Privacy policy

Privacy policy

1. Introduction

The terms and conditions of this Privacy and Cookie Policy (hereinafter the “Privacy Policy”) apply to all Services that End User may subscribe to with Tugush or its affiliates anywhere in the world [1]. The Privacy Policy (and where it relates to our Services; together with our Terms & Conditions) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. For the purpose of providing the Services and Trial Services, Tugush collects personal data within the following conditions. End User expressly agrees that they have read this Privacy Policy carefully, that they have understood its meaning and are thus informed of and expressly accept its content.

2. Data Collected

When End User creates an Account to use the Tugush Trial Services, Tugush asks End User to provide contact information such as surname, first name, telephone number, email address, company name of End User, etc. When End User acquires Services, additional information will be requested from End User by Tugush such as billing information and address. In this Privacy Policy, the personal data as mentioned above are referred to as “End User’s Personal Data” or “Its Personal Data”. Tugush may also collect personal data of users surfing Tugush’s websites such as these users’ IP addresses.

3. Use of Data

3.1 Purpose

Tugush uses the personal data collected for the following purposes:

  • Identification and authentication of End User when End User accesses Account;
  • Providing the Services to End User;
  • Billing purposes;
  • Improving the quality of the Services provided;
  • Market research purposes;
  • Marketing and advertising purposes.

Third-Party Platforms may collect personal data concerning End User if End User connects to such Platforms via the Services. Tugush is not responsible for the manner in which these Platforms handle any personal data that may be disclosed to them. End User is invited to refer to the appropriate Third-Party Platform’s privacy provisions in order to verify how its personal data is used by such Platforms.

Tugush’s Services provide URL links to third-party websites. Tugush is not responsible for the manner in which these third-party websites handle any personal data that may be disclosed to them. End User is invited to refer to the appropriate third-party website’s privacy policy in order to verify how its personal data is used by such a third-party website.

3.2 Transfers of data

End User’s Personal Data will not be shared with third parties, except as provided below. Tugush may resort to the Tugush Group of companies that are located outside the territory of the EU for Service optimization purposes.

4. Information Sharing

Tugush does not sell or trade personally identifiable information about our Site visitors or End Users or their Authorized Users.

Tugush may share your personal data with:

  • Trusted third parties, including our business partners, sub-contractors, and suppliers who provide services to us (including handling and delivering email communications, newsletters, and website hosting services). These third parties assist us in operating our Site (“the Site”) and Services, conducting our business, or servicing you and have agreed to keep this information confidential and use such information only for purposes relating to their services for us;
  • Tugush Group: Any member of our group, which means our subsidiaries, our ultimate holding company, and its subsidiaries;
  • Other Users on the Site: Tugush may occasionally post testimonials on the Site that may contain personal information. Tugush obtains your consent to post your name along with your testimonial. If you wish to update or delete your testimonial, you can contact us;
  • Events and Partnerships: Tugush may occasionally partner with other organizations to run events, promotions, or competitions. If you register for an event/promotion/competition and Tugush indicates on the Site that the event is being run in partnership with or sponsored by another organization, in circumstances where either you agreed to be contacted for marketing purposes at the time Tugush collected your information or where Tugush is otherwise permitted by law to contact you for these purposes, your email address may be available to that organization and you may receive emails from them after the event/promotion/competition. In these circumstances, please refer to the privacy policy of that organization for information on how to opt out of their communications should you receive an email from them but no longer wish to be contacted by them;
  • Social networking and other websites: the Site or Service may allow you to post information on social networking sites. Tugush does not share your personal data to such websites unless you direct the Site or Service to share it. The use of the information by such social networking sites will be governed by their privacy policies and Tugush does not control their use of shared data;
  • Analytics and search engine providers that assist us in the improvement and optimization of our Site and Services. See Clause 5 regarding Cookie Policy for more information;
  • Our prospects or customers: If you choose to be a reference to our prospects and customers regarding our products and services, Tugush will obtain your consent to provide your contact information to them. If you wish to update or remove your reference information, you can contact us through the contact details noted below in Clause 9.

Tugush may also share your personal data under the following circumstances:

  • Merger, sale, or other asset transfers: As a result of the sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, reorganization or liquidation of Tugush. Your personal data may be transferred as part of such a transaction (as one of the transferred assets) as permitted by law and/or contract;
  • As required by law: If Tugush is under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements with you; or to protect the rights, property, or safety of Tugush, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and law enforcement purposes;
  • With your consent: Tugush may also disclose your information, including your personal information, where you have specifically provided your consent for the disclosure. You may withdraw a consent at any time by contacting us via the email address listed below.

5. Cookies

Cookies are small amounts of data sent on End User ’s and any Tugush websites user’s browser and stored on their hard drive that may not allow identification of the party receiving the cookies, unless such party has already provided Tugush with personal information allowing such identification, e.g. by creating an Account.

Tugush uses cookies in order to provide End User with a tailored experience while using the Services.

In this regard, Tugush uses:

  • Session cookies that enable Tugush to process and memorize End User ’s transactions and requests during a given session on its Account. These cookies are necessary in order to use the Services;
  • Persistent cookies that enable Tugush to remember End User ’s information in order to provide easier and more convenient access to the Services, tailored information, web content and promotional messages to End User , and that are used for market research purposes.

Tugush warrants that any information collected via these cookies will not be shared by Tugush with any third party.

End User or any user of Tugush’s websites may set their browser parameters to select the types of cookies they wish to receive or not receive from Tugush.

6. Security and Data Retention

Tugush has implemented administrative, physical and electronic measures designed to protect your information from unauthorized access. Tugush will comply with applicable law in the event of any breach of the security, confidentiality, or integrity of your Personal Information and, where Tugush considers it appropriate or where required by applicable law, notify you via email, text or conspicuous posting on the Site in the most expedient manner possible and without unreasonable delay, insofar as it is consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Although guaranteed security does not exist either on or off the Internet, Tugush make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations.

Where Tugush has given you (or where you have chosen) a username, login or password which enables you to access certain parts of the Site and/or the App, you are responsible for keeping this information confidential. Tugush asks you not to share a username, login or password with anyone.

Tugush restricts access to your Personal Information to individuals who need access to it in order to process it on Tugush’s behalf. These individuals, where employees, are bound by confidentiality agreements and Tugush will take appropriate action (which may include disciplinary proceedings) in the event Tugush finds that its employee(s) has failed to meet standards in looking after your personal data. Tugush cannot accept any liability for employees or agents acting outside its normal course of business, or for any third-parties with whom your Personal Information may be shared who act outside of the terms of our contracts with Tugush.

Tugush will retain your Personal Information only for as long as necessary to fulfil the purpose(s) for which it was collected and to comply with applicable laws.

In general, this means that Tugush store your data throughout the existence of your account with us or for as long as is otherwise required to deliver our Services, except where Tugush have a lawful basis for saving it for an extended period of time (for instance, after fully executing a contract, Tugush may still have a legitimate interest in using your contact details for marketing purposes). Tugush also retain the data Tugush need for the execution of pending tasks and the data Tugush need to investigate and realize our legal rights and our claims, as well as certain data that Tugush must store for a legally mandatory period of time. When certain data is only saved due to a legally mandatory preservation term, the processing of it by us is limited, even where you do not specifically request this.

Tugush undertakes to provide End User with such list within a reasonable timeframe.

9. How to Contact Us

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to:


This Privacy Policy shall be governed and construed in accordance with the laws of the Republic of Estonia.

Tugush may alter terms and conditions of this Privacy Policy, in whole or in part, by notifying End User of such alterations beforehand via an appropriate method of information.

[1] Including but not limited to Tugush Blockchain Capital, Tugush OU and other affiliates.