Privacy Policy

Last Updated: October 13, 2025

1. Introduction.

The mobile application known as Fuga ("App") and its related features (collectively, "Services") are provided to you under this Privacy Policy.

We are dedicated to safeguarding your privacy rights and to enhancing transparency and fairness in the handling of Personal Information (as defined below).

This Policy is designed to inform you about our practices concerning the collection, storage, usage, and sharing of information. It applies to your interactions with our Website, the App, and anytime you use or access the Services.

Providing Personal Information is not a legal requirement. However, without it, we may not be able to offer you the complete range of Services or the optimal user experience.

This Privacy Policy forms an integral part of the ==Terms of Service==, to which it is fully incorporated by reference. Any term not defined in this Policy shall be interpreted in accordance with the definitions provided in the Terms of Use.

We strongly recommend that you read this Policy thoroughly to ensure you fully understand and consent to it. Your use of the Services, including the Website and App, indicates your acceptance of this Policy. If you do not accept the terms contained in this Policy, please refrain from using the Services. Continuation of use of the Services following any updates to this Policy constitutes your acceptance of those changes.

2. What Types of Data We Collect?

We collect two categories of information from you: Personal Information and Non-Personal Information. "Personal Information" refers to any data that could reasonably be used to identify you. This might include, but is not limited to, your name, email address, and other identifiable details. In contrast, "Non-Personal Information" pertains to data that cannot identify you personally. Examples of Non-Personal Information include aggregated statistics about your use of our Services and technical details transmitted by your device, such as the type of device, browser, operating system, language settings, access times, and so forth. This policy outlines our practices for collecting both types of information.

Personal Information Collection

Non Personal Information

3. Tracking Technologies.

When you access or utilize our Services, we deploy cookies, pixels, beacons, local storage, and other similar tracking technologies ("Tracking Technologies"). These technologies automatically gather data about you, your device, and your interactions online, enhancing navigation on our Services, optimizing service performance, facilitating analytics, personalizing your experience, and delivering targeted content and advertisements aligned with your preferences.

The types of Tracking Technologies used are outlined as follows:

  1. Strictly Necessary Tracking Technologies: These are automatically activated on your computer or device upon accessing our Services or initiating certain activities on our App or Website. They are imperative for enabling the functionality of our Services, allowing you to navigate and use essential features. The use of these Tracking Technologies does not require your consent.

  2. Tracking and Advertising Technologies: These collect information related to your browsing habits to tailor advertising to your interests. They also limit advertisement repetition and gauge campaign effectiveness. This information, which includes the sites you visit, is shared with other entities such as advertisers and publishers. Furthermore, publishers, advertisers, and third-party ad networks might use these or similar technologies to deliver and track the performance of advertisements. The collection and usage of information via Tracking Technologies by such third parties are subject to their respective privacy or cookie policies, over which our Company has no control.

  3. Functionality Tracking Technologies: These enable our Services to remember your preferences (e.g., language choice) and offer enhanced, personalized features. They are employed for purposes such as authentication (to remember your login status) and to support other functionalities of our Services.

  4. Performance Tracking Technologies: These gather data regarding your activities online, such as the duration of your visit to our Services, as well as behavioral data and content interaction metrics. These technologies are utilized for analytics, research, and statistical purposes based on aggregated information.

Storage and Management of Tracking Technologies:

  1. Tracking Technologies are stored on your device during your visit or access to our Services as "First Party Tracking Technologies". Additionally, "Third Party Tracking Technologies" are stored by external parties (e.g., analytics service providers, business partners, and advertisers) who operate content on our Services. Both types of technologies might be stored either temporarily for a session or permanently for recurring visits.

  2. You can manage and control your Tracking Technologies settings through various means, including our cookie settings tool (note: availability may vary by jurisdiction), or by modifying your browser settings to issue a "Do-Not-Track" signal. It should be noted, however, that disabling cookies may impair the functionality of our Website or prevent certain features from operating correctly.

  3. To learn more about how can manage your cookies, below is a list of useful links that can provide you with more information on how to manage your cookies:

- Google Chrome

- Internet Explorer

- Mozilla Firefox

- Safari (Desktop)

- Safari (Mobile)

- Android Browser

  1. You can learn more and turn off certain third party targeting and advertising cookies by visiting the following third party webpages:

- The Interactive Advertising Bureau (US)

- The Interactive Advertising Bureau (EU)

- European Interactive Digital Advertising Alliance (EU)

  1. You can withdraw your consent to personalized advertising experience on your device at any time by using your device settings as follows:

- On iOS, depending on the applicable iOS version, you may withdraw consent across all apps by either enabling the "Limit Ad Tracking" setting or disabling the "Allow Apps to Request to Track" permission in your iOS device settings. Depending on the applicable iOS version, instead of withdrawing consent on a device-wide basis, you may also have the option of withdrawing consent on a per-app basis by disabling tracking permissions for specific apps that appear under the "Allow Apps to Request to Track" setting in your iOS device settings (precise directions may differ depending on the applicable iOS version).

- On Android devices, you may withdraw your consent in the Google Ads settings within your Android settings by enabling the "Opt out of Ads Personalization" setting (precise directions and the name of the setting may differ depending on the applicable Android versions and device manufacturer).

4. Conditions For Processing Personal Information.

This section outlines the underlying purposes and legal bases for the processing of your Personal Information:

Purpose Legal basis
Service Provision, Support, and Customer Relations: We employ your personal data, including but not limited to your name and email address, for the purpose of customer services. This encompasses managing your account, operating the Services, and addressing your inquiries. The lawful grounds for processing this data are as follows: the execution of our contractual commitments to you as stipulated in Article 6(1)(b) of the GDPR; your explicit consent as per Article 6(1)(a) of the GDPR; our adherence to legal obligations outlined in Article 6(1)(c) of the GDPR; and the pursuit of our legitimate interests according to Article 6(1)(f) of the GDPR. In this instance, our legitimate interests include the enforcement of our policies and the provision of our Services.
Enhancement of Our Services. We gather and analyze data pertaining to your use and interaction with our Services in order to enhance their functionality and efficiency. The lawful grounds for processing this data are predicated on our legitimate interests, as stipulated in Article 6(1)(f) of the GDPR, specifically for the purposes of delivering and enhancing our Services.
Marketing, Advertising, and Analytics: We utilize your Personal Information to deliver personalized advertising while you access our Services, to promote our Services, and to collect aggregated data regarding usage for analytical purposes. The lawful grounds for processing this data are based on your consent (where necessary) and our legitimate interests, as stipulated by Article 6(1)(a) and 6(1)(f) of the General Data Protection Regulation (GDPR). Our legitimate interests include delivering customized services, content, and advertisements that align more closely with your interests, as well as promoting our Services.
We collect your Personal Information for the purposes of investigating any policy violations, resolving disputes arising from your use of the Services, and asserting and protecting our legal rights. The lawful grounds for processing this information is grounded in our legitimate interests, as stipulated by Article 6(1)(f) of the GDPR. In this instance, our legitimate interests consist of establishing and defending our legal rights.
Corporate Transactions: Your Personal Information may be disclosed to potential buyers, successors, or investors of the Company, or in connection with any corporate transaction, such as the sale of a substantial portion of our business, a merger, reorganization, bankruptcy, consolidation, or the sale or transfer of an asset or its operations, pertaining to the Company. The lawful grounds for processing this data is our legitimate interests (Art. 6(1)(f) GDPR), in expanding and building our business.
Fraud Prevention. We retain the right to utilize your Personal Information for the purposes of detecting, preventing, and mitigating fraudulent or unlawful activities, or any other actions that might compromise or adversely impact the integrity of the Services. This includes assessing risks linked to your engagement with our Services. The lawful grounds for data processing in this instance are articulated under Article 6(1)(f) of the GDPR, pertaining to legitimate interests. Specifically, our legitimate interests include safeguarding our Company and our customers from fraudulent activities.
We process your Personal Information in adherence to applicable laws and regulatory requirements. This includes but is not limited to obligations related to anti-money laundering, identity verification, fraud prevention, and ensuring compliance with the rights of data subjects. The lawful grounds for processing this data is to ensure compliance with our statutory obligations and to protect our legitimate interests, as stipulated in Article 6(1)(f) of the GDPR.

Processing Special Categories of Personal Information Our handling of your Personal Information may include processing special categories of data, such as your racial or ethnic background. We will process and disclose such information to relevant authorities (e.g., licensing bodies or law enforcement agencies) when necessary for the purposes listed below, to the extent permitted by applicable laws: (i) detecting or preventing illegal activities, (ii) preventing dishonesty, malpractice, or other forms of serious misconduct, particularly when seeking consent could compromise these objectives.

5. Data Sharing.

Your Personal Information shall not be rented, sold, or shared with third parties ("Recipients"), except as explicitly outlined in this Privacy Policy. Disclosure of Personal Information to Recipients will occur solely to the degree necessary for the designated purpose, as specified herein.

Personal Information may be disclosed to the following Recipients:

6. Third party collection of information.

This policy solely governs the collection, use, and disclosure of information obtained directly through our services. It should be noted that when you disclose your information to third parties through our Services or on other sites across the internet, different regulations may govern the usage or disclosure of the information you provide to them. As an example, third-party payment processors such as Apple Store and Google Play Store, engaged during credit card transactions, may collect your credit card and other necessary information to process or authorize your payments. Moreover, these payment entities might also share certain details with us.

This Policy does not extend to the practices of companies not owned or controlled by us, nor to the actions of individuals not employed or managed by us, including third parties to whom we may disclose information as detailed in this Policy. Our Services may enable you to interact, directly or through links, with non-affiliated third-party websites, mobile software applications, and services (collectively referred to as "Third Party Services"). We do not oversee the privacy practices or content of any Third Party Services. Be aware that these Third Party Services may collect Personal Information from you. Thus, we advise you to review the terms, conditions, and privacy policies of each Third Party Service you choose to engage with.

By using any Third Party Services, you acknowledge and accept all risks associated with their use. We bear no liability in relation to these Third Party Services and your interactions with them.

7. Children's Privacy Protection.

We are firmly committed to protecting the privacy and safety of minors who may interact with our Services. The Services are intended only for individuals who have reached the legal age of consent ("Age of Consent"), which is the minimum age required by applicable laws in the country or region where the user resides. In most jurisdictions, this age is 18 years old.

Individuals under the Age of Consent may only use the Services with verified parental or guardian authorization. If you are under the Age of Consent, you are not permitted to create an account or provide any personal information through our Services unless explicit consent is obtained from your parent or legal guardian.


7.1 Age Restriction and Eligibility

Our Services are designed for adults aged 18 and above. Users must confirm their age eligibility during registration. We reserve the right to suspend or terminate any account if we discover that the user has misrepresented their age or does not meet the minimum age requirement.

We do not knowingly collect, store, or process personal information from minors without verifiable parental consent. If such information is discovered, it will be removed promptly in accordance with this policy.


7.2 Parental and Guardian Responsibility

Parents and legal guardians play an important role in protecting minors online. We encourage them to actively monitor and guide their child’s use of internet services, including our platform.
If a parent or guardian believes that their child has provided us with personal data without consent, they should contact us immediately at service@phi-long.com so we can take appropriate action, including removing the child's data and closing the account.


7.3 Data Collection and Deletion of Minor Information

If we become aware that we have inadvertently collected personal information from a user under the Age of Consent without verified parental permission, we will:

However, certain limited data may be retained where required by law, regulatory compliance, or for recordkeeping and fraud prevention.


7.4 Compliance with International Laws

We comply with all applicable laws and regulations regarding children's privacy and online protection, including but not limited to:

Our policies and internal procedures are periodically reviewed to ensure continued compliance with global child protection standards.


7.5 Reporting and Contact

If you have concerns or believe that we may have unintentionally collected or processed information from a minor in violation of this policy, please contact us immediately at service@phi-long.com. We will investigate the matter thoroughly and respond promptly.

8. Retention of Personal Information.

Subject to your registration and creation of an account through our Services, the Company retains your Personal Information while your account remains active. Beyond this period, the Company will continue to retain your Personal Information to comply with its legal obligations, including but not limited to obligations under Know-Your-Customer (KYC) and Anti-Money Laundering (AML) regulations.

Furthermore, the Company may retain your Personal Information for extended periods when such retention is deemed necessary for the pursuit of the Company's legitimate interests, including fraud prevention and efficient record management.

9. What are Your Rights?

If you are a resident in the EU or other jurisdictions that confer the following rights, you may contact us at any time via email at service@phi-long.com to:

  1. Access or delete any Personal Information concerning you;
  2. Amend or update any Personal Information concerning you (for example, if your Personal Information is erroneous, you may request its correction or deletion). Note that you can demand corrections to errors in your Personal Information, except where such information must be maintained in its original form under applicable laws and regulations;
  3. Request a limitation on the further usage of your Personal Information;
  4. Receive the Personal Information you have provided to us in a machine-readable format;
  5. Object to the processing of your Personal Information, including for marketing purposes;
  6. Withdraw your consent for processing activities where such processing is based on your consent rather than any other legal basis;
  7. Not be subjected to decisions based exclusively on automated processing, including profiling, which may have a legal or similarly significant effect on you, unless such processing is necessary for the fulfillment of a contract between you and us, or it is based on your explicit consent as stipulated herein.

Please be aware that these rights are not unconditional, and all requests are subject to applicable legal requirements including but not limited to legal and ethical reporting or document preservation obligations. We retain the right to correct, refill, or eliminate incomplete or inaccurate information at any given time in accordance with our internal policies, at our discretion.

Should you be dissatisfied with our response, you are entitled to contact the relevant data protection supervisory authority.

10. How to delete your information?

You retain full control over the information you opt to disclose to us via the App (except for data we deem mandatory for your usage). You can manage this by adjusting your settings within the App or your mobile device. Alternatively, you have the option to completely uninstall the App from your device.

At any time, you have the liberty to request the removal of your data. If you request the deletion of your account, we will endeavor, to the extent commercially feasible, to eliminate your data from our servers, barring any legal or regulatory obligations mandating the retention of certain personally identifiable information. Please be aware that deleting your personally identifiable data from our database may result in the inability to continue providing you with our services.

To initiate the deletion of your data, kindly navigate within the App to the Settings section of your profile, proceed to "Account Settings", select the "Delete Account" option, and then confirm the deletion.

Furthermore, you reserve the right to request the erasure of your data by submitting an email to the following address: service@phi-long.com

11. How we keep your information secured.

We diligently implement and uphold the security of the Services and the information of our users. To hinder unauthorized access and ensure the security and proper use of the information collected online, we have established several physical and technological safeguards. The extent of these safeguards is tailored to the sensitivity of the data we collect and store.

Despite adopting reasonable measures to protect information, it is impossible for us to guarantee complete security against unauthorized access or misuse of the Services by third parties. Consequently, we disclaim all warranties, whether express, implied, or statutory, regarding the prevention of such unauthorized access.

The data of our users is housed on the Google Cloud Platform, which incorporates robust security measures to maintain the protection of user information over time.

12. Changes to the Privacy Policy.

We reserve the right to modify this Policy at any time. It is advised that you frequently revisit this page for any updates. In the event of significant changes, we will notify you by either posting a notice on our Services or sending an email to the email address provided by you. Such significant changes will become effective fourteen (14) days after the notice is provided using any of the aforementioned methods. All other modifications to this Policy become effective on the date noted as "Last Revised." Your continued use of our Services following the Last Revised date constitutes your acceptance of and agreement to the changes.

13. How to contact us?

If you have any questions about the Services or the information that we collect about you and how we use it, please contact us via email at service@phi-long.com. We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time.

14. California Residents.

This part of the Policy addresses the specific disclosure requirements under the California Consumer Privacy Act of 2018 (Cal. Civ. 1798.100 - 1798.199) and the California Consumer Privacy Act Regulations by the Attorney General (collectively, "CCPA" ).

14.1 What Information We Process

In the preceding 12 months, we have collected, and or disclosed the following categories of Personal Information:

Category of Personal Information Collected Personal Information Collected Categories of recipients to whom Personal Information was disclosed
Identifiers Full name, email address, social media identifiers, username, birthdate, IP address, MAC, UDID Affiliated companies Advertising networks KYC Service providers
Personal Information Categories listed in the California Customer Records Statute (Cal. Civ. Code 1798.80(e)) Telephone number, debit or credit card number, passport or other government or state ID card number Affiliated companies Payment processors Other service providers
Internet or Other Electronic Network Activity Information Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. Affiliated companies Advertising networks Other service providers
Geolocation Data Geolocation Affiliated companies Advertising networks Other service providers

14.2 Sources of Personal Information

In the past 12 months, we have obtained Personal Information categorized as mentioned above from the following sources:

Sale of Personal Information

We do not engage in the "sale" of Personal Information as it is commonly understood. Nevertheless, we permit selected third-party advertising partners to gather information about users via our Services. The purpose of this data collection is to deliver ads that are more accurately targeted, assess advertising campaigns, and support analytics, as well as to detect and report on advertising fraud. For further details, kindly refer to the "Cookies and Tracking Technologies" section provided earlier.

14.3 Users Rights under the CCPA

The California Consumer Privacy Act (CCPA) grants consumers specific rights regarding their personal information. This section outlines your rights under the CCPA and provides instructions on how to exercise them.

  1. Right to Access Personal Information: You may, twice within a twelve-month period, request that we provide you with the following information regarding your personal information:
    - The categories and specific pieces of personal information we have collected about you,
    - The sources from which your personal information is collected,
    - The business or commercial purposes for collecting or selling your personal information,
    - The categories of personal information that we have disclosed for business purposes,
    - Any categories of personal information that we have sold,
    - The categories of third parties with whom your personal information has been shared,
    - The business or commercial purposes for selling your personal information, if applicable.

  2. Right to Deletion:
    You have the right to request the deletion of your personal information that we have collected and retained, unless a legal exception applies. Upon receiving and verifying your consumer request, we will delete your personal information from our records, and direct our service providers, subcontractors, and consultants to do the same, unless an exception applies.

  3. Right to Opt-Out of the Sale of Personal Information:
    Should we sell your personal information, you are entitled to request to opt-out of the sale at any time. Should you decide to opt-out, we may still share certain personal information with our partners, who then function as our service providers, to assist in business-related functions. These functions include, but are not limited to, service provision, service maintenance, security, analytics, and fraud prevention.

  4. Right to Non-Discrimination:
    You possess the right not to be discriminated against for exercising any of your CCPA rights. If you exercise any CCPA rights, we will not provide you with different pricing, products, or quality of services based solely on this exercise. However, please note that certain services may be affected if you choose to have your personal information deleted.

These rights are enforced under the regulations of the CCPA, and you are encouraged to exercise your rights by contacting us as specified in our contact section.

14.4 Exercising Your Rights

To exercise your rights, you may submit a verifiable consumer request either to our email address at service@phi-long.com.

Only the individual concerned or a duly authorized representative may submit a request pertaining to that individual's Personal Information.

Each request must fulfill the following criteria:

We are unable to process any request or disclose any Personal Information if we cannot verify the identity of the requester or their authority to make such a request, and confirm that the Personal Information pertains to them. You are not required to have an account with us to make a verifiable consumer request. The Personal Information provided in a verifiable consumer request will only be used to verify the identity and authority of the individual making the request.

14.5 Designating Agents

Under the California Consumer Privacy Act (CCPA), you may appoint an authorized agent to submit requests on your behalf, provided that:

Please forward a certified copy of this written declaration via mail using the contact information provided below when submitting any requests through your authorized agent.

Furthermore, should you grant your authorized agent full power of attorney in accordance with sections 4000 to 4465 of the Probate Code, the aforementioned processes may not be required, and we will address all requests from such an agent in compliance with the CCPA.