Privacy Policy

Effective Date: 4 October 2025

This Privacy Policy explains how Ludo Malta Property Ads (“Ludo”, “we”, “our”, or “us”) collects, uses, discloses, and protects your personal information when you use our website https://ludo.com.mt, our WhatsApp bot, and related services (collectively, the “Platform”). By using the Platform, you acknowledge this Policy. Where required, we will obtain your consent.

1. Who We Are (Data Controller)

Controller: Ludo Malta Property Ads (Malta).
Contact: Contact Us

We are a digital media advertising platform. We are not a licensed real estate operator, agent, or broker.

2. Legal Basis & Compliance

We process personal data in accordance with the EU General Data Protection Regulation (GDPR) and Maltese law, including the Data Protection Act (Chapter 586). Depending on the activity, our legal bases include:

• Contract: account creation, posting and managing listings, communications with you.
• Legitimate interests: fraud prevention, security, moderation, improving and safeguarding the Platform.
• Consent: for certain WhatsApp interactions where required.
• Legal obligation: responding to lawful requests, retention obligations under Maltese or EU law.

3. What We Collect

• Account data: name (if provided), mobile number, authentication data, session information.
• Listing data: property title, description, price, locality, features (bedrooms, bathrooms, garages), images, status, timestamps.
• Communications: service messages (e.g. approvals, hidden status, violation notices) and your interactions with them.
• Technical data: IP address, browser/device information, request headers, logs.
• Moderation data: automated content flags, image checks, deletion logs, deduplication checksums.

4. How We Use Data

• Provide and manage your property listings.
• Send you service updates and notifications.
• Enable secure communication through our WhatsApp bot.
• Moderate and remove unlawful or non-compliant content.
• Protect the Platform against fraud, abuse, and misuse.
• Comply with legal obligations.

5. Image Moderation

All uploaded images must be lawful and property-related. We use automated tools to detect and block inappropriate or non-compliant images. Examples of prohibited content include pornography, nudity, explicit or sexual material, images of people/faces, animals, documents/IDs, violent or hateful material, illegal goods, and images with heavy advertising overlays. Non-compliant images are deleted without notice. Repeated violations may result in account suspension or permanent blocking.

6. Listing Descriptions

We may use automated tools to assist with readability and grammar. However, you remain solely responsible for ensuring that your descriptions are accurate, lawful, and reflect the true details of your property.

7. WhatsApp Bot

We use WhatsApp for account verification, property updates, and secure communication. Use of WhatsApp is also subject to WhatsApp’s own terms and privacy practices. We store only the minimum identifiers necessary to provide these services.

Privacy note: We do not publicly display your phone number on property listings. Communication is routed through our WhatsApp system so that your number remains protected.

8. Cookies & Similar Technologies

We do not use non-essential cookies or third-party tracking technologies on the Platform. No advertising or analytics cookies are set, and no profiling or behavioural tracking is performed.

Note: We only set strictly necessary technical cookies (such as short-lived session identifiers) required for secure logins and essential site functions. These cookies do not track you across websites, contain no personal data beyond what is required for functionality, and do not require consent under GDPR or the EU ePrivacy Directive.

If in the future we introduce optional cookies (for example, to remember preferences or improve services), we will update this Privacy Policy and our Cookie Policy, clearly inform users, and request consent where required by law.

9. Data Sharing

We do not sell or rent your personal data. We may share data only with trusted service providers acting on our instructions (for hosting, moderation, security, messaging, or support), or where required by law. Such parties are bound by confidentiality and data processing agreements.

10. International Transfers

If your data is transferred outside the European Economic Area, we apply appropriate safeguards such as contractual protections and technical security measures.

11. Data Retention

• Account data: kept for the lifetime of your account and up to 24 months after closure.
• Listings & images: while active and up to 12 months after deletion or expiry.
• Moderation logs: up to 12 months.
• Technical logs: typically up to 180 days.
• Backups: retained on a rolling basis, usually no longer than 35 days.

12. Your Rights

Under GDPR, you have the right to:

• Access your data.
• Request correction or deletion.
• Restrict or object to processing.
• Data portability (where applicable).
• Withdraw consent at any time.

To exercise your rights, please Contact Us. We may need to verify your identity before processing requests. You may also lodge a complaint with the Information and Data Protection Commissioner (IDPC) in Malta or your local authority.

13. Security

We apply technical and organisational safeguards, including encryption, access controls, and monitoring. However, no system is completely secure. You should also protect your account credentials and report suspected abuse immediately.

14. Children

The Platform is for persons 18+. We do not knowingly collect data from children. If you believe a child has used the Platform, please Contact Us so we can delete the data.

15. Updates to this Policy

We may update this Privacy Policy at any time. Updates will be posted here with a new effective date. Your continued use of the Platform after changes means you accept the updated Policy.

16. Contact

For questions or requests regarding this Privacy Policy, please Contact Us.