services to you.
8. Right to Non-Discrimination. Unless permitted by applicable law, we will not
discriminate against you for exercising any of your privacy rights under
applicable law.
IX. Exercising Your Privacy Rights
A. Procedure
1. Requests to know, correct, or delete can be submitted by email to
[email protected]. You can opt out of having your personal information shared
or sold to third parties for targeted marketing by clicking on the Your Privacy
Choices link. Additionally, if your browser supports it, you can turn on the GPC
to opt out of the sharing of your personal information for targeted online
advertising. You can learn more about the GPC and how to enable it in your
browser from the Global Privacy Control website.
2. Only you or a person that you authorize to act on your behalf, may make a
verifiable consumer request related to your personal information.
B. Authorizing an Agent to Act on Your Behalf
1. Where applicable and except where you have provided an agent with a Power of
Attorney pursuant to Sections 4000 – 4465 of the California Probate Code, when
using an authorized agent you must provide that person with written permission
clearly describing their authority to make a request on your behalf. That agent
must also be able to verify their identity with us and provide us with their
authority to act on your behalf. An individual to whom you have provided
Power of Attorney pursuant to applicable state rules may also make a request on
your behalf. We may deny a request from an authorized agent if the agent does
not provide us with the signed written permission demonstrating that they have
been authorized to act on your behalf.
C. Verifying Your Request
1. The verifiable consumer request initiated by you or your authorized agent must:
a) Include your full legal name, email and phone number, which we will
need to contact you in order to verify that you are the person about
whom we collected personal information or an authorized representative.
b) Describe your request with sufficient detail that allows us to properly
understand, evaluate, and respond to it.
c) If you are making the request as an authorized agent you must also
provide the full legal name of the party for which you are making the
request and documentation on which your authorization is based.
2. We cannot respond to your request or provide you with your personal
information if we cannot verify your identity or authority to make the request
and confirm the personal information relates to you. Making a verifiable
consumer request does not require you to create an account with us. One of our
representatives will contact you in order to verify your identity. You may need to
provide additional information in order to verify your request. We will only use
personal information provided in a verifiable consumer request to verify the
requestor’s identity or authority to make the request.
D. Response Timing and Format
1. We endeavor to respond to a verifiable consumer request within forty-five (45)
days of its receipt. If we require more time (up to ninety (90) days), we will
inform you of the reason and extension period in writing. We will deliver our
written response by mail or electronically, at your option. The response we
provide will also explain the reasons we cannot comply with a request, if
applicable.
2. We do not charge a fee to process or respond to your verifiable consumer
request unless it is excessive, repetitive, or manifestly unfounded. If we
determine that the request warrants a fee, we will tell you why we made that
decision and provide you with a cost estimate before completing your request.
E. Appeals. Depending on applicable law, you may have the right to appeal any decision
that includes a refusal to take action on a request. If applicable, you can file an appeal by emailing us at [email protected] within fifteen (15) calendar days from receipt of our decision.
F. Exceptions
1. These rights are not absolute and are subject to certain exceptions. For example,
we cannot disclose or permit access to specific pieces of personal information if
granting your request would present a certain level of risk to the security of the
personal information at issue, your account with us or the security of our
Services. We may deny your deletion request if retaining the information under
certain circumstances, for example, when it is necessary for us or our service
providers to complete a contract or transaction with you or to comply with legal
obligations.
G. Other California Privacy Rights. California Civil Code Section 1798.83 permits
California residents who have provided personally identifiable information to us or our
third-party advertisers and marketing partners, if any, to request certain information
regarding our disclosure of personally identifiable information to third parties for their
own direct marketing purposes (if any). Requests should be submitted via email to
[email protected] and should include CALIFORNIA PRIV ACY RIGHTS in the
subject line. Please be aware that not all information sharing is covered by the
requirements of Section 1798.83 and only information on covered sharing will be
included in our response. This request may be made no more than once per calendar
year.
X. Age Restriction
The Services are intended for Members aged twenty-one (21) and older. If you are under the
age of twenty-one (21), you are not authorized to provide us with any personally identifying
information, nor access or use our Services in any manner whatsoever. By using the Services,
you represent that you are twenty-one (21) years of age or older.
XI. Contact
If you have any questions about our privacy practices or this Policy, or wish to update your
information, please send an email to [email protected].