Privacy Policy

This Privacy Policy describes how Sugie ("we," "us," or "our") collects, uses, shares, and protects your personal information when you use Sugie.fun ("the Platform"). By using the Platform, you consent to the practices described in this policy.

We are committed to protecting your privacy. As a Web3-native platform, we are designed to minimize data collection where possible and give you control over your personal information.

1. Information We Collect

1.1 Information You Provide

• Account Information: Name, email address, date of birth, gender, and role selection (Sugar Baby or Sugar Daddy/Mommy).
• Profile Information: Photos, bio text, location (city), lifestyle tags, body type, ethnicity, education, income range, and arrangement preferences.
• Wallet Information: Your Solana wallet public address. We never have access to your private keys.
• Verification Data: Selfie photos and government-issued ID (if you choose to verify your identity). This data is processed by our third-party verification provider.
• Communications: Messages sent through the Platform's messaging system, support requests, and feedback.

1.2 Information Collected Automatically

• Device Information: Browser type, operating system, device type, screen resolution, and language preferences.
• Usage Data: Pages visited, features used, time spent on the Platform, search queries, and interaction patterns.
• IP Address: Used for security, fraud prevention, rate limiting, and approximate geolocation (country/region level).
• Cookies & Similar Technologies: See our Cookie Policy for details.

1.3 Blockchain Data

When you use the escrow system, certain data is recorded on the Solana blockchain, including wallet addresses, transaction amounts, timestamps, and arrangement terms hashes. Blockchain data is public and immutable — it cannot be deleted or modified by Sugie or any third party. We recommend reviewing how blockchain transparency may affect your privacy before using on-chain features.

2. How We Use Your Information

We use your information to:

• Provide the Service: Create and manage your account, display your profile to other members, facilitate messaging and matches, and process escrow transactions.
• Verify Identity: Confirm your age and identity, prevent fraud, and display verification badges.
• Ensure Safety: Detect and prevent abuse, fraud, trafficking, and other harmful behavior. Monitor compliance with our Terms of Service.
• Improve the Platform: Analyze usage patterns, optimize features, fix bugs, and develop new functionality.
• Communicate: Send transactional emails (e.g., arrangement confirmations, security alerts), respond to support requests, and send product updates (with your consent).
• Legal Compliance: Comply with applicable laws, respond to legal requests, and enforce our Terms.

3. How We Share Your Information

We do not sell your personal information. We may share your data in the following limited circumstances:

• With Other Members: Your profile information (name, photos, bio, location, tags) is visible to other members based on your privacy settings. Your wallet address is shared only with members you enter into an arrangement with.
• Service Providers: We use trusted third-party services for hosting (Vercel), database (PostgreSQL), identity verification (Jumio/Onfido), real-time messaging (Ably), email delivery (Resend), image storage, and content moderation. These providers process data on our behalf and are contractually obligated to protect your information.
• Legal Requirements: We may disclose your information if required by law, court order, or governmental request, or if we believe disclosure is necessary to protect the rights, safety, or property of Sugie, its members, or the public.
• Safety & Enforcement: We may share information with law enforcement agencies in cases involving suspected trafficking, exploitation, or other illegal activity.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred as part of the transaction. We will notify you of any such change.

4. Data Storage & Security

Your data is stored on secure servers managed by our infrastructure providers. We implement industry-standard security measures including:

• Encryption in transit (TLS/HTTPS) and at rest.
• Access controls and role-based permissions for our team.
• Regular security audits and vulnerability assessments.
• Rate limiting and DDoS protection.
• EXIF/metadata stripping from uploaded photos before storage.

While we take reasonable precautions, no system is 100% secure. We cannot guarantee the absolute security of your data. You are responsible for protecting your wallet private keys and login credentials.

5. Data Retention

We retain your data as follows:

• Active Accounts: Your data is retained for as long as your account is active.
• Deleted Accounts: Upon account deletion, your profile, photos, and messages are deleted within 30 days. Some data may be retained longer for legal, safety, or fraud prevention purposes (up to 3 years).
• Blockchain Data: Data recorded on the Solana blockchain is permanent and cannot be deleted by Sugie.
• Verification Data: Identity verification documents are retained for the minimum period required by our verification provider and applicable regulations, then securely destroyed.
• Anonymized Data: We may retain anonymized, aggregated data indefinitely for analytics and improvement purposes. This data cannot be used to identify you.

6. Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

6.1 All Users

• Access: Request a copy of the personal data we hold about you.
• Correction: Update or correct inaccurate personal data via your profile settings or by contacting us.
• Deletion: Delete your account and request removal of your personal data (subject to legal retention requirements).
• Data Export: Request a portable copy of your data in a machine-readable format.

6.2 European Economic Area (GDPR)

If you are located in the EEA, you also have the right to:

• Restrict Processing: Request that we limit how we use your data in certain circumstances.
• Object: Object to our processing of your data based on legitimate interests.
• Withdraw Consent: Withdraw your consent at any time where we rely on consent as the legal basis for processing.
• Lodge a Complaint: File a complaint with your local data protection authority.

Our legal bases for processing your data under GDPR include: performance of our contract with you (providing the service), legitimate interests (safety, fraud prevention, platform improvement), consent (marketing communications), and legal obligations.

6.3 California Residents (CCPA)

If you are a California resident, you have the right to:

• Know what personal information we collect and how it is used.
• Request deletion of your personal information.
• Opt out of the sale of your personal information (we do not sell personal information).
• Non-discrimination for exercising your privacy rights.

7. Privacy Controls

Sugie provides in-app privacy controls that allow you to manage your visibility and data sharing:

• Online Status: Choose whether to show your online status to other members.
• Profile Visibility: Control whether your profile appears in search results and discovery feeds.
• Read Receipts: Toggle read receipts in messages on or off.
• Profile Views: Choose whether others can see when you've viewed their profile.
• Block & Report: Block any member to prevent all contact and remove them from your experience.

These controls are available in your Settings > Privacy & Activity section.

8. Photo Privacy

We take your photo privacy seriously:

• All EXIF data and metadata is stripped from uploaded photos before storage, ensuring no location data, device information, or timestamps are retained in your images.
• Photos are stored securely and served via encrypted connections.
• Profile photos are subject to moderation to prevent inappropriate content.
• You can delete any photo from your profile at any time.

9. Children's Privacy

Sugie is strictly for users who are 18 years of age or older. We do not knowingly collect personal information from anyone under 18. If we discover that we have collected data from a minor, we will delete the account and associated data immediately.

If you believe a minor is using the Platform, please report it to us immediately at support@sugie.fun.

10. Third-Party Services

The Platform integrates with third-party services that have their own privacy policies. We encourage you to review them:

• Phantom Wallet: Wallet connection and transaction signing. Phantom Privacy Policy
• Solana Blockchain: On-chain transactions are public and permanent.
• Google / Apple: If you sign in with social login, the respective provider's privacy policy applies to the data they share with us.
• Identity Verification: Verification documents are processed by our third-party KYC provider in accordance with their privacy policy and applicable regulations.

The Platform may contain links to third-party websites. We are not responsible for the privacy practices or content of those sites.

11. International Data Transfers

Your data may be processed and stored in countries outside your jurisdiction, including the United States. We ensure appropriate safeguards are in place for international transfers, including Standard Contractual Clauses (SCCs) where required by GDPR and compliance with applicable data transfer frameworks.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. We will notify you of material changes via email or an in-app notification. The "Last updated" date at the top of this page indicates when the policy was last revised.

Continued use of the Platform after changes constitutes acceptance of the updated policy. We encourage you to review this page periodically.

13. Contact Us

If you have questions about this Privacy Policy or want to exercise your data rights, please contact us:

• Privacy Inquiries: privacy@sugie.fun
• General Support: support@sugie.fun
• Data Requests: To request data export, correction, or deletion, use the data management tools in your account settings or email privacy@sugie.fun.

For GDPR-related inquiries, you may also contact your local data protection authority.