Privacy Policy

Last Revised: April 16th, 2024

This Privacy Policy (“Privacy Policy”) explains how Trugly Labs, Inc. (“Trugly,” “we” or “our,” or “us”) collects, uses and discloses information from website visitors (“you” or “your”) via the https://trugly.meme website (“Site”). We are committed to protecting and respecting your privacy. By accessing the Site, you acknowledge and agree to this Privacy Policy. The Privacy Policy does not apply to information collected through third-party websites or services that you may access through the Site. Please review this Privacy Policy carefully. If you have any questions, please reach out via the “Contact Us” information provided below.

Information We Collection

We collect and process the Personal Information that you provide to us through the Site. “Personal Information” includes any information that, alone or in combination with other information, can be used to identify you, such as a personal identifier (e.g., name or email address), an identification number, online identifiers or inferences about your preferences. Personal Information does not include information that is de-identified or aggregated such that it cannot be used to identify individuals.

We collect the following Personal Information: usage data about devices you use to access the Site, such as device manufacturer, operating system, domain name, location, internet protocol (“IP”) address and digital wallet address, from all website visitors (“Automatically Collected Information”).] We use Automatically Collected Information internally to help us improve your experience with the Site, to enforce eligibility requirements, and record IP addresses, browser types, internet service provider (“ISP”) and usage metrics.

Information Used and Disclosed to Third Parties

We use the Personal Information that we have about you to enforce the Terms of Service for the Site and this Privacy Policy, to communicate with you regarding your requests, analyze Site usage t to detect fraud or misuse and to comply with our legal or regulatory obligations. We use Automatically Collected Information internally to help us improve your experience with the Site, to enforce eligibility requirements, and record IP addresses, browser types, internet service provider (“ISP”) and usage metrics.

We may share your Personal Information in the following circumstances:

• Designated Service Providers. We may share your Personal Information with companies that we contract with in order to provide services (“Service Providers”). These services may include: (i) providing products or services to you on our behalf; (ii) creating or maintaining our networks, systems, and databases, analytics; (iii) providing support; (iv) responding to inquiries; and (v) monitoring and analyzing the use and functionality of our Site. Information disclosed to third parties may include aggregated and/or de-identified information derived from your Personal Information. We may disclose Automatically Collected Information obtained from your use of the Site to our Service Providers.
• Affiliates. We may share your Personal Information with companies under common ownership and control of Trugly, including our subsidiaries and affiliates.
• Legal Obligations. We may disclose your Personal Information if we believe in good faith that such disclosure is necessary to satisfy our legal obligations. This may include: (i) to comply with the law or in response to a subpoena, court order, government request, or other legal process; (ii) to produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, or other legal or administrative proceedings; (iii) to protect the interests, rights, safety or property of us, or any of our subsidiaries, affiliates, employees and users; (iv) to monitor compliance with and enforce the Terms of Service for this Site; (v) to operate the systems that ensures the Site functions properly; or (vi) if we believe in good faith that a disclosure is necessary.
• Business Transactions. In the event that Trugly goes through a business transition, such as a merger, acquisition by another company, reorganization or sale of a portion of its assets, some or all of your Personal Information may be transferred in connection with the proposed transaction.
• Consent. With your consent or at your direction, such as sharing with your representatives or third parties.

Cookies and Other Tracking Technologies

We utilize cookies and other tracking technologies on this Site. A cookie is a small text file placed on your computer that helps us understand how you and our other visitors use the Site, to enhance the user experience through different features and functionality, and to analyze and compile usage data. Personal Information collected by cookies may include your device’s IP address, browser type, operating system, computer platform, web pages viewed and/or the date and time of your visit. For example, we may use cookies to remember your preferences or settings.

Most browsers include tools to manage or disable cookies. You can visit the help function on most browsers to modify how your browser handles cookies. However, if you disable cookies, some features of this Site may not function properly.

Cookies can be categorized by how long they remain on your device. All cookies have expiration dates in them that determine how long they stay in your browser. There are two broad categories of duration:

• Session Cookies. Session cookies are temporary cookies that exist only during an online session and are not stored on your computer or mobile device. Session cookies are used as part of the login, authentication and session management flows of the platform websites and to process your online transactions and requests.
• Persistent Cookies. Persistent cookies are those placed on your computer or mobile device for a pre-determined length of time when you visit this Site. We use persistent cookies that only the website can read and use, to identify the fact that you are a Site visitor, to store user preferences and to understand which areas of our websites and platform are most popular. Persistent cookies remain on your device until deleted manually or automatically.

To assist us with the various uses and purposes described in this Privacy Policy, your information, including information collected by the cookies or similar tracking technologies, may be aggregated, analyzed or linked to other information we have about you (including information from other online and offline sources). For example, we may use third parties to collect information

Global Privacy Control. The Global Privacy Control (“GPC”) is a method for individuals to opt-out of the sale or sharing of their personal information, as such terms are described under applicable data protection laws, via a user-enabled privacy control that is available on certain internet browsers. We do not sell or share your Personal Information and as such, our systems are not configured to detect or respond to the GPC. You can learn more about the GPC here.

“Do Not Track” signals. Some web browsers have “Do Not Track” or similar features that allow you to tell each website you visit that you do not want your activities on that website tracked. Currently, our Site does not respond to “Do Not Track” signals and will continue to collect information about you even if your browser’s “Do Not Track” functionality is activated. Please note that your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of cookie information.

Data Retention

We retain information we collect as long as it is necessary and relevant to fulfill the purposes outlined in this Privacy Policy and to provide services to you. Subject to applicable law, we may retain Personal Information to resolve disputes, enforce our Terms of Service, or other actions permitted by law.

Children’s Privacy

In accordance with children’s data protection laws, we do not knowingly collect Personal Information from children under the age of 13. If we learn we have collected or received Personal Information from a child under 13 years of age without authorization, verification, or parental consent, we will promptly delete that information.

Rights With Respect To Your Personal Information

Depending on the jurisdiction in which you reside, you may have the right to access, correct, delete or restrict use of certain Personal Information covered by this Privacy Policy. You may also have the right to request that we refrain from processing Personal Information. To honor any requests, we will take steps (and may need to collect information from you) to verify your identity. We will only use any Personal Information provided in the verification process for identity verification purposes. Please note that if you exercise such rights, this may affect our ability to provide services to you on the Site. While we will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such requests, to the extent allowed or required by applicable law. For inquiries about your Personal Information, please contact us through one of the methods listed below.

Data Transfer

We are headquartered and operate in the United States. If you use our Site, or contact us from outside the United States, please be advised that (i) any Personal Information you provide to us or that we automatically collect will be transferred to the United States; and (ii) by using or submitting Personal Information through our Site, you explicitly authorize the transfer to and subsequent processing in the United States, and other countries in which we operate, in accordance with this Privacy Policy. Please be advised that the United States and other countries may not offer the same privacy protections as the laws of the jurisdiction where you reside.

Security of Your Personal Information

We maintain administrative, physical and technical safeguards designed to protect the Personal Information we collect and maintain. However, no data transmission over the internet is ever 100% secure. As a result, while we strive to protect your information, we cannot guarantee or warrant the security of any information you transmit to our Site.

Third Party Websites

The Site may contain links to third-party websites, such as social media sites. If you visit those sites, any information collected on those sites is governed by the privacy policies of the third party websites and not this Privacy Policy. We are not responsible for any information you may provide while browsing third-party websites.

“Shine the Light” Law

Under California Civil Code Section 1798.83, California residents are entitled to request and obtain from Trugly once per calendar year information about when we share your Personal Information with third parties for those third parties’ own direct marketing purposes. To request this information, please contact us by email and indicate “California Shine the Light” in the subject line. In the past year, Trugly has not shared Personal Information with third parties for those third parties’ own direct marketing purposes.

Notification of Changes

We reserve the right to update, modify or change this Privacy Policy from time to time. If we make a material change to the way we intend to use your Personal Information, we will notify you by updating this Privacy Policy and modifying the date updated at the beginning of this Privacy Policy. We encourage you to review the Privacy Policy whenever you access the Site or otherwise interact with us to stay informed about our privacy practices.

Contact Us

We seek to resolve any issues that you have with our privacy practices. If you have questions or complaints regarding this Privacy Policy, please contact us at through email at: contact@trugly.meme. Please include “Privacy” in the subject line of your inquiry.