Privacy Policy

1. Age Requirement

TugVote is intended for people who are at least 16 years old.

If you are under 16, you may not create or use a TugVote account.

2. Information We Collect

Account information

When you create and use a TugVote account, we process information associated with your account, including:

• username;
• email address;
• authentication information necessary to secure your account;
• account creation date;
• last login information; and
• account status information.

Passwords are not stored in readable form.

Profile information

You may voluntarily provide profile information, including:

• a profile picture;
• a biography; and
• a country.

The country associated with your profile is selected by you. TugVote does not use this field to determine your precise geographic location.

If you choose to add a profile picture, TugVote processes the image that you select from your device so that it can be uploaded, processed, stored, and displayed as your profile picture.

Selecting a profile picture does not cause TugVote to upload your entire photo library.

Voting and participation information

When you participate in TugVote, we process information about your activity, which may include:

• the face-offs in which you participate;
• the side you select;
• when you vote;
• support associated with your vote;
• Tug Coins used to boost support; and
• participation and reward activity.

Comments and community activity

When you use TugVote's community features, we may process:

• comments you create;
• changes made to comments;
• likes you place on comments;
• reports you submit about comments;
• report reasons; and
• information about the resolution of reports.

Some information you provide through profiles or community features may be visible to other TugVote users where the relevant feature is designed to display that information.

Tug Coins, rewards, and achievements

TugVote processes information necessary to operate its virtual-currency and participation features, including:

• Tug Coin balance;
• Tug Coin transaction history;
• Tug Coins earned or spent;
• associated face-offs where applicable;
• daily reward information;
• achievements; and
• achievement unlock information.

If TugVote introduces the ability to purchase Tug Coins or other digital items with real money, this Privacy Policy may be updated to explain any additional personal data processing involved.

Notifications

TugVote processes information necessary to provide and manage in-app notifications, which may include notification content, notification type, read status, creation time, and an associated face-off where applicable.

Verification and account-security information

To provide email verification, password recovery, and account security, TugVote may process:

• the account associated with a verification or password-reset request;
• securely hashed verification or password-reset codes;
• expiration information;
• failed verification attempts;
• whether a code has been used; and
• relevant timestamps.

3. How We Use Information

We use personal data as necessary to:

• create, authenticate, and maintain accounts;
• verify email addresses;
• provide password recovery;
• provide and display user profiles;
• operate voting and face-offs;
• operate comments, likes, reports, and other community features;
• provide Tug Coins, rewards, achievements, and participation features;
• provide in-app notifications;
• provide user support;
• protect accounts and the security and integrity of TugVote;
• prevent, investigate, and respond to misuse or abuse;
• moderate TugVote and enforce applicable rules;
• process account and privacy requests; and
• operate, maintain, troubleshoot, and improve TugVote.

4. Legal Bases for Processing

Where the General Data Protection Regulation (GDPR) or other applicable law requires a legal basis for processing, the basis depends on the purpose of the processing.

We may process personal data because:

• processing is necessary to provide TugVote or perform our agreement with you;
• processing is necessary for legitimate interests such as operating, securing, preventing abuse of, and moderating TugVote;
• processing is necessary to comply with a legal obligation; or
• you have given consent where consent is required.

Where processing relies on consent, you may withdraw that consent where applicable. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

5. Profile Pictures and Device Photos

Adding a profile picture is optional.

When you choose a profile picture from your device, the selected image is sent to TugVote's backend, processed into a suitable profile image, and stored for use with your account.

TugVote does not require you to upload your other photographs merely because you choose a profile picture. Access to photos is used to allow you to select the image you choose, subject to the permissions and photo-selection mechanisms provided by your device and operating system.

You may replace or remove your TugVote profile picture.

6. Service Providers

We use third-party service providers where necessary to operate TugVote.

Railway provides infrastructure used to host TugVote's backend, database, and stored profile images.

Resend provides transactional email delivery used for functions such as email verification and password recovery. When such an email is sent, information necessary to deliver and operate that email service, including the recipient email address and email content, may be processed by Resend.

Service providers may process personal data on our behalf to provide their respective services.

They may also process information as independently required by applicable law or under their own legal obligations.

7. International Processing and Transfers

TugVote is intended to be available internationally.

TugVote and its service providers may process or store information outside the country in which you live. In particular, TugVote currently uses infrastructure in the United States for parts of its service.

Where applicable law requires safeguards for transfers of personal data between countries, appropriate transfer mechanisms and safeguards will be used as required.

8. Data Retention

We retain personal data for as long as reasonably necessary for the purposes for which it is processed, including providing TugVote, maintaining account and service security, moderating the service, resolving disputes, enforcing applicable agreements, and complying with legal obligations.

Account-associated information may generally remain while your account remains active unless it is deleted earlier through a particular TugVote function or otherwise no longer needs to be retained.

Some content may change status without being deleted. For example, closed face-offs may be archived while information associated with those face-offs remains stored.

Transactional-email providers may maintain email-related information according to their own applicable retention periods.

When an account is deleted, TugVote deletes associated account data from its active systems as described below, subject to information that may need to be retained where required or permitted by applicable law.

9. Account and Data Deletion

You can permanently delete your TugVote account from within the TugVote app.

From your profile, select Delete account and confirm the deletion. Account deletion cannot be undone.

Deleting your account removes your TugVote account and associated account data from TugVote's active systems. This includes associated profile information and profile image, votes, comments, comment likes, Tug Coin activity, daily reward records, achievements, notifications, and account verification and password-reset records.

Reports associated with your account may also be deleted as part of the deletion of your account or related comments.

If you cannot access the TugVote app, you can request account deletion by contacting tugvote@noverdane.com from the email address associated with your TugVote account. We may need to verify that you own the account before processing the request.

Additional instructions are available on TugVote's Account & Data Deletion page.

10. Your Privacy Rights

Depending on your location and applicable law, you may have rights concerning your personal data. These may include the right to:

• request access to personal data concerning you;
• request correction of inaccurate personal data;
• request deletion of personal data;
• object to or request restriction of certain processing;
• withdraw consent where processing relies on consent;
• request portability of certain personal data; and
• lodge a complaint with an appropriate data-protection authority.

Some rights are subject to legal conditions, limitations, and exceptions.

To make a privacy request, contact tugvote@noverdane.com .

If you are in the European Economic Area, you may also have the right to lodge a complaint with your competent supervisory authority. The supervisory authority in Bulgaria is the Commission for Personal Data Protection.

11. Security

We use technical and organizational measures intended to protect personal data and TugVote accounts.

These include authentication controls, protected account credentials, secure handling of verification and password-reset codes, authorization requirements for account functions, and measures intended to reduce unauthorized access to personal data.

However, no internet-based service or method of electronic storage can guarantee absolute security.

12. Public and Community Information

TugVote contains social and community features.

Information you intentionally make available through your profile or community features may be visible to other users according to how the relevant feature operates.

You should avoid including personal, confidential, or sensitive information in public content if you do not want other users to see it.

13. Users Under 16

TugVote is not intended for people under 16 years of age, and people under 16 may not create or use a TugVote account.

If we learn that an account is being used by a person under 16, we may take appropriate action concerning the account and associated information.

If you believe a person under 16 is using TugVote, contact tugvote@noverdane.com .

14. Changes to This Privacy Policy

We may update this Privacy Policy when TugVote, our data practices, our service providers, or applicable requirements change.

When the Privacy Policy is updated, the Last updated date at the top of this page will be changed.

Where required by applicable law, we will provide additional notice or obtain consent for material changes.

15. Contact and Data Controller

The operator and data controller responsible for TugVote is:

Vasil Mutafchiev
Operating under the Noverdane brand
Bulgaria

Privacy and support contact: tugvote@noverdane.com