Privacy Policy

PRIVACY POLICY – iNUDGE

EFFECTIVE DATE: March 11, 2026

DATE OF LATEST UPDATE: March 11, 2026

NudgedSocials OÜ (the “Service Provider”, “we”, “our”, “us” and other similar expressions), an Estonian company, owns and manages the iNudge application and its corresponding website (collectively, the “Application”). The Application provides a free service intended to help users connect with other users within geographic proximity who share similar interests. Use of the Application is contingent upon accepting to be subject to this Privacy Policy.

This Privacy Policy (the “Privacy Policy” or “Policy”) sets forth the policy applicable to our collection, usage, storage, maintenance, and disclosure of Personal Data provided through the Application. This Privacy Policy also sets forth the rights provided to users of the Application in connection with their Personal Data.

1. DEFINITIONS

Certain capitalized terms used in this Privacy Policy have the meanings provided below.

“Account” means the user account you create on the Application to benefit from the Services.

“Affiliate” means any of our employees, contractors, consultants, or third party service providers.

“Personal Data” means information relating to an identified or identifiable natural person allowing for such person to be identified. Personal Data includes a person’s name and address.

“Non-Personal Data” means information that cannot be used in isolation to identify a natural person. Non-Personal Data includes anonymous usage data, general demographic information and preferences submitted. However, certain Non-Personal Data may identify a natural person when combined with other information.

“Services” means the facilitation services offered by the Service Provider through the Application.

“Third Party Sites” means third party websites, sites, and/or platforms linked or otherwise provided on the Application.

“Users” means all users of the Application. Individual users of the Application are referred to as “you”, “your” and other similar expressions in this Privacy Policy.

2. BACKGROUND

The Application provides the Services at no cost for Users and solely for the purpose of connecting local Users with Users who share similar interests. Users may select areas of interest and their location in order for the Application to facilitate their connection with Users.

3. APPLICATION

This present Privacy Policy shall apply to our collection, use and disclosure of your Personal Data provided on or obtained from the Application. Any provision or submission of your Personal Data on the Application is subject to and governed by this Privacy Policy. This Privacy Policy further indicates your rights in connection with your Personal Data.

4. BINDING LAWS

This Privacy Policy has been drafted in accordance with the requirements set forth in privacy and data protection laws applicable in North America as well as in the European Union. Certain privacy laws apply to Users residing in the states of California and Nevada as well as to Users residing in the European Union (EU).

5. CONSENT

Once you access, browse or use the Application, in any way, you are deemed to have read, understood and agreed to this Privacy Policy, in its entirety. Accordingly, your access or use of the Application signifies your agreement with this Privacy Policy. If you do not agree with this Privacy Policy, even partially, please refrain from using the Application.

6. CHILDREN’S PRIVACY

The Application is intended for Users who are at least eighteen (18) years old. Any child who is at least thirteen (13) years old may however use the Application with the authorization of the child’s parent or legal guardian. In this case, all use of the Application must then be supervised by the child’s parent or legal guardian. We do not knowingly target or advertise to minors. We do not intend nor wish to receive any Personal Data from children. We also do not knowingly collect Personal Data from children.

7. CHANGES TO THIS PRIVACY POLICY

We may update this Policy, in full or in part, from time to time, at our discretion. The latest version of this Privacy Policy will be published and available for review on the Application. You are encouraged to consult this Privacy Policy regularly for any changes, as your continued use is deemed to be approval of all changes.

The date of the latest update made to this Privacy Policy is specified in the header. The latest version is enforceable and applicable as of the date listed in the header.

8. PERSONAL DATA YOU SUBMIT

Any Personal Data you submit on the Application is voluntarily provided. You are not required to provide Personal Data to access the Application. While you are not under any obligation to provide Personal Data on the Application, you understand that the Services may not be available to you if you do not have an Account. Additionally, once you create an Account, you will have a public profile on the Application. Your public profile will be shared with Users on the Application to allow for the provision of the Services. The following information will be shared as part of your public profile: Your name and your interests. You may select your interests from a list of categories, which include, without limitation, books, music, movies, sports, wellness, travel, gaming, food, university alumni and network and fandoms. It is optional for you to include your social media handle as part of your public profile.

9. DATA WE COLLECT

We remain committed to protecting Personal Data that you submit on the Application. Accordingly, we only collect Personal Data you voluntarily provide on the Application upon your download and use. We also automatically collect Non-Personal Data from the Application. Personal Data To create an Account on the Application and benefit from the Services, we may require that you provide us with Personal Data, including, without limitation, your email address, User ID, name, age and gender. As stated, it is optional for you to provide your social media handle on the Application. Considering the Services are provided free of charge, no payment information will be collected from you. For certainty, we do not allow for the provision of financial information, such as credit card numbers, on the Application. Non-Personal Data When you access, use or log onto the Application, we may collect indirect identifiers, such as your device, the pages visited, the time and dates of your visits, the operating system of your device and how you use the Application. Non-Personal Data, including indirect identifiers, is anonymous, and therefore do not allow for your identification, unless combined with other Non-Personal Data and Personal Data. Moreover, we may collect information regarding your usage history, such as interests selected and Users connected with. We may collect such information to provide you with personalized recommendations and to analyze the popularity of certain interests. We may also automatically collect information obtained through cookies, pixel tags and web beacons. Location and Bluetooth Data The Application uses Bluetooth and device location services to determine your approximate geographical location and estimate proximity between Users. These technologies provide approximate location data and may not always accurately reflect the actual distance between Users. This is essential for providing our core Services. Location data is used for our geolocation Services, such as displaying Users nearby and facilitating the matching process. The Application uses Bluetooth to collect anonymized device data to detect and connect with other Users in your vicinity for purposes of connection.

10. SECURITY

We handle, safeguard and protect Personal Data obtained from the Application in compliance with all applicable privacy and data protection laws and regulations. To ensure your Personal Data is handled and processed with care, we use various security measures, including physical, electronic and procedural safeguards to protect the Personal Data we process and maintain.

Additionally, considering Non-Personal Data can serve to identify when combined with other Non-Personal Data or Personal Data, we treat such Non-Personal Data with appropriate safeguards.

We do not share, communicate or disclose your Personal Data, except if absolutely necessary and required for legitimate purposes.

Any disclosure of Personal Data to an Affiliate will be strictly limited to data that is required to fulfill the purpose of the disclosure. Furthermore, we will not share your Personal Data with an Affiliate, unless the Affiliate is bound by confidentiality obligations as strict and binding as those set forth in this Privacy Policy.

We take available precautions and measures to protect and safeguard your Personal Data from unauthorized access and breaches. Notwithstanding the foregoing, you understand that despite our best efforts and security protocols in place, the transmission of Personal Data over the Internet is never completely secure. Consequently, we are unable to provide a guarantee regarding the security of your Personal Data beyond those required by applicable law. You also agree that your submission of Personal Data on the Application is at your sole risk.

11. HOW WE USE AND SHARE YOUR PERSONAL DATA AND OTHER DATA

We use your Personal Data only to fulfill the purposes expressly stated in this Policy. All our use of your Personal Data is limited to the extent required by our business interests, and in accordance with applicable legislation.

We are permitted to use your Personal Data for any of the following purposes:

To comply with a court order, legal obligation or applicable laws

We disclose all information legally required by a government agency, subpoena, court order or similar legal process. Considering the potentially urgent nature of a court order or legal obligations, we may not be able to notify you prior to the disclosure if your Personal Data is to be shared. In such cases, we will share the requested Personal Data, but we endeavor to ensure the sharing is restricted to that which is absolutely necessary to comply with the court order or law.

You waive your right to be notified prior to our disclosure of any Personal Data if required by law or a court order. Nonetheless, we seek to notify the impacted Users in advance, where possible. The notification is intended to allow you to secure a protective order or remedy to protect your Personal Data.

We also reserve the right to disclose your Personal Data if it is our good faith opinion that the disclosure is necessary to protect our rights, your safety, or the safety of others.

To provide the Services

We may share Personal Data to provide the Services, namely to help connect Users with similar interests who are within proximity. We use third-party services to generate analytics and assist with User matching. The Application uses the ChatGPT API by OpenAI solely to enhance our user matching algorithm. Your interests and public profile may be sent to the API in a pseudo-anonymized format, thereby not allowing for your identification, to help determine compatibility. As per OpenAI’s policies in effect at the date of the latest update of this Privacy Policy, data submitted via their API is not used to train their models.

We may use trusted third-party service providers to host infrastructure, process analytics, and maintain the Application.

To improve the Application

We may use the Personal Data we collect to provide and improve the Application and the Services. We may share Personal Data with trusted Affiliates, who assist us with the provision of the Services. As stated, all Affiliates are bound by strict confidentiality obligations and may not use the Personal Data for purposes unrelated to the provision of the Application and the Services.

To share a newsletter or marketing materials

We may use the email address you provided to send you a newsletter or marketing materials by email. You may opt out of receiving emails from us by unsubscribing in accordance with the instructions contained in the email.

For public interest or the public domain

For statistical purposes

We may use Non-Personal Data obtained from the Application to obtain analytical data. Such data may include but shall not be limited to total views, interests selected and number of Users connected.

The statistical data collected may be used to analyze performance data, metrics and statistics relating to Users and the effectiveness of the Services.

To process your requests

You may grant us an explicit authorization to use your Personal Data for purposes beyond those permitted in this Privacy Policy. You have the option of consenting to us using your Personal Data for specific marketing purposes and to benefit from certain Services. To be valid, any consent you provide will set out the scope of the consent and the duration thereof.

Provided the consent you granted complies with the terms of this Privacy Policy, we will be empowered to use such Personal Data to the extent specified in the consent you provided.

For advertising purposes

Considering the Services are provided at no charge, we reserve the right to display ads on the Application. We do not provide any Personal Data to these ad servers or ad networks without your consent. However, please note that if an advertiser asks us to show an advertisement to a certain audience and you choose to respond to that advertisement, the advertiser may determine that you fit the description of the audience sought by the advertiser.

You are encouraged to review the respective privacy policies of these third-party ad servers or ad networks. This Policy does not apply to, and we cannot control the activities of such advertisers.

12. REPORTING USERS

If you believe that another User has engaged in misconduct or violated this Privacy Policy while using the Application, you may report the issue to us, through our support section.

13. YOUR RIGHTS

You are granted certain rights in connection with your Personal Data disclosed on the Application. For reference purposes, any requests you submit to exercise your rights may be sent by email (support@inudge.app).

Right to be Informed

You hold the right to be informed of our collection and usage of your Personal Data. To exercise your right to be informed, as protected by data privacy laws, you may send us a request for information regarding our collection, use and processing of your Personal Data. Please send the email from the email address listed in your Account.

Upon our receipt of your written request, we will attempt to respond to your request in a timely manner. You acknowledge that we may only provide information that is both: (i) available and (ii) does not violate any applicable data protection laws.

Right to Make Corrections

We may, but are under no obligation, to verify that your Personal Data provided on the Application is true and current. If you believe that the Personal Data listed in your Account is inaccurate, you may update the information directly in your Account.

Right to Delete Account

You have the right to delete your Account at any time. The Application provides a clear and easy-to-find option to delete your Account. This is a complete deletion, not merely a deactivation. Once your Account is deleted, all Personal Data in connection with your Account will be deleted or anonymized as detailed in this Privacy Policy.

You can also email us to request the deletion of your Personal Data. We undertake to respond to your request within a reasonable time.

Right to Revoke Consent

You may consent to us using your Personal Data for purposes beyond those provided in this Privacy Policy. You benefit from the right to revoke any consent provided to us by sending us a request by email. There may be a delay in the removal of a consent previously provided. In this respect, you should expect processing times of at least forty-eight (48) hours following our receipt of your request sent by email.

14. PERSONAL DATA RETENTION AND DELETION

We retain Personal Data only for the duration necessary to fulfill the purposes set out in this Privacy Policy.

We retain and store your Personal Data in our secure servers so long as you have an active Account on the Application and for a reasonable time thereafter. We retain Personal Data to maintain information relating to dates of logins, connections with Users and previous interests.

Personal Data associated with your Account will be retained while your Account remains active. If you delete your Account, your Personal Data will be deleted or anonymized within thirty (30) days following the deletion request, except where the retention is required to comply with legal obligations, resolve disputes or protect our rights and interests.

Certain limited information, such as records relating to logins, connections and security logs, may be retained for a limited period following account deletion for fraud prevention, system integrity, and compliance purposes.

15. DATA TRANSFERS

You understand that your Personal Data may be processed or stored in jurisdictions other than in your country of residence. These jurisdictions may consist of jurisdictions where our Affiliates operate.

We may transfer your Personal Data outside of the country where we operate in compliance with applicable laws and regulations. In these cases, we proceed with a thorough assessment of the destination jurisdictions, to verify whether the destination jurisdiction benefits from an adequacy decision or whether appropriate technical safeguards are implemented.

When Personal Data is transferred across borders, we will take measures to ensure that the transfer complies with applicable data protection laws and that safeguards are implemented to protect your Personal Data.

16. USERS BASED IN CALIFORNIA

California privacy laws grant California residents the right to request information regarding the disclosure of their Personal Data to third parties for direct marketing purposes. In addition to this right, California residents benefit from additional rights, including the right to access any Personal Data collected and the right to request the deletion.

California residents further benefit from the right to be informed of our collection and usage of their Personal Data. California residents also have the right to obtain copies of their Personal Data we hold or store.

California Users may submit any of these requests to us by email in accordance with the terms of this Privacy Policy.

17. USERS BASED IN NEVADA

Users residing in the State of Nevada have the right to disallow the sale or licensing of their Personal Data to third parties. To exercise the right to disallow same, Users shall send us an email to our attention.

18. USERS BASED IN CANADA

Users residing in Canada are protected by Canadian privacy legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, the Act respecting the protection of personal information in the private sector in the Province of Quebec. These laws grant certain rights regarding Personal Data, including the right to access Personal Data and the right to request corrections to inaccurate information.

Users based in Canada may exercise these rights by emailing us in accordance with the terms of this Privacy Policy.

19. USERS BASED IN THE EUROPEAN UNION (EU)

Residents of the European Union (EU) and the European Economic Area (EEA) are governed by the General Data Protection Regulation 2016/679, commonly known as the GDPR. The GDPR sets forth the terms and conditions applicable to the collection, use and transfer of Personal Data. The GDPR grants its data subjects additional rights regarding the use, collection and handling of their Personal Data.

To exercise any of the rights granted to Users under this Privacy Policy or by the GDPR, Users residing in the European Union may send us an email. For any request to be valid, it must properly identify you, allowing us to ascertain your identity. Secondly, the request must specify the extent of the Personal Data requested and the justification for the request. If the request is found to be legitimate, we will comply with it. We reserve the right to use your Personal Data to confirm your identity and satisfy the request. We also reserve the right to refuse a request if it is unfounded or does not comply with the terms of this Privacy Policy.

If you reside in the European Union or the European Economic Area, our legal basis for collecting and using Personal Data depends on the Personal Data concerned and the context in which it is collected. We may process Personal Data on the following legal bases as set forth in this Policy and confirmed below:

Consent: You provided consent for the processing of your Personal Data for specific purposes.
Performance of the Services: The processing is needed to provide the Services and fulfill our obligations to you.
Legitimate Interests: The processing is needed for our legitimate interests, such as improving the Application, ensuring security, and analyzing trends, in compliance with your data protection rights.
Legal Obligations: The processing is to comply with applicable legal or regulatory obligations.

In accordance with the “data minimization” obligations contained in the GDPR, we will limit our usage of Personal Data only to such extent which is absolutely necessary to fulfill the purpose for which it was collected.

20. COOKIE POLICY

We reserve the right to use various types of cookies, including essential, functional, performance, analytical and/or advertising cookies. We may use cookies primarily for session management purposes and to optimize your experience on the Application.

We may obtain Non-Personal Data through cookies or small text files. Cookies may be sent to your browser from our servers, upon which the cookies are stored on your device.

Functional cookies are designed to save your preferences and settings. These cookies allow for the recognition of your devices, allowing for the safeguard of your preferences, such as location. Functional cookies retain information to facilitate your subsequent access and use of the Application.

Where applicable, you may remove or disable cookies by activating certain browser settings or turning off cookies.

You may delete the cookies stored on your device. You acknowledge that certain parts of the Application may be unavailable or inaccessible if cookies are disabled or removed. Moreover, the Application may not function optimally if cookies are disabled or otherwise removed.

21. THIRD PARTY SITES

This Privacy Policy applies solely and exclusively to the Application. Any links to Third Party Sites on the Application are provided for convenience purposes. The Third Party Sites are not governed by this Policy, and are subject to their own privacy policy.

The inclusion of any links to Third Party Sites on the Application does not imply our affiliation or association with such Third Party Sites.

22. CONTACT US

If you have any questions or comments regarding this Privacy Policy, we encourage you to contact us in writing so that your inquiry can be properly tracked and addressed. Below is your address:

NudgedSocials OÜ

Address: Harju maakond, Tallinn, Kesklinna linnaosa, Raekoja plats 8-42, 10146

Country: Estonia

You may send your questions or comments to us by email at support@inudge.app.