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:

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:

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

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:

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.

7. Marketing Preferences

Tugush may use End User’s Personal Data to contact End User to discuss the Services it has subscribed to or to send End User information concerning Tugush and/or the Services and/or promotional activities via newsletters, messages, calls and letters to the email address, telephone number or postal address provided by End User.

By accepting this Privacy Policy, End User thus expressly accepts that Tugush uses the email address, telephone number or postal address provided by End User in order to contact End User for the purposes above. Except as mentioned in this Privacy Policy, Tugush does not use End User’s Personal Data for any other kind of marketing or promotional purposes. End Users may opt out of being contacted by Tugush at any time by using the opt-out link provided in any newsletter sent to End User or by contacting Tugush in this regard at the following email address:

8. Rights of End User

End User can update or correct any Personal Data at any time by contacting Tugush at the following email address: End User is entitled to request Tugush to provide End User, free of charge, with a list of all of End User’s Personal Data stored by Tugush by sending an email in this regard to the following e-mail address:

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.