Privacy Policy

1. Introduction

NUGL.com ("we," "our," or "us") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website.

This policy complies with the General Data Protection Regulation (GDPR) for European users and the California Consumer Privacy Act (CCPA) for California residents.

2. Information We Collect

2.1 Information You Provide

• Email address (for newsletters, investor updates, account creation)
• Name and contact information (if provided)
• Wallet addresses (for crypto transactions)
• Payment information (processed through third-party providers)
• Communications with customer support
• Brand / Dispensary / Content listings: business name, website, category, phone number, description, logo, pricing tier selected, and transaction hashes you send us to confirm crypto payment
• Investor Subscriptions: email and optional name captured via the Investor Relations page when you opt in to quarterly-report and press-release updates

2.2 Information Collected Automatically

• IP address and device information
• Browser type and version
• Pages viewed and time spent on pages
• Referring website addresses
• Click data and navigation patterns
• Cookies and similar tracking technologies

2.3 Third-Party Data

We may receive information from analytics providers (Google Analytics), affiliate networks, and social media platforms.

3. How We Use Your Information

We use collected information for:

• Service Delivery: To provide and improve our services
• Communication: To send newsletters, updates, and respond to inquiries
• Analytics: To understand user behavior and improve the Site
• Security: To detect and prevent fraud, abuse, and security threats
• Legal Compliance: To comply with legal obligations and enforce our Terms
• Marketing: To show relevant content and advertisements (with consent)
• Affiliate Tracking: To track referrals and commissions

4. Cookies and Tracking Technologies

We use cookies, web beacons, and similar technologies to enhance your experience. For detailed information, see our Cookie Policy.

Types of Cookies We Use:

• Essential Cookies: Required for site functionality
• Analytics Cookies: Google Analytics for usage statistics
• Preference Cookies: Remember your settings
• Advertising Cookies: For targeted advertising (with consent)

5. Information Sharing and Disclosure

We may share your information with:

• Service Providers: Analytics, hosting, payment processors
• Affiliate Partners: When you click affiliate links (anonymous tracking data)
• Legal Authorities: When required by law or to protect our rights
• Business Transfers: In case of merger, acquisition, or sale

We do NOT sell your personal information to third parties for their marketing purposes.

6. Data Security

We implement appropriate technical and organizational measures to protect your data, including:

• SSL/TLS encryption for data transmission
• Secure server infrastructure
• Regular security audits
• Access controls and authentication
• Rate limiting on authentication endpoints (5 attempts / 15 minutes per IP)
• Session-scoped admin credentials (never persisted to long-term browser storage)

However, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security.

7. Specific Data Flows

7.1 Investor Relations Subscriptions

When you subscribe to NUGL, Inc. (OTC: NUGL) investor updates via the Investor Relations page, we store your email address and optional name in our investor_subscriberscollection. We use this strictly to send quarterly reports, annual highlights, press releases, and material corporate updates. You can unsubscribe at any time by emailing info@nugl.com — we will purge your record within 30 days.

7.2 Brand, Dispensary & Content Submissions

When you submit a listing (Brand / Dispensary) or sponsored content via the Canna Hub, Psychedelics Hub, or Shop pages, we collect the business details you provide (company name, website, contact email, phone, category, description, logo URL) plus the pricing tier you selected. For paid tiers, we also record the crypto transaction hash you send us to verify payment. This data is stored in our brand_submissions, dispensary_submissions, and content_submissions collections, retained for the duration of your active listing plus 7 years for tax / accounting compliance.

7.3 Admin Access

Admin dashboard access is password-protected and verified server-side via POST /api/admin/verify. On successful login the typed password is held in the browser's sessionStoragefor the duration of the tab only — it is cleared when the tab closes and never written tolocalStorage, cookies, or any persistent store. Repeated failed login attempts are rate-limited to 5 per 15 minutes per IP address.

7.4 AI / LLM Services

Certain features (AI chat, news summarization, annual-report auto-extraction) forward prompt content and uploaded documents to third-party large language models (Google Gemini, OpenAI GPT, Anthropic Claude) via an Emergent-managed gateway. These providers process the content ephemerally under their respective privacy policies and do not retain it for model training. Do not paste sensitive personal data into AI chat inputs.

8. Your Privacy Rights

8.1 GDPR Rights (EU Users)

• Right to access your personal data
• Right to rectification of inaccurate data
• Right to erasure ("right to be forgotten")
• Right to restrict processing
• Right to data portability
• Right to object to processing
• Right to withdraw consent

8.2 CCPA Rights (California Residents)

• Right to know what personal information is collected
• Right to know if personal information is sold or disclosed
• Right to say no to the sale of personal information
• Right to access your personal information
• Right to equal service and price

To exercise these rights, contact us at: privacy@nugl.com

9. Data Retention

We retain your personal data only as long as necessary for the purposes outlined in this Privacy Policy or as required by law. When data is no longer needed, we securely delete or anonymize it.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place to protect your data in compliance with applicable laws.

11. Children's Privacy

Our Site is not intended for individuals under 18 (or 21 in certain jurisdictions). We do not knowingly collect personal information from minors. If you believe we have collected information from a minor, contact us immediately.

12. Third-Party Websites

Our Site contains links to third-party websites (dispensaries, affiliates, partners). This Privacy Policy does not apply to those sites. We encourage you to review their privacy policies.

13. Changes to This Privacy Policy

We may update this Privacy Policy periodically. Changes will be posted on this page with an updated "Last Updated" date. Significant changes will be communicated via email or prominent notice on the Site.

14. Contact Us

For questions about this Privacy Policy or to exercise your privacy rights: