Tugan.ai, Inc. (“Tugan.ai,” “we,” “us,” or “our”) provides a platform that provides tools designed to allow developers to build decentralized applications. This Privacy Notice is designed to help you understand how we collect, use, process, and share your personal information, and to help you understand and exercise your privacy rights.
1. SCOPE AND UPDATES TO THIS PRIVACY NOTICE
This Privacy Notice applies to personal information processed by us, including information collected through our websites, services, and other online or offline offerings (collectively referred to as the "Services"). Unless otherwise specified, this Privacy Notice does not apply to personal information provided by our customers when using our Services ("Customer Data"), which is governed by the customer's respective privacy policies regarding the collection and use of Customer Data. Our processing of Customer Data is governed by the contracts we have in place with our customers, not by this Privacy Notice. Any questions or requests about Customer Data should be directed to the appropriate customer's legal or privacy team.
Changes to our Privacy Statement. We reserve the right to make changes to this Privacy Notice at any time. We will notify you of any material changes to this Privacy Notice to the extent required by applicable law. You understand and agree that if you continue to use our Services after the new Privacy Notice goes into effect, you will be deemed to have accepted the updated Privacy Notice.
2. PERSONAL INFORMATION WE COLLECT
The types of personal information we collect are determined by how you interact with us and our Services, as well as the requirements of applicable law. As described below, we collect information that you provide to us, information that we automatically collect when you use our Services, and information from other sources such as third-party services and organizations.
A. Personal Information You Provide to Us Directly
- Account CreationWhen you create an account, we may collect personal information such as your name, email address, username(s), and professional details.
- Purchases.We may collect personal information and purchase details, including payment information, from you. Payments made through our Services are handled by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive payment-related information.
- Your Communications with Us.When you request information about our Services, register for our newsletter, educational programs, or other offerings, request customer or technical support, or otherwise communicate with us, we may collect personal information such as your email address, phone number, or mailing address.
- Surveys.We may contact you to invite you to participate in surveys. If you choose to participate in the survey, we may collect personal information from you.
- Interactive Features.Personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages) may be collected by us and others who use our Services. Any information you provide using the Services' public sharing features will be considered "public," unless otherwise required by applicable law, and is not subject to the privacy safeguards mentioned herein.
- Sweepstakes or Contests.We may collect personal information from you if you enter any of our sweepstakes or contests. We are required to publicly share information about sweepstakes and contest winners in some jurisdictions.
- Conferences, Trade Shows, and Other Events.When we attend or host conferences, trade shows, hackathons, socials or happy hours, and other events, we may collect personal information from individuals.
- Business Development and Strategic Partnerships.To assess and pursue potential business opportunities, we may collect personal information from individuals and third parties.
- Job Applications.We reserve the right to post job openings and opportunities. We may collect your personal information if you respond to one of these postings, such as your application, CV, cover letter, and/or any other information you provide to us.
B. Personal Information Collected Automatically
When you use our Services, we may automatically collect personal information.
- Automatic Collection of Personal Information. When you use our Services, we may automatically collect information such as your IP address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also collect information about your use of our Services automatically, such as the pages you visit before, during, and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
- Cookies. Cookies are small text files that are stored in device browsers to facilitate and enhance your experience.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code that is embedded in our Services and collects information about how our Services are used. We can use pixel tags to record, for example, that a user has visited a specific web page or clicked on a specific advertisement. Web beacons may also be included in e-mails to determine whether messages have been opened, acted on, or forwarded.
- Operationally Necessary. This includes technologies that give you access to our Services, applications, and tools needed to detect unusual website behavior, prevent fraudulent activity, improve security, or allow you to use our functionality.
- Performance-Related. We may use Technologies to evaluate the performance of our Services, including analytics to better understand how people use our Services (see Analytics below).
- Functionality-Related. We may employ Technologies that enable us to provide you with enhanced functionality when accessing or using our Services. This may include recognizing you when you sign into our Services or remembering your specified preferences, interests, or previous items viewed.
- Advertising or Targeting-Related. We may use first-party or third-party Technologies to deliver content, including advertisements relevant to your interests, on our Services or on third-party digital properties. To learn more about your privacy options and rights in relation to these technologies, see "Your Privacy Choices and Rights."
C. Personal Information Collected from Other Sources
Third-Party Services and Sources. Personal information about you may be obtained from other sources, including third-party services and organizations. For example, if you access our Services via a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect personal information about you that you have made available via your privacy settings from that third-party application.
3. HOW WE USE YOUR PERSONAL INFORMATION
As described below, we use your personal information for a variety of business purposes, including providing our Services, administrative purposes, and marketing our products and Services.
A. Provide Our Services
We use your information to carry out our contract with you and provide you with our Services, which include: Managing your information and accounts; Giving you access to specific areas, functionalities, and features of our Services Responding to customer or technical support requests; We will communicate with you about your account, our Services, and policy changes. Processing your financial information and other payment methods for purchased products or services; If you apply for a job that we post on our Services, we will process your application; and we will allow you to register for educational programs or other events, offerings, programs, or communities.
B. Administrative Purposes
We use your information for a variety of administrative purposes, including: Pursuing our legitimate interests, which include direct marketing, research and development (including marketing research), network and information security, and fraud prevention. Detecting security incidents, safeguarding against malicious deception, fraud, or illegal activity, and prosecuting those responsible; Measuring interest and participation in our Services; enhancing, upgrading, or improving our services; Creating new goods and services; Internal quality control and safety assurance; Individual identity authentication and verification, including requests to exercise your rights under this Privacy Notice; Auditing interactions, transactions, and other compliance activities; Debugging to identify and repair errors with our Services; Sharing personal information with third parties as necessary for the provision of the Services; Enforcing our agreements and policies; and Carrying out activities necessary to meet our legal obligations.
C. Marketing and Advertising our Products and Services
We may use personal information to tailor and deliver content and advertisements to you. We may provide you with these materials in accordance with applicable law. Email campaigns, text messages, custom audiences advertising, and "interest-based" or "personalized advertising," including cross-device tracking, are some of the ways we may market to you. If you have any questions about our marketing practices, please contact us at any time using the information provided in the "Contact Us" section below.
D. With Your Consent
We may use personal information for other purposes that are made clear to you when you provide personal information or with your consent.
E. Other Purposes
We also use your personal information for other purposes that you have requested or that are permitted by applicable law. De-identified and aggregated data We may use personally identifiable information to create de-identified and/or aggregated data, such as information about the device from which you access our Services or other analyses we create.
4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION
In order to provide our Services, protect ourselves and others, or in the case of a significant business transaction like a merger, sale, or asset transfer, as explained below, we may disclose your personal information to third parties for these and other business purposes.
A. Disclosures to Provide our Services
Below is a list of the different types of third parties with whom we might share your personal information.
- Service Providers. Your personal information might be disclosed to our third-party vendors and service providers who help us deliver our services. These companies and suppliers give us IT support, authentication, security, hosting, payment processing, analytics, alerting, customer service, and other related services.
- Business Partners. In order to give you the product or service you've requested, we might share your personal information with our business partners. Your personal information might also be disclosed to business partners with whom we co-brand goods and services.
- Affiliates. We may share your personal information with our company affiliates, if any.
- Advertising Partners. We might provide third-party advertising partners with access to your personal information. These third-party ad partners may install technologies and other tracking tools on our services to gather data about your activities and device (such as your IP address, cookie identifiers, page(s) visited, location, and time of day). When you visit digital properties within their networks, these advertising partners may use this information (along with similar data gathered from other services) to deliver tailored advertisements to you. This method is also known as "personalized advertising" or "interest-based advertising."
- APIs/SDKs. Application program interfaces ("APIs") and software development kits ("SDKs") from third parties may be used or provided by us as a component of the Services.
B. Disclosures to Protect Us or Others
We may access, preserve, and disclose any information associated with you to third parties if we believe it is necessary or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order; protect your, our, or others' rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution.
C. Disclosure Upon Merger, Sale, or Other Transfer of Assets
Your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract, if we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider.
5. YOUR PRIVACY CHOICES AND RIGHTS
Your Options for Privacy. The privacy choices you may have regarding your personal information are outlined below and are determined by applicable law.
- Email correspondence. If you ever receive an email from us that you don't want to receive, you can unsubscribe using the link at the bottom of the email or by getting in touch with us as described in "Contact Us" below. Keep in mind that you will still receive transaction-related emails about the goods or services you have ordered. Additionally, we might send you some non-promotional communications about us and our services; however, you won't be able to choose not to receive them.
- SMS texts. If you receive an unwanted text message from us, you can choose not to receive further texts from us by following the instructions in that text message or by getting in touch with us as described below under "Contact Us."
- Phone calls You can choose not to receive calls from us in the future if you receive an unwanted marketing call from us by following any instructions that may be provided on the call or by contacting us as described in "Contact Us" below.
- “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
- Personalized advertising and cookies. By changing your preferences as your browser or device permits, you can prevent or restrict the placement of Technologies on your device or remove them. But if you change your preferences, our Services might not function as intended. Please be aware that mobile applications cannot be blocked using cookie-based opt-outs. On some mobile applications, however, you can choose not to see personalized ads by doing so by adhering to the guidelines for Android, iOS, and other platforms. Additionally, the online advertising sector offers websites where you can choose not to receive targeted advertisements from data partners and other advertising partners who take part in self-regulatory initiatives. Visit the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada to access these resources and learn more about targeted advertising, consumer choice, and privacy. Please be aware that you must individually opt out of each browser and device.
Your Privacy Rights. In accordance with applicable law, you may have the right to:
- Access to and Portability of Your Personal Information, which includes: (i) determining whether we are processing your personal data; (ii) requesting access to or a copy of your personal data; and (iii) receiving an electronic copy of the personal data you have given to us or requesting that we send that data to another business in a structured, widely-used, and machine-readable format (also referred to as the "right of data portability");
- If your personal information is incorrect or lacking, request a correction. In some instances, we might offer self-service tools so you can update your personal data;
- Request the removal of your personal data;
- Request a restriction on our use of your personal information or object to it;
- Refuse to give us permission to process your personal information. Please be aware that your withdrawal will only apply to processing that will be done in the future; it will not have an impact on processing that was done legally prior to your withdrawal.
Please get in touch with us using the information under "Contact Us" if you want to make use of any of these rights. Such requests will be handled in accordance with relevant legal requirements.
6. SECURITY OF YOUR INFORMATION
We take precautions to guarantee the security and adherence to this Privacy Notice of the handling of your information. The security of any information you provide to us, however, is not warranted or guaranteed by us. We disclaim responsibility for unauthorized access, use, disclosure, or loss of personal information to the fullest extent permitted by applicable law. You agree that we may communicate with you electronically about security, privacy, and operational issues relating to your use of our Services by using our Services or by giving us personal information. If we become aware of a security system breach, we may try to alert you electronically by sending you an email, posting a notice on our Services, or sending you a letter.
7. INTERNATIONAL DATA TRANSFERS
Any information we process may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other nations with data protection regulations that may differ from those in your country of residence. We make an effort to protect your information in accordance with the requirements of any relevant laws.
The EU Standard Contractual Clauses are one of the safeguards we may use to support a transfer of personal data that originates in the European Economic Area, Switzerland, and/or the United Kingdom to a nation that has not been determined to provide an adequate level of protection under applicable data protection laws.
8. RETENTION OF PERSONAL INFORMATION
For as long as you use our services, or as long as it's necessary to fulfill the purpose(s) for which it was collected, provide our services, resolve disputes, establish legal defenses, conduct audits, pursue legal business purposes, enforce our agreements, and comply with applicable laws, we store the personal information we collect as described in this Privacy Notice.
9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
Additional Privacy Rights for Residents of California
Personal information "sales" as defined by the CCPA Tugan.ai does not "sell" personal information for CCPA purposes, nor do we have knowledge of any "sale" of personal information of minors under the age of 16.
Non-Discrimination. Residents of California have a right not to experience discrimination from us when exercising their CCPA-granted rights.
Appointed Agent. Only you, or a representative who is legally able to act on your behalf, may submit a verified consumer request pertaining to your personal data. A verifiable consumer request may also be made on behalf of your minor child. If you want to appoint an agent, you must do so in writing and have it signed by both you and the person you've chosen. For more information, get in touch with us using the information under "Contact Us" below.
Verification. Before completing your request, we will take steps to reasonably verify your identity in order to protect your privacy. These actions might entail requesting information from you that enables us to reasonably confirm that you are the person about whom we collected personal information or a legitimate representative, or they might entail asking you questions about your account and use of our Services. If you live in California and would like to exercise any of your CCPA rights, please get in touch with us using the information provided under "Contact Us" below. Such requests will be handled in accordance with relevant legal requirements.
Data that has been deidentified. Except to comply with applicable law, we will not attempt to reidentify de-identified information that we create or receive.
10. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
If you live in Nevada, you have the choice not to allow certain personal information to be sold to third parties who plan to either license or sell it. If applicable, you may exercise this right by sending us an email at the address provided below in the "Contact Us" section with the subject line "Nevada Do Not Sell Request" and identifying yourself along with the email address connected to your account. Please be aware that as defined in Chapter 603A of the Nevada Revised Statutes, we do not currently sell your personal information. Contact information is provided below in the Contact Us section if you have any questions.
11. CHILDREN'S INFORMATION
Children under the age of 16 are not intended for use with the Services, and we do not knowingly collect personal information from them. You can get in touch with us as stated in "Contact Us" below if you're a parent or legal guardian and think your child has uploaded personal information to our site without your permission. If we learn that a child has provided us with personal information in violation of applicable law, we will delete that information unless we are required by law to keep it and, if necessary, we will also terminate the child's account.
12. OTHER PROVISIONS
Websites and applications from third parties. Both other websites and applications and our Services may be referenced or linked to on other websites and applications. We have no control over these services provided by third parties. We advise all of our users to read the privacy statements on every website and application they use. The privacy policies or content of such other websites or applications are not supported by, reviewed, or approved by us, and we are not liable for them. You do so at your own risk when providing personal information to third-party websites or applications.
Supervisory Authority. If you believe our processing of your personal information violates any applicable laws in the European Economic Area, Switzerland, or the United Kingdom, where your personal information is subject to those laws, you have the right to file a complaint with the appropriate supervisory authority.
- EEA Data Protection Authorities (DPAs)
- Swiss Federal Data Protection and Information Commissioner (FDPIC)
- UK Information Commissioner’s Office (ICO)
13. CONTACT US
Tugan.ai is in charge of controlling the personal data we handle in accordance with this Privacy Notice. Contact us at [email protected] if you have any inquiries about our privacy practices, this privacy notice, or to make use of the rights described in this privacy notice.