Privacy policy
Version 1.0 · In force from 1 September 2026 · Mobile app “Ludorbi” (iOS and Android)
This translation is provided for convenience. The French version is the only authoritative one.
In short
Ludorbi asks for no account and the publisher owns no application server. Your games, scores, favourites and preferences stay on your device and disappear with the app.
On the other hand, the app is free because it shows advertising. A third-party ad network — Google AdMob — therefore connects and collects an advertising identifier. Ludorbi is not an offline app: saying so would be false. The one-time purchase “Stop the ads” ends this collection.
1. Data controller
Guillaume POUPPA-BEJUY, sole trader operating under the trade name E-3P.
- SIREN
- 432 873 131
- SIRET
- 432 873 131 00077
- Registered office
- 3 Bis Avenue Moulins Les Metz, 69630 Chaponost, France
- Contact
- contact@e-3p.com
2. What data, and what for?
| Processing | Data | Legal basis | Recipient |
|---|---|---|---|
| Personalised advertising | Advertising identifier (IDFA on iOS, AAID on Android), advertising usage data, approximate device data | Consent (Google CMP compliant with the IAB TCF v2.2 framework, and App Tracking Transparency permission on iOS) | Google AdMob and its certified partners |
| Non-personalised advertising | Limited technical data (context, device), without profiling | Legitimate interest — funding a free app | Google AdMob |
| “Stop the ads” purchase (€4.99) | Anonymous app identifier and purchase receipt. No banking data passes through the publisher | Performance of the contract | RevenueCat, Apple's App Store, Google Play |
| Reporting an error in a rule | Your email address and the content of your message, if you choose to write to us | Legitimate interest — correcting the app's content | The publisher only (Infomaniak email) |
And that is all. The scores of your games, the history of your wins, your favourite games and your choice of theme never leave your device. Ludorbi knows neither who you are nor what you play.
3. Your advertising consent
On first launch in the European Economic Area, a consent window (Google CMP, compliant with the IAB TCF v2.2 framework) lets you accept or refuse personalised advertising. On iOS, the App Tracking Transparency permission is also requested.
If you refuse, the app remains fully functional: no game, no rule and no score keeper is reserved for people who accept. Only the advertising becomes non-personalised.
You can change your choice at any time from Settings → Change my privacy choice in the app, or from your device settings (iOS: Settings → Privacy → Tracking; Android: Google settings → Ads).
The one-time purchase “Stop the ads” (€4.99) removes both the video and the banner, permanently.
4. Service providers and transfers outside the EU
- Google AdMob (Google Ireland Ltd) — advertising and consent management
- RevenueCat Inc. (United States) — validation of the ad-free purchase
- Apple (App Store) and Google (Google Play) — processing of payments on their own platforms
Some of these providers are located outside the European Union. Transfers are covered by appropriate safeguards — standard contractual clauses of the European Commission, and/or certification under the EU-US Data Privacy Framework.
5. Retention periods
- By the publisher: no personal data kept — no account, no application server.
- On your device: scores, history and preferences, until the app is deleted.
- By third parties: according to their own policies — typically thirteen months at most for advertising trackers subject to consent.
- Your reports: kept for the time needed to handle the request and correct the sheet concerned.
6. Your rights
You have the rights of access, rectification, erasure, restriction, objection and portability. As the publisher holds no data about you, these rights are mainly exercised with the providers above — we can nonetheless help you: contact@e-3p.com.
You may lodge a complaint with the CNIL, the French data protection authority: www.cnil.fr.
7. Minors
Ludorbi is an app for general audiences, which is not specifically aimed at children and targets none. The publisher creates no profile, and advertising content is capped at the “parental guidance” level.
The catalogue describes traditional games some of which are played, in real life, for money — poker, baccarat, sette e mezzo. Ludorbi does not allow any stake, real or fictitious, and simulates no gambling: it keeps a score, like a sheet of paper.
8. Updates
This policy may change. The version in force, dated, is published permanently on this page, which can be reached from the “Settings” screen of the app.