PRIVACY POLICY

TUGDI LLC PRIVACY POLICY
April 21, 2026

TUGDI LLC (“Company”, “we”, “us”, or “our”) respects your privacy and is committed to protecting it through compliance with this Privacy Policy. This Policy describes the types of information we may collect from you or that you may provide when you use our website and services (the “Services”), how we use, share, and protect such information, and your rights regarding your information.

1. Data We Collect, Use, and Disclose
Below is a list of the types of data we may collect, where we got it, why we collect it, and the categories of third parties to whom we may disclose it. We do not sell your data to third parties.

Data Type
Where We Got It
Why Collected
Disclosed To
First and last name
User entry
Facilitating account creation, user-to-user communications, and personalizing your use of the Services
No one
Email
User entry
Account creation, user-to-user and Service-to-user communications, combating fraud/abuse
No one
Phone number
User entry
User-to-user communications, fraud prevention, personalized use of the Services
Phone verification service providers
Mailing or street address
User entry
Account and post creation, communication with corporate users, facilitating transactions, personalization
No one
Geographic location (latitude and longitude)
User entry, IP/geolocation providers
Personalizing your experience, combating fraud/abuse
No one
Photos and other data you voluntarily provide, post, or send
User entry
Facilitating and personalizing your use of the Services
No one
Saved searches, account preferences, favorite/hidden postings
User entry
Facilitating and personalizing your use of the Services
No one
Comments posted on the website
User entry
Facilitating communication between users, personalizing the user experience, and ensuring community standards
No one
Messages exchanged between users
User entry
Facilitating user-to-user communication and dispute resolution
No one
Chatbot interactions (including conversation transcripts)
User entry
To provide virtual support, improve chatbot responses, and enhance the Services
No one
HTTP browser cookies
User's browser, Service web server
Facilitating and personalizing your use of the Services, combating fraud/abuse
No one
Device information (device ID, OS, browser version, plugins)
User's browser, mobile app
Facilitating and personalizing your use of the Services, combating fraud/abuse
No one
IP address
User's browser, mobile app, IP/geolocation providers
Fraud prevention and abuse detection
Service providers assisting with fraud/abuse prevention
Web page views, access times, HTTP headers
User's browser, mobile app
Fraud prevention and abuse detection
No one
Communications with us (support requests, forms, surveys, feedback, event participation)
User entry
To respond to your inquiries, provide support, process event participation, and improve the Services
No one
Marketing preferences and engagement data
User entry
To manage your marketing preferences and send relevant communications
No one

2. How We Use Your Information
We use information for purposes including:
 Providing, maintaining, and improving the Services
 Communicating with users about accounts, listings, or disputes
 Marketing and promotional purposes, including advertising on third-party platforms
 Preventing fraud, abuse, and illegal activity
 Complying with legal obligations, security, and customer support.

3. Sharing Your Information
We do not sell personal information. We may share information:
 With vendors, service providers, or contractors to operate the Services
 When required by law or legal process involving with law enforcement bodies
 In connection with corporate transactions (mergers, acquisitions)
 To protect the rights, safety, or property of users, the Company, or others

4. Permission to Use Your Name, Profile Picture, and Activity Information
You give us permission to use your profile name, profile picture, and information about actions you have taken in our products (for example, apps or services you use) next to or in connection with ads, offers, and other sponsored or commercial content that we display in our products, without any compensation to you.

5. Cookies and Similar Technologies
We use cookies, web beacons, and similar technologies to:
 Remember account preferences and session information
 Analyze usage and performance of the Services
 Deliver relevant advertising on our platform and third-party sites
You may control or block cookies through your browser settings; however, some features of the Services may not function properly without cookies.
6. Retention of Personal Information
We retain Personal Information, including sensitive Personal Information, only for as long as necessary to provide our products and services, comply with legal obligations, or protect our or others’ legitimate interests. The retention period is determined based on the specific purpose and legal requirements. When deciding how long to keep information, we consider:
 Whether the information is needed to operate or provide our products and services,
 Which feature the information is used for and how that feature works,
 How long we are required to retain information to meet legal obligations,
 Other legitimate purposes, such as preventing harm, investigating potential violations of our terms or policies, enhancing safety and security, and protecting our rights, assets, or products.
7. Your California and New York Privacy Rights (CCPA/CPRA and NY SHIELD Act)

Data Type	Where We Got It	Why Collected	Disclosed To
First and last name	User entry	Facilitating account creation, user-to-user communications, and personalizing your use of the Services	No one
Email	User entry	Account creation, user-to-user and Service-to-user communications, combating fraud/abuse	No one
Phone number	User entry	User-to-user communications, fraud prevention, personalized use of the Services	Phone verification service providers
Mailing or street address	User entry	Account and post creation, communication with corporate users, facilitating transactions, personalization	No one
Geographic location (latitude and longitude)	User entry, IP/geolocation providers	Personalizing your experience, combating fraud/abuse	No one
Photos and other data you voluntarily provide, post, or send	User entry	Facilitating and personalizing your use of the Services	No one
Saved searches, account preferences, favorite/hidden postings	User entry	Facilitating and personalizing your use of the Services	No one
Comments posted on the website	User entry	Facilitating communication between users, personalizing the user experience, and ensuring community standards	No one
Messages exchanged between users	User entry	Facilitating user-to-user communication and dispute resolution	No one
Chatbot interactions (including conversation transcripts)	User entry	To provide virtual support, improve chatbot responses, and enhance the Services	No one
HTTP browser cookies	User's browser, Service web server	Facilitating and personalizing your use of the Services, combating fraud/abuse	No one
Device information (device ID, OS, browser version, plugins)	User's browser, mobile app	Facilitating and personalizing your use of the Services, combating fraud/abuse	No one
IP address	User's browser, mobile app, IP/geolocation providers	Fraud prevention and abuse detection	Service providers assisting with fraud/abuse prevention
Web page views, access times, HTTP headers	User's browser, mobile app	Fraud prevention and abuse detection	No one
Communications with us (support requests, forms, surveys, feedback, event participation)	User entry	To respond to your inquiries, provide support, process event participation, and improve the Services	No one
Marketing preferences and engagement data	User entry	To manage your marketing preferences and send relevant communications	No one

If you are a California resident, you may have the following rights under CCPA/CPRA:
 Right to Know: Request details about personal information we collect and share
 Right to Delete: Request deletion of personal information, subject to exceptions
 Right to Opt-Out: Opt out of the sale of personal information (we do not sell information, but some sharing may trigger this right)
 Right to Non-Discrimination: You cannot be discriminated against for exercising these rights.
To learn more about the California Consumer Privacy Act (CCPA/CPRA) and applicable New York privacy laws, including the New York SHIELD Act, please visit the California Attorney-General's website.

8. Data Access and Deletion Request
Depending on your location, including California and New York, and subject to applicable law, you may have the following rights regarding the Personal Data we process about you as a data controller:
 You may submit a request to know or delete via info@tugdi.com
 Only you, or someone you authorize to act on your behalf, may make a request to know or delete your data. An authorized agent may make a request on your behalf by providing written permission signed by you.
 We will need to confirm your identity before processing your request by asking you to log into your existing account (if you are a registered user) or by asking you for additional information, such as a government issued ID, to confirm your identity against information we have already collected.
9. International Users
By accessing TUGDI LLC or providing us data, you agree we may use and disclose data we collect as described here or as communicated to you, transmit it outside your resident jurisdiction, and store it on servers in the United States.

10. Data Retention
We retain your personal information for as long as necessary to provide the Services, comply with legal obligations, resolve disputes, enforce agreements, and for other legitimate business purposes. Retention periods may vary based on applicable laws or regulations in your jurisdiction. After the retention period, information will be deleted, anonymized, or securely disposed of.

11. Security
We implement reasonable administrative, technical, and physical measures to protect your information. However, no system is completely secure, and we cannot guarantee the absolute security of your data.

12. Children’s Privacy
The Services are not directed to children under 13, and we do not knowingly collect information from children under 13. If we learn that personal information has been collected from a child under 13, we will take steps to delete it.

13. Changes to This Policy
We may change this Policy from time to time to reflect new services, changes in our privacy practices or relevant laws. The “Last updated” legend at the top of this Policy indicates when this Policy was last materially revised. Any changes are effective the latter of when we post the revised Policy on the Services or otherwise provide notice of the update as required by law.

We may provide you with disclosures and alerts regarding the Policy or Personal Data collected by posting them in our Help Center.

14. Contact Us
For questions or requests regarding your information, contact us at:
info@tugdi.com