*TUGCH.COM («our Website») is owned and operated by TUGCH LTD, , a company having its registered seat in DARKHAN SUM, DARKHAN-UUL, MONGOLIA, which for the purposes of this Policy shall be the data controller («we», «us», or «our»). We have designated a contact person responsible for compliance and implementation of this Policy and related personal data rights and may be contacted as described in the ‘Contact Us’ section hereinbelow.
1. Types of Personal Information That Might Be Collected
When you visit our Website, the following types of data about you may be collected:
- your IP address;
- your operating system and browser software used to access our Website;
- other information, as will be explained in Section 4 (With Whom We Share Information) below;
- in the event you contact us by email, we may keep a record of that correspondence; such record may include, apart from your email address, the data that you will include in the communication.
Such data are collected by Our Partners (as such term is explained in Section 4).
If you wish to register on our Website in order to receive our subscription-based services, we will ask you to provide the following data:
- your email address;
- your gender;
- your date of birth.
In addition, when subscribing for any of the services offered on our Website you will be requested to identify your display name and choose your profile image which may be an avatar or a photo. The display name is what will be displayed next to your comments on our Website. We strongly encourage you not to use your real-life name and/or surname as your display name.
We never share with third parties any of the data supplied by you as part of subscription-based services/registration.
For the purposes of this Policy, the collected data mentioned in this Section, shall be defined as ‘Personally Identifiable Information’.
2. Ways Personal Information Might Be Used
Use of Personal Data by Us. We collect and use your Personally Identifiable Information for the purposes of the following legitimate business interests pursued by our data controller company and the group of companies to which it belongs:
- to carry out general data analysis and to administer our Website and affiliated sites;
- to generate statistics and measure web traffic and popularity of specific areas of our Website;
- to identify usage trends and expand our business activities;
- to build higher quality and develop more useful services by performing statistical analyses of the collective characteristics and behavior of our users
- to improve or modify our Website, develop new services and functionality;
- to comply with applicable legal requirements, legal process and relevant industry standards, and satisfy requests by governmental and supervisory authorities;
- to identify and prevent fraud.
Additionally, if you choose to register on our Website in order to receive our subscription-based services, your Personally Identifiable Information will be used in order to communicate with you.
Under such circumstances, the legal basis for providing this service to you would be your express consent. You may withdraw your consent at any time and detailed unsubscribe instructions will be displayed at the bottom of each email. Withdrawal of your consent will not affect the legality of our data processing for the time before the consent was withdrawn.
Use of Personal Data by Our Partners. Our Partners (as such term is explained in Section 4, With Whom We Share Information) may be collecting and using your Personally Identifiable Information to tailor the content that advertisers display to you, including building relevant data segments based on what you click and view and when or how many times you have viewed it; for these purposes, they use the information collected by technologies, such as pixel tags or cookies, to improve the services provided by third-party advertising companies, which include Google. The list of Google partners can be viewed at partners.
3. What You Agree to by Using Our Website
Before using Personally Identifiable Information for a purpose other than any of the purposes set out in the preceding Section 2 (Ways Personal Information Might Be Used) we will request your explicit consent.
4. With Whom We Share Information
Except as set forth in this Policy or as explicitly agreed by you, we will not disclose any of your Personally Identifiable Information. In addition to the other uses set forth in this Policy, we may disclose and otherwise use Personally Identifiable Information as described below.
Our Partners. We allow third parties, including carefully selected ad networks and business partners (referred to as «Our Partners»), to display advertising on our Website. Our Partners may, for instance, collect, use and share your information to make or help us make predictions about your interests, and may provide you with offers, promotional materials, and advertisements. In addition, Our Partners may be collecting certain information either by you or from your device. Our Website permits Our Partners to collect your Personally Identifiable Information to provide personalized advertising to you. Our Partners are leading digital performance-based advertising groups which put great effort in making sure that your personal information is safe and used properly.
Service Providers. Your information may be collected by entities that provide services to us, including companies that deliver web analytics, data processing, data enhancement and customer insights, advertising, email distribution, and other services.
Other Parties (when required by law or as necessary to protect our services). We may disclose your information (including Personally Identifiable Information) to other parties in order to:
- protect our legal rights or property, the legal rights or property of our affiliates, and sites or services we work with;
- protect the rights, safety and security of our users, ourselves, or any other person or entity;
- prevent fraud (or for risk management purposes);
- comply with applicable legal requirements, legal process or request for cooperation by a governmental or supervisory authority, whether or not legally required. For example, we may be required to disclose your information to meet national security or law enforcement requirements.
Other Parties (in connection with transfer of assets). If we make a sale or transfer of assets, or are otherwise involved in a merger or transfer (or due diligence related to such a transaction), or in the unlikely event of bankruptcy, we may transfer your Personally Identifiable Information as part of that transaction.
Use for Analytical and Ad Serving Purposes. We use standard tools common within the industry, including but not limited to Google Analytics, to collect information about use of our Website. These tools collect information such as how often you visit our Website and what other sites you visited prior to reaching our Website. We use the information we obtain from analytical tools for the purposes of improving our Website. The analytical tools collect only the IP address assigned to your computer or other device and your browser settings as of the moment you visit our Website, rather than your name or other identifying information.
Finally, our Website relies on common industry tools Google Display Network Impression Reporting and Google Analytics Demographics and Interest Reporting. These tools help us understand the composition of viewers of our Website in terms of gender, age and interests. We need this information in order to understand what types of creative content we need to develop to suit the interests of different demographic and interest groups. In addition, Our Partners may need this information to develop marketing content. You may, at any time, opt out of Google Analytics tracking, including Google Display Network Impression Reporting and Google Analytics Demographics and Interest Reporting, by installing the Google Analytics Opt-Out Browser Add-On. You may also opt out of ad serving through Google’s opt-out page.
You can opt out of ads personalization using Google’s Ads Settings by following the instructions contained on the following resource of Google — Google Ads Settings. If you choose to opt out of ads personalization, you will no longer receive personalized advertising.
The above mentioned policies are issued and updated by the respective developers and should be considered by our Website users independently.
5. Cross-Border Transfer of Information
We generally maintain centralized servers and systems in Europe and may maintain servers and systems elsewhere. These servers and systems are managed by us or on our behalf, or by our affiliates located in Europe.
In the event of transfer and processing of your Personally Identifiable Information outside the EEA for the purposes described above, we will ascertain that the information receives the same level of protection as if it remained within the EEA, including when entering into data transfer agreements, using the EU Commission approved Standard Contractual Clauses, or by relying on certification schemes such as the EU-US Privacy Shield.
6. How We Keep Your Information Secure
We use commercially reasonable physical, electronic, and procedural safeguards to protect your Personally Identifiable Information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction in accordance with requirements of applicable laws.
7. Use of ‘Cookies’
8. Use of Information for Personal Advertising
The information collected by Our Partners is used to analyze trends, understand user activities and gather demographic information to enable, manage and develop their personalized ads and related services. Our Partners may share such information with their affiliates. To do this, Our Partners use technologies such as cookies and web beacons to collect information about your interaction with our Website and third-party websites. This type of information does not identify you personally and, typically, is aggregated with other data to create segments —groups of users and general interest categories that are inferred based on a range of factors (for example, «sports fan»). Our Partners use this information to form a more accurate picture of the interests of the audiences with which they interact — including you — so that their ads are more relevant to those interests.
In addition, Our Partners may use the information collected from these types of cookie or similar technologies for a variety of other purposes, including:
- in conjunction with advertising that appears on other third-party websites;
- to measure the effectiveness of web-based and email advertisements;
- for reporting website traffic, statistics, advertisement data and other interaction with ads and the websites on which they are served.
Our Partners retain your information in accordance with their legitimate business purposes for processing. Thereafter, the information is removed, archived for restricted legitimate interests, or anonymized. Non-identifying information may be kept without time and use limitations.
9. Retention of Personal Information
If you reside or are located in the EEA, your Personally Identifiable Information will be stored for no longer than necessary for the purpose for which the Personally Identifiable Information was collected. The length of time Personally Identifiable Information is retained depends on the purpose for which such information was collected and/or as required to comply with applicable laws and establish, exercise or defend our legal rights.
10. Your Legal Rights
You have certain rights in relation to your Personally Identifiable Information. Depending on the jurisdiction, you have the right to request that we:
- provide access to any Personally Identifiable Information we, or Our Partners, hold about you;
- update any Personally Identifiable Information which is out of date or incorrect;
- delete any Personally Identifiable Information which we, or Our Partners, are holding about you, or withdraw your consent, where applicable;
- object to certain means of processing of Personally Identifiable Information (e.g., opt-out from marketing communications);
- restrict the way in which we process your Personally Identifiable Information;
- provide your Personally Identifiable Information to a third-party service provider;
- provide you with a copy of any Personally Identifiable Information which we hold about you.
The above requests shall be processed by us within reasonable time and unless provided otherwise from the local applicable law, within one month from the submitted written request. This period of time may be extended under certain circumstances by further two months.
You will not have to bear any cost to exercise any of your rights. We may though charge a reasonable fee should your requests be clearly unfounded or excessive. due to their repetitive character, or refuse to comply with such requests
Where applicable, we may request specific information to assist us confirm your identity and ensure your capacity to enforce your rights. This is part of our security measures to certify that your Personally Identifiable Information is not disclosed to any person who has no right to receive it.