Date: Mar 10, 2023
1. What is a “Vulnerable Person”?
A vulnerable consumer is a consumer who is less likely to be able to make fully informed or rational decisions due to a specific characteristic, circumstance, or need, and may be likely to suffer detriment as a result.
Within Ludico Business SL, we offer the following services/ content and are aware that the following characteristics, circumstances, or needs displayed by a consumer might make them vulnerable in respect of these services/ content. As such, creation, operation and promotion of these services will need to be considered with these persons in mind.
| Service/ Content | Specific characteristic, circumstance, or need displayed |
|---|---|
| ICSS service | Low income group |
2. Responsible Person
At Ludico Business SL the person responsible for ensuring the needs of vulnerable persons are met in the phone-paid service environment is Mr. José Ignacio Andrade, who can be contacted at info@ludicobusiness.com or on +34 91 557 12 30.
3. Risk Assessment and Controls:
| Risk | Level of Risk | Control/ Mitigation | Review Date | Additional Comments |
|---|---|---|---|---|
| Mental Health Challenges - Addiction | NONE | Excessive use policy (see point 4.1) | Mar 9, 2023 | |
| Mental Health Challenges - Anxiety | NONE | Mental Health Policy (see point 4.5) | Mar 9, 2023 | |
| Learning Difficulties | NONE | N/A | Mar 9, 2023 | |
| Financial Challenge | MED | Low Income Policy (see point 4.6) | Mar 9, 2023 | |
| Phone has been stolen | LOW | Customer statement / Refund | Mar 9, 2023 | |
| Phone has been used without permission | LOW | Customer statement / Refund | Mar 9, 2023 |
4. Additional Policies Required
The additional policies we require in order to protect vulnerable people are:
Excessive Use Policy
4. 1 - Excessive Use Policy
Our Excessive Use Policy is based on the continuous analysis of the calls received. When we detect that a telephone number makes more than 20 calls in a week through our service, it becomes part of a registry of telephone numbers with a special risk of complaints. In this way, if the customer asks us for a refund of the cost incurred, the resolution of his claim is carried out quickly and without ambiguity.
4. 2 - Age Verification Policy
We do not provide any adult content, so we do not use a concrete age verification process. However, we clearly indicate in the service information that you must be of legal age to use it.
4. 3 - Bereaved Person Policy
Since our service is provided in a fully automated way with no staff intervention, there is no risk that a bereaved person could be exploited. Only through the communication of this type of customer with our customer service channels could their status be revealed to us, a situation in which they will be given preferential and careful treatment, as a differentiated communication with respect to customers without this personal situation.
4. 4 - Ill Health Policy
Once again, due to the automation of our service and the absence of human intervention in it, our Ill Health Policy focuses on the communications that the customer may generate with our customer service channels. In these cases, in which the client informs us of his/her situation, the communication is adapted to his/her state to avoid major concerns.
4. 5 - Mental Health Policy
Our Mental Health Policy links directly to our Ill Health Policy. Like that, only at the time of communication with our customer service channels will we be able to discriminate communication to this type of customer, using more neutral and careful messages with them. On the other hand, given the nature of the service, we do not believe that this type of customer is particularly exposed, given that the service (call connection) does not generate addiction or anxiety in itself.
4. 6 - Low Income Policy
Due to the service we offer and its potentially high cost for low-income people, our Low Income Policy is based on several aspects:
We make available to potential customers the links to obtain the desired information at no cost.
5. Policy Review
We shall review the policies listed above by the review date stated on page 1 and determine whether they are having the expected impact using the matrix below:
| Policy | Expected Impact | Actual Impact | Changes Required (if any) |
|---|---|---|---|
| Excessive Use Policy | LOW | LOW | --- |
| Age Verificaiton Policy | NONE | NONE | --- |
| Bereaved Person Policy | LOW | LOW | --- |
| Ill Health Policy | LOW | LOW | --- |
| Mental Health Policy | LOW | LOW | --- |
| Low Income Policy | LOW | LOW | --- |
6. Complaints Procedure
Ludico Business’s Complaints Procedure is available at: Appendix 1 to this template.
7. Refund Policy
Ludico Business’s Refund Policy is available at: Appendix 2 to this template.
8. Privacy Policy
Ludico Business’s Privacy Policy is available at: Appendix 3 to this template.
SIGNED for and on behalf of Ludico Business, S.L.
Name: Raul de Castro
Title: Director
Dated: 14th November 2023
We are aware that given the nature of our service, it is possible that complaints and claims may be generated, related above all to its cost.
To facilitate the reception of these complaints, we have made available to customers who require it two ways to transmit them:
1. Through the email address info@ludicobusiness.com
2. Through the customer service telephone number +34 91 557 12 30
Both possibilities are clearly visible on the web pages of the service.
The treatment of the complaints received in both media is carried out daily, estimating the resolution time of the same in a maximum of five days from the reception of the complaint until the end of the process, generally with a refund of the total cost incurred.
Considering the service we offer and the costs that customers might incur, our refund policy is straightforward and simple.
When a refund claim comes through our customer service channels, it is automatically given priority treatment.
After requesting the customer the necessary information to verify the use of the service and the cost that it has entailed (invoice from his/her telephone operator, date and approximate time of the call and telephone number from which the call was made), if everything is in order, a transfer of the amount of the service will be made to the bank account that the customer indicates. This transfer will be made within 5 days of receipt of the requested information, thus minimizing the resolution time of the incident.
Effective date: Nov 14, 2023
Ludico Business SL (“us”, “we”, or “our”) operates the website and a directory enquiry service (the “Service”).
This APPENDIX informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.
We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.
Definitions
Information Collection And Use
We collect several different types of information for various purposes to provide and improve our Service to you. Types of Data Collected:
Personal Data. While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to Phone number and Contact Details, Cookies and Usage Data.
Usage Data
We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Use of Data
We use the collected data for various purposes:
Retention of Data
We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Transfer Of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to United Kingdom and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
Disclosure for Law Enforcement
Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Legal Requirements
We may disclose your Personal Data in the good faith belief that such action is necessary to:
Security Of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Your Rights
We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
Whenever made possible, you can update your Personal Data directly within your account settings section. If you are unable to change your Personal Data, please contact us to make the required changes.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the right:
You have the right to data portability for the information you provide to us. You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it. Please note that we may ask you to verify your identity before responding to such requests.
Service Providers
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Links To Other Sites
Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Children’s Privacy
Our Service does not address anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
Changes To This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on the website.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.