Tugg, Inc. (“Tugg”, “we”, “our”, or “us”) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive via our Service (as defined in the Terms of Service available at from users of our Service. This Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on the Service. Your use of the Service following any such notice will signify and constitute your assent to and acceptance of such revised Privacy Policy. Unless otherwise defined in this Privacy Policy, capitalized terms used herein have the same meanings as in our Terms of Service and Purchase Policy.

Except as described in this Privacy Policy, this Privacy Policy does not apply to the products or services of our business partners or to any other third parties, even if their products or services are linked to, or embedded within, our Service. For example, we may provide social media features as part of our Service that enable you to share information with your social networks and to interact with us or others on various online social media networks. Your use of these features may result in the collection or sharing of information about you, depending on the feature. We recommend that you review the privacy statements of the other parties with whom you interact before submitting your information.

  1. Information Collection and Use

For the purposes of this Privacy Policy, “Personal Information” means information that can be used to contact or uniquely identify you, such as your name, telephone number, e-mail address, shipping address, billing address and credit card account number.

Personal Information We Collect

When you interact with us, we may ask you to supply us with Personal Information. For example, when you create an account with us, purchase or rent audiovisual content from the Tugg library, upload audiovisual content, buy tickets to an Event, or place an order, or otherwise use our Service, we may ask you to provide information such as your name, address, phone number, e-mail address, gender, date of birth, and user names on various social media platforms (e.g., Facebook, Twitter, and Google).

If you use our Service to share your content with third parties, or to send invitations or information regarding products and services (including without limitation, Events) to third parties, we may collect the information you provide about those third parties, such as their name, e-mail address, phone number and mailing address. Please be aware that when you use any send-to-a-friend functionality on our Service, your e-mail address may be included in the communication sent to your friend.

We also may, from time to time, supplement the information we collect with outside records from third parties, such as Channel Owners (pursuant to the Channel Owner Agreement and the privacy policy of the applicable Channel) or Promoters (pursuant to the Promoter Agreement), in order to enhance our ability to serve you and to tailor our content to you. We may combine the information we receive from those other sources with information we collect through our Service. In those cases, we will apply this Privacy Policy to any Personal Information received, unless otherwise specifically disclosed by us at the time you provide such Personal Information. For example, if you log in to our Service via a Facebook account, Facebook will provide us with information about you, and we will treat that information in accordance with this Privacy Policy.

Our Use of Your Personal Information

We mainly use your Personal Information, either alone or in combination with other information, so that we can provide, enhance and personalize our Service and related content, products, and marketing efforts.

The following are examples of a variety of ways that we may use your Personal Information. We may use your Personal Information:


*           to provide you with the best customer experience possible;

*           to provide the products and services (including without limitation, tickets) you purchase, respond to your questions, and carry out the transactions you have requested;

*           to communicate with you regarding Service updates, offers, orders, alerts, promotions, and events;

*           to help us develop, customize, deliver, support and improve our Service, products, content, and advertising;

*           to help authenticate any account you create with us;

*           to administer promotions and contests;

*           to protect the rights or property of Tugg or our users, and prevent fraud and other prohibited or illegal activities;

*           to protect the security of our products, services, and business;

*           for our internal purposes (such as auditing, data analysis, and research to improve our products, services, and communications); and

*           otherwise, as disclosed to you at the point of collection.

If you purchase tickets to an Event, or rent or purchase audiovisual content or other goods, we may provide your email address and name to the party that owns or controls such audiovisual content or other goods, to the applicable Channel Owner (if any) and/or to the applicable Promoter (if any), who may send communications to you directly. If you decide at any time that you no longer wish to receive communications from us or the party that owns or controls such audiovisual content or other goods, the Channel Owner and/or Promoter, please follow any unsubscribe instructions that may be provided in those communications to you, or update your user preferences. Please note that we may use your Personal Information to contact you with important notifications, such as notices with respect to purchases, safety, or changes to our terms, conditions, and policies; you may not opt out of these notifications.

Public Forums

We may offer message boards, bulletin boards, chat features, or similar public forums where you and other users of our Service can post content or otherwise communicate. The protections described in this Privacy Policy do not apply when you provide information (including personally identifiable information about any person) in connection with your use of these public forums. We may use Personal Information and other information about you to identify you with a posting in a public forum and also to identify you on lists of users from your city that we display online. Any information you share in a public forum is public information and may be seen or collected by other persons, including third parties that do not adhere to the standards set forth in this Privacy Policy. We are not responsible for events arising from the distribution of any information you choose to publicly post or share through our Service.

Collection and Use of Non-Identifying Information

We may collect, use, transfer, and disclose information in a form that does not personally identify you (“Non-Identifying Information”) for any purpose. Non-Identifying Information can include certain Personal Information that has been de-identified; that is, information that has been rendered anonymous. We, the Channel Owners, Promoters, the parties that own or control audiovisual content or other goods that we make available to you and third parties and our third party service providers obtain non-personal information about you from information that you provide us, either separately or together with your Personal Information. We and/or our third party service providers also automatically collect certain Non-Identifying Information from you when you access our Service.

Certain Non-Identifying Information about you would be considered a part of your Personal Information if it were combined with other identifiers in a way that enables you to be identified. However, the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other Non-Identifying Information. We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other users or sources to attempt to provide you with a better experience, to improve the quality and value of our products and services, and to analyze and understand how our products and services are used. We may also use the combined information without aggregating it to serve you specifically.

Non-Identifying Information We Automatically Collect

When you access our Service, we, our third-party service providers and Channel Owners may use a variety of technologies, now and hereafter devised, that automatically record certain usage information. This information may include your Internet Protocol address (and other unique identifiers for the particular device you use to access the Internet), browser type, your web or application request, your interaction with our Service, the webpage or other feature you were using before you came to our Service, pages of our Website that you visit, information you search for via our Service, access times and dates, and other similar information. We use this information for a variety of purposes, including analyzing and enhancing our products and services, and to help personalize our Service for you. We do not treat this information as Personal Information (except to the extent required by local law), although if we combine it with the Personal Information you provide, we will treat the combined information as Personal Information. We, our third-party service providers and Channel Owners may automatically collect Non-Identifying Information using various methods, including, without limitation, cookies.

A cookie is a small data file transferred to your computer (or other device) when it is used to access our Service. Cookies may be used for many purposes, including to enable certain features of our Service, to better understand how you interact with our Service and to monitor aggregate usage by visitors and online traffic routing. You may be able to instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the online services you visit. If you do not accept cookies, however, you may not be able to use all portions of our online services or all functionality of our online services.

  1. Information Sharing and Disclosure

Except as described in this Privacy Policy, the Channel Owner Agreement, each respective Channel’s Privacy Policy and the Promoter Agreement, we will not share your Personal Information with other companies or individuals outside of Tugg unless we have received your consent. Non-Identifying Information may be provided to third parties for marketing, advertising, or other uses.

Our Service Providers and Other Third Parties

We may engage third party companies and individuals to perform services on our behalf (e.g., without limitation, payment processing, software maintenance services, e-mail notifications, product delivery services, database management, web analytics and other services). These third parties may have access to your Personal Information. If they do, this access is provided so that they may perform these tasks on our behalf and they are not authorized by us to otherwise use or disclose your Personal Information, except to the extent required by law. We may also provide your Personal Information (other than your payment information) to Promoters, Channel Owners and the licensors of the motion pictures, audiovisual works and/or other entertainment for which you purchase tickets on our Service or rent or purchase audiovisual content or other goods in order to communicate with you regarding events, films, productions, promotions, services and other products. For Events which permit Contributions, your Personal Information (other than your payment information except to the extent necessary to process your Contribution) may be provided to the organization(s) to which such Contributions are being provided. We encourage such parties to use your Personal Information responsibly, but we are not responsible for the actions of the Promoters, Channel Owners, such licensors or such organizations with respect to your Personal Information.

Compliance with Laws, Legal Process and Authorities

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of us or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable.

Data Transfer

Tugg processes Personal Information on our servers in the United States of America. Your Personal Information may be transferred to, and used by, Tugg entities located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. Such export is a requirement of providing your information to Tugg.

Business Transfers

If we become involved in a merger, acquisition, bankruptcy, or other transaction involving the sale of some or all of our assets, user information, including Personal Information collected from you through your use of our Service, could be included in the transferred assets. Should such an event occur, we will use reasonable means to notify you, either through email and/or a prominent notice on the Service.

  1. General.

Changing or Deleting Your Information

Tugg makes good faith efforts to enable features on the Service that provide individuals with reasonable access to Personal Information that they have provided to Tugg and the reasonable ability to review and correct it or ask for deletion, as applicable, if it is not otherwise required to be retained by law or for legitimate business purposes. To view and change Personal Information that you have directly provided to Tugg via the Service, you can log in to your user account on the Service and access your “Account” or “Profile” pages via the “My Tugg” link, or contact Tugg in writing via the “Contact Us” page on the Website. Please note we may retain server/backup copies of all such data, and that we may decline to process change or deletion requests that we deem to be unreasonable, or require disproportionate technical effort, or jeopardize the privacy of others.


We employ reasonable security measures to protect your Personal Information from unauthorized access, alteration, disclosure, or destruction. These security measures include administrative, technical, and physical precautions to safeguard your Personal Information against loss, theft, and misuse. Please be advised, however, that while we strive to protect your Personal Information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and are not responsible for the theft, destruction or inadvertent disclosure of your Personal Information.

Third Party Products and Services

Our products and services may contain links to, or content from, third party websites, including without limitation, Channels, and other products and services. Such third party websites are owned and operated by third parties and/or their licensors. Your access and use of the third party websites, including any online communication services such as chat, email and calls will be governed by the terms of use and privacy policies of those applicable third party websites, except to the extent that you engage in a transaction, on a Channel, directly with Tugg in which event the terms of this Privacy Policy and our Terms of Service will govern the information that we collect from you from such transaction, provided that all other features of the Channel will be governed by the terms of use and privacy policy of such channel. The fact that we link to a website or display an advertisement or other third party content is not an endorsement, authorization or representation of our affiliation with any of those third parties, nor is it an endorsement of their privacy or information security policies or practices.

We do not exercise control over third party websites, products or services. These other products and services may place their own cookies or other files on your computer or other device, collect data or solicit personal information from you. Other persons and entities follow different rules regarding the use or disclosure of the information you submit to them or they collect from you. We encourage you to learn about the privacy practices of those third parties. You acknowledge and agree that we will not be liable for any loss or damage caused by your use of or reliance on such third party websites, including the (1) availability or accuracy of third party websites, or (2) the content, advertising, or products on or available from third party websites. Your use of third party websites is at your own risk.

Our Policy Toward Children

We do not knowingly collect Personal Information from children under 13 via our Service, and do not target our Service to children under 13. We encourage parents and guardians to take an active role in their children’s online activities and interests.

Do Not Track

Some web browsers have settings that include “do not track signals.” Our services are not currently engineered to respond to those signals from browsers.

Changes to this Privacy Policy

We will occasionally update this Privacy Policy. If we make changes, we will revise this Privacy Policy to reflect such changes and revise the effective date included at the end of this policy.

Contacting Us

If you have any questions about this Privacy Policy, please feel free to contact us using the functionality available on the “Contact Us” page on the Website.