Important: TEGULAR SOFTWARE LLC is committed to protecting your privacy. We do NOT store your private keys, recovery phrases, or have access to your cryptocurrency. This Privacy Policy explains how we collect, use, and protect your personal information in compliance with GDPR and CCPA regulations.
01 // Data Controller
TEGULAR SOFTWARE LLC
1325 E Woodland Dr, Spring Valley, 91977, United States
Email: info@tegular.it.com
Phone: +1 605 642 9088
02 // Information We Collect
2.1 Information You Provide
| Data Type | Purpose | Legal Basis (GDPR) |
|---|---|---|
| Name and Shipping Address | Beta program fulfillment (if selected) | Contract Performance / Consent |
| Email Address | Beta application, support, updates | Consent, Legitimate Interest |
| Phone Number (optional) | Customer support, delivery notifications | Consent |
| Payment Information | Transaction processing | Contract Performance |
2.2 Automatically Collected Information
| Data Type | Purpose | Legal Basis (GDPR) |
|---|---|---|
| IP Address | Security, fraud prevention, analytics | Legitimate Interest |
| Device Information | App compatibility, troubleshooting | Legitimate Interest |
| Usage Data | Service improvement, analytics | Legitimate Interest |
| Cookies (see Cookie Policy) | Website functionality, analytics | Consent |
2.3 Information We DO NOT Collect
We explicitly do NOT collect, store, or have access to:
- Your private keys or seed phrases
- Your cryptocurrency wallet addresses
- Your transaction history or blockchain activity
- Your PIN codes or authentication credentials
- Your cryptocurrency balances or holdings
03 // How We Use Your Information
3.1 Primary Uses
- Beta Program: Process applications and ship SecureCard Pro to selected beta testers
- Customer Support: Respond to inquiries, provide technical assistance, and resolve issues
- Product Updates: Send firmware updates, security notifications, and important product information
- Legal Compliance: Comply with applicable laws, regulations, and legal processes
3.2 Secondary Uses (with consent)
- Marketing Communications: Send promotional emails about new products and features (opt-out available)
- Service Improvement: Analyze usage patterns to improve our app and services
04 // Legal Bases for Processing (GDPR)
We process your personal data based on the following legal grounds:
- Consent: Processing based on your explicit consent (beta program, marketing, cookies)
- Legitimate Interest: Processing for fraud prevention, security, and service improvement that does not override your rights
- Legal Obligation: Processing required to comply with legal obligations (tax reporting, law enforcement requests)
05 // Data Sharing and Disclosure
5.1 Third-Party Service Providers
| Service Provider | Purpose | Data Shared |
|---|---|---|
| Payment Processors | Process credit card transactions | Payment info, billing address |
| Shipping Carriers | Deliver products | Name, address, phone number |
| Email Service Providers | Transactional and marketing emails | Email address, name |
| Cloud Hosting | Store and process data securely | Account info, order history |
| Analytics Providers | Website and app analytics | Usage data, IP address (anonymized) |
All third-party providers are contractually obligated to protect your data and use it only for specified purposes.
5.2 We Do NOT Sell Your Data
We do NOT sell personal data to third parties. We do NOT share data for advertising purposes.
5.3 Legal Disclosures
We may disclose your information when required by law, to protect our rights or safety, to prevent fraud, or in connection with business transfers (mergers, acquisitions).
06 // International Data Transfers
TEGULAR SOFTWARE LLC is based in the United States. If you are located outside the United States, your information will be transferred to and processed in the United States.
6.1 EU–US Data Transfers
- Standard Contractual Clauses (SCCs): We implement EU Commission-approved SCCs with our service providers
- Adequacy Decisions: Where applicable, we rely on European Commission adequacy decisions
- Additional Safeguards: Encryption, access controls, and regular security audits
07 // Data Retention
| Data Category | Retention Period | Reason |
|---|---|---|
| Beta Application Data | 3 years | Program management, warranty claims |
| Customer Support Records | 3 years | Service quality, warranty claims |
| Marketing Consent | Until withdrawal | Marketing communications |
| Analytics Data | 26 months | Service improvement |
| Account Information | Until deletion request | Account management |
08 // Your Rights Under GDPR
If you are in the European Union, you have the following rights:
Obtain confirmation of whether we process your data and request a copy.
Request correction of inaccurate or incomplete personal data.
Request deletion when data is no longer necessary or consent is withdrawn.
Request restriction of processing when accuracy is contested or processing is unlawful.
Receive your data in a structured, machine-readable format to transfer to another controller.
Object to processing based on legitimate interests or for direct marketing at any time.
Withdraw consent at any time without affecting prior lawful processing.
File a complaint with your local supervisory authority if you believe GDPR has been violated.
To exercise your GDPR rights, contact: info@tegular.it.com. We respond within 30 days as required by GDPR.
09 // Your Rights Under CCPA (California)
9.1 Right to Know
You may request categories of personal information collected, sources, business purposes, and third parties with whom we share information.
9.2 Right to Delete
You may request deletion of your personal information, subject to certain exceptions.
9.3 Right to Opt-Out of Sale
We do NOT sell personal information. Therefore, there is no need to opt-out of sale.
9.4 Right to Non-Discrimination
We will not discriminate against you for exercising your CCPA rights. You will not receive different prices or services.
To exercise CCPA rights, contact: info@tegular.it.com or +1 605 642 9088. We verify your identity before processing and respond within 45 days.
10 // Data Security
10.1 Technical Safeguards
- Encryption: All data transmitted over the internet is encrypted using TLS 1.3
- Secure Storage: Personal data is stored on encrypted servers with restricted access
- Access Controls: Only authorized personnel have access on a need-to-know basis
- Regular Audits: We conduct regular security audits and vulnerability assessments
- Incident Response: We have procedures in place to respond to data breaches
10.2 Physical & Administrative Safeguards
- Secure data centers with 24/7 monitoring and restricted physical access
- Employee training on data protection and privacy
- Confidentiality agreements with all personnel and regular policy reviews
Important: While we implement robust security measures, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security of your data.
11 // Children's Privacy
SecureCard Pro is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child under 18, we will take steps to delete such information promptly. Contact us at info@tegular.it.com if you believe we have collected such information.
12 // Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
TEGULAR SOFTWARE LLC — Privacy Department
1325 E Woodland Dr, Spring Valley, 91977, United States
Email: info@tegular.it.com
Phone: +1 605 642 9088
EU Representative (GDPR inquiries): gdpr@tegular.it.com
If you are in the European Union and believe we have violated your data protection rights, you may lodge a complaint with your national data protection authority.