Privacy Policy

This is an English translation provided for convenience. If there is any difference, the Serbian version prevails.

Last updated: October 15, 2026.

This policy explains how Ludus Vibe, Miloš Stevanović PR Računarsko programiranje Ludus Digital Beograd, Džona Kenedija 31v, 11070 Novi Beograd, Serbia, Tax ID (PIB): 115065956, Registration number: 68066948 (hereinafter "Ludus Vibe" or "we") collects and uses information from visitors to our website ludusvibe.com (hereinafter our "Website"), people who register on our Website, users who subscribe to our platform, and individuals who communicate with our Website by email or in any other way (hereinafter "you" and "your").

By visiting our website, viewing its content, registering on our Website, subscribing to our platform and/or communicating with us by email or in any other way, you agree to the terms of this Privacy Policy.

Legal framework

Personal data is processed in accordance with the Law on Personal Data Protection of the Republic of Serbia (ZZPL, Official Gazette of RS No. 87/2018). The data controller is Miloš Stevanović PR Računarsko programiranje Ludus Digital Beograd.

When do we collect data?

We may collect and process your personal data in the following situations:

• when you sign up for our newsletter (by entering your name and email address)
• when you sign in or register on the Ludus Vibe platform
• when you order any product or service from us, or contact us by email or in any other way
• when you send us your email or other details in exchange for a free download from our Website
• when you fill in any surveys we may run
• when you use the platform: watch lessons, post in the Community or ask the AI assistant in a lesson a question
• when you visit our Website (through cookies or otherwise)

The types of data we collect include: name, email address, username, purchase and membership information, platform usage data (lessons watched, activity, Community posts and comments, questions to the AI assistant), your selected language, IP address and the country you connect from, browser type and time of visit.

Not all the data we collect can identify you personally. However, we do track and record user sessions to improve the site experience for our users. For this we use Google Analytics (through Google Tag Manager), Microsoft Clarity (heatmaps and session recordings), PostHog (usage analytics and session recordings) and DataFast (visit analytics). In session recordings, the content of form fields is masked. When you are signed in, analytics events are linked to your account's internal ID (without your name or email address). These tools may change as technology evolves and improves.

Our Website and the materials and services provided through it are not intended for children or anyone under 16. If someone under 16 wants to use our Website, that person is responsible for getting consent from their parents or legal guardians.

Legal bases for processing (Article 12 ZZPL)

We process your data on the following legal bases:

• Consent — for the newsletter, creating an account, transferring data to third parties, and analytics and marketing cookies where consent is required (visitors from the EEA, the United Kingdom and Switzerland)
• Performance of a contract — to provide access to the platform and process your membership
• Legal obligation — keeping transaction records as required by law
• Legitimate interest — improving the user experience (including visit analytics), tracking technical errors and keeping the platform secure (protection from abuse and automated attacks)

Why do we collect your data?

We use the data we collect from you in the following ways:

• To provide you with services and materials through our Website
• To give you information about the products, services and materials on our Website
• To meet our contractual obligations to you as part of any transaction or order involving our products, services and/or materials
• To contact you about our products and services through our newsletter

You can opt out of these communications at any time by following the instructions in them or by sending a request to [email protected].

Who do we share this information with?

We share the information you provide with third parties only in the ways described in this privacy policy. We do not sell, trade, rent or otherwise disclose personal data, except as listed below:

• Polar Software, Inc. — membership payments as the seller (Merchant of Record), invoicing and tax calculation
• Raiffeisen Bank a.d. Beograd — payment processing for memberships purchased through the bank
• Hetzner Online GmbH — server and database hosting (European Union)
• Cloudflare, Inc. — website delivery, attack protection and bot checks (Turnstile)
• Amazon Web Services (SES) — sending emails
• Google (Analytics, Tag Manager), Microsoft (Clarity), PostHog (EU servers) and DataFast — visit and usage analytics
• Meta Platforms (Meta Pixel) — measuring ad performance
• Sentry — technical error tracking (EU servers)
• Anthropic — the AI assistant in lessons (processes the text of the questions you send)
• Vimeo — playing video lessons
• Legal requirements — if required by law or legal proceedings, or if we cooperate with a law enforcement investigation

International data transfers

By using the third-party services listed above (e.g. Polar, Cloudflare, Amazon Web Services, Google, Microsoft, Meta, Anthropic), data may be transferred to countries of the European Union and the USA. Such transfers are made with appropriate safeguards — standard contractual clauses or the user's explicit consent, in accordance with Articles 65–69 ZZPL.

Data retention periods

Your rights (Articles 26–37 ZZPL)

Under the Law on Personal Data Protection, you have the following rights regarding your data:

• Right of access — you can request a copy of the data we hold about you
• Right to rectification — you can request correction of inaccurate or incomplete data
• Right to erasure — you can request deletion of data when processing is no longer necessary, except for data we are required by law to keep
• Right to restriction of processing — you can request that the use of your data be restricted
• Right to data portability — you can request your data in a structured, machine-readable format
• Right to object — you can object to processing based on legitimate interest
• Right to withdraw consent — you can withdraw consent at any time, without affecting the lawfulness of processing before the withdrawal

You can send requests to [email protected]. We will respond within 30 days of receiving your request.

Third-party cookies

Our website uses cookies to improve the experience of our users. Cookies are small pieces of information stored on your device when you visit our website. For visitors from the EEA, the United Kingdom and Switzerland, non-essential cookies are activated only after explicit consent through the cookie banner. For visitors from other countries, including Serbia, analytics and marketing cookies are on by default. More details are in our Cookie Policy.

You can control the use of cookies through your browser settings. However, our website may not work as intended if you choose to turn cookies off.

Changes to our Privacy Policy

Any updates or changes we make to this Privacy Policy will be published on our website. We reserve the right to make appropriate changes at any time, including when the law changes. We will notify you of significant changes by email at the address you gave us.

How to contact us

If you have any questions about our Privacy Policy, you can contact us at [email protected].