TruGen Labs App Privacy Policy

Effective September 22 2026

This Privacy Policy explains how TruGen Labs Inc. ("TruGen Labs," "TGL," "we," "us," or "our") collects, uses, discloses, retains, and protects personal information when people use the official TruGen Labs application and related TGL web portals, support channels, and services that link to this Policy (collectively, the "Services").

The Services support TGL personnel, business clients, client personnel and contractors, and clients' customers or consumers. Because TGL operates technology for other businesses, TGL sometimes determines why and how personal information is used and sometimes processes information only on a client's instructions. Section 3 explains that distinction.

By using the Services, you acknowledge the practices described in this Policy. This Policy does not replace a client business's own privacy notice when that business decides how personal information is collected or used through the Services.

1 Scope

This Policy applies to personal information handled through the Services, including information submitted through the TGL app, generated through use of the app, or provided to TGL for account administration, support, security, billing, and platform operations.

This Policy does not apply to third-party websites, applications, or services that have their own privacy policies, even when they are linked to or integrated with the Services. It also does not govern a client business's independent handling of information outside the Services.

2 Information We Collect

Category	Examples	Typical source
Account and contact information	Name, business name, job title, email address, phone number, mailing address, username, authentication details, account role, and preferences.	You, your employer or client organization, or an authorized administrator.
Client business and customer records	Customer profiles, orders, service records, inventory, operational records, notes, appointments, transactions, and other records a client chooses to manage through the Services.	Business clients, their personnel, their customers, integrations, or imports authorized by the client.
Payments and financial records	Invoices, payment status, transaction amounts, subscription information, refunds, billing contacts, and limited payment-card details such as brand, expiration date, and last four digits. TGL does not receive or store complete card numbers submitted directly to Stripe.	You, a client business, and Stripe.
Device usage and log information	IP address, device type, operating system, app version, identifiers, timestamps, pages or features used, diagnostic data, crash information, security events, and approximate location inferred from IP address.	Automatically from devices, servers, and service activity.
Photos camera files and documents	Images, scans, attachments, receipts, records, and other files selected, captured, uploaded, or shared through app features.	You or an authorized user, after choosing to use the applicable feature or permission.
Messages email and communications	Messages, email content, contact details, attachments, support requests, call or communication records, and related metadata handled through enabled communication features.	Users, client organizations, communication participants, and connected systems authorized by the client.

Information You Provide About Others

If you submit personal information about another person, you represent that you are authorized to provide it and that the information may be handled as described in this Policy and any applicable client instructions. Client businesses are responsible for providing any notices and obtaining any permissions required for information they collect through the Services.

App Permissions

The app may request access to the camera, photos, files, or similar device resources only when needed for a feature you choose to use. You can deny or later change device permissions in your device settings, although doing so may prevent the related feature from working. Approximate location may be inferred from IP address for security, fraud prevention, regional configuration, and service operation. This Policy does not authorize collection of precise GPS location unless TGL separately provides notice and obtains any consent required by law.

3 TGL and Client Business Roles

TGL acts in different privacy roles depending on the context.

TGL as the business or controller. TGL determines how information is used for TGL account administration, client onboarding, billing, security, fraud prevention, platform analytics, service improvement, legal compliance, and direct support relationships.
TGL as a service provider or processor. When a client business uses the Services to manage its employees, contractors, customers, communications, transactions, or operations, the client usually determines the purposes and means of that processing. TGL handles that information on the client's documented instructions and applicable contract, subject to law.

Requests involving information controlled by a client business may be referred to that client. TGL may assist the client in responding. A client can access information associated with its own organization but does not receive access to another client's information unless authorized by TGL, the affected client, and applicable law.

Client businesses retain ownership of their business data as provided in their agreements with TGL. TGL retains ownership of the Services, software, platform technology, infrastructure, templates, modules, generalized improvements, and other intellectual property. Ownership of technology does not eliminate individual privacy rights or change the privacy role required by applicable law.

4 How We Use Information

We use personal information for the following purposes:

Provide, operate, maintain, and personalize the Services.
Create and administer accounts, permissions, organizations, and user roles.
Process payments, subscriptions, invoices, refunds, and transaction records.
Enable business workflows, customer management, document handling, communications, reporting, and other client-selected features.
Authenticate users, protect accounts, prevent fraud and abuse, investigate incidents, enforce policies, and maintain system integrity.
Provide customer service, respond to requests, deliver operational notices, and troubleshoot problems.
Monitor performance, diagnose failures, understand feature usage, and improve the reliability and usability of the Services.
Create aggregated or de-identified information that cannot reasonably be linked to an identified person and use it for analytics, benchmarking, service improvement, and lawful business purposes.
Comply with law, legal process, contractual obligations, audits, and recordkeeping requirements, and establish, exercise, or defend legal claims.
Carry out another purpose disclosed when information is collected or with appropriate authorization.

TGL will not use identifiable client-controlled information to train a general-purpose artificial intelligence model unless the applicable client agreement, notice, and any required permission expressly allow that use.

5 How We Disclose Information

We may disclose personal information in the following circumstances:

Client organizations and authorized users. Information may be available to the client organization that controls the relevant workspace and to its authorized administrators, personnel, contractors, or customers according to assigned permissions.
Service providers. Vendors may process information for hosting, storage, communications, technical support, security, fraud prevention, document handling, and similar operational purposes under contractual restrictions.
Stripe. Stripe processes payment-card and payment information for transactions. Stripe handles information under its own privacy policy and payment-services terms. TGL generally receives transaction status and limited card details rather than full payment-card numbers.
Legal and safety reasons. We may disclose information when reasonably necessary to comply with law or legal process, protect rights or safety, investigate fraud or security incidents, enforce agreements, or respond to lawful requests.
Corporate transactions. Information may be transferred as part of a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar transaction, subject to applicable law and appropriate confidentiality protections.
With direction or consent. We may disclose information when a user or client directs us to do so, enables an integration, or otherwise gives authorization.

TGL does not sell personal information for money and does not share personal information for cross-context behavioral advertising. If this practice changes, TGL will update this Policy and provide any notice and opt-out mechanism required by law before the change applies.

6 Payment Processing

Payments are processed by Stripe. When payment information is entered into a Stripe-hosted or Stripe-enabled payment interface, Stripe receives that information directly. TGL may receive billing contact information, transaction identifiers, payment status, subscription details, card brand, expiration date, and the last four digits of a payment card. Stripe's privacy practices are governed by Stripe's own notices. Users should not place complete payment-card numbers or security codes in ordinary messages, support requests, or document fields not designed for payment entry.

7 Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, including to provide the Services, maintain business and transaction records, comply with legal and contractual obligations, resolve disputes, enforce agreements, prevent fraud, maintain security, and support backups and disaster recovery.

Retention periods vary based on the type of information, the client's instructions, the status of the account or contract, legal requirements, and operational needs. When information is no longer required, we delete, de-identify, or securely isolate it. Deletion from active systems may not immediately remove information from encrypted backups; backup copies are protected and deleted or overwritten according to the applicable backup cycle. We may retain records that law requires us to keep, including certain payment, tax, audit, fraud-prevention, and legal records.

8 Security

TGL uses administrative, technical, and physical safeguards designed to protect personal information. Measures may include access controls, role-based permissions, authentication, monitoring, encryption where appropriate, system and security logging, backups, incident-response procedures, and integrity checks. Access is limited according to business need and assigned authority.

No storage or transmission method is completely secure. TGL cannot guarantee absolute security. Users are responsible for protecting passwords, devices, access credentials, and account recovery methods and for promptly reporting suspected unauthorized activity.

9 Your Choices and Privacy Rights

Account Information and Communications

Users may review or update certain account information through the app or by contacting TGL. Operational and security messages are part of the Services and generally cannot be disabled while an account remains active. Where marketing messages are offered, recipients may opt out using the instructions in the message, but may still receive non-marketing communications.

Account and Data Deletion

A user may initiate account deletion through the Delete Account option in the app's account settings. A user may also submit a deletion request by emailing info@trugenlabs.com with the subject line "Account Deletion Request." TGL may verify identity and authority before acting. Deleting an account may not delete records that belong to or are controlled by a client organization, and TGL may retain information when required by law or reasonably necessary for security, fraud prevention, dispute resolution, or enforcement. Where a client controls the information, TGL may refer the request to that client.

Applicable Privacy Rights

Depending on where a person lives and subject to legal exceptions, that person may have rights to request access to personal information, correction of inaccurate information, deletion, portability, restriction or objection to certain processing, withdrawal of consent, and information about categories of personal information collected and disclosed. Some jurisdictions also provide rights to opt out of certain sales, sharing, targeted advertising, or profiling. TGL does not sell personal information or share it for cross-context behavioral advertising as stated above.

To exercise a privacy right, email info@trugenlabs.com, call (725) 347-2321, or write to the address in Section 15. Describe the request and the account or client organization involved. TGL may ask for information reasonably necessary to verify identity, authority, and the scope of the request. An authorized agent may submit a request where permitted by law, but TGL may require proof of authorization and direct identity verification. TGL will not unlawfully discriminate against a person for exercising an applicable privacy right. If an applicable law provides a right to appeal TGL's decision, the response will explain how to appeal.

California Notice

The categories of personal information TGL may collect are described in Section 2. The business or commercial purposes for collecting and using that information are described in Section 4. The categories of recipients are described in Section 5. TGL does not sell personal information or share it for cross-context behavioral advertising. California residents may submit applicable requests to know, access, correct, delete, or obtain information about collection and disclosure using the contact methods above. These rights apply only to the extent provided by California law, and legal exemptions may apply, including for certain business-to-business, employment, regulated, or client-controlled information.

10 Cookies and Similar Technologies

TGL web portals and app-connected services may use cookies, local storage, software development kits, tokens, and similar technologies to maintain sessions, remember settings, authenticate users, prevent fraud, measure performance, diagnose errors, and understand use of the Services. Device or browser controls may limit some technologies, but doing so may impair functionality. TGL does not respond to browser Do Not Track signals because there is not a uniform industry standard for those signals. Where legally required, TGL will honor applicable opt-out preference signals for covered activities.

11 Children's Privacy

The Services are designed for business operations and are not directed to children under 13. TGL does not knowingly collect personal information directly from a child under 13 without legally sufficient authorization. A client business may use the Services to maintain customer records that include information about minors; in that circumstance, the client is responsible for determining the lawful basis, providing required notices, obtaining required parental or guardian permission, and configuring access appropriately. If you believe TGL received a child's personal information in violation of law, contact info@trugenlabs.com.

12 International Processing

TGL is based in the United States. Personal information may be processed in the United States or other locations where TGL or its service providers operate. Those locations may have privacy laws different from the laws where a user lives. Where required, TGL uses appropriate contractual or legal safeguards for cross-border transfers.

13 Third Party Services and Integrations

The Services may allow a client or user to connect third-party services or follow links to third-party sites. The third party's privacy policy governs information it receives directly. Enabling an integration may allow information to flow between TGL and that provider as directed by the user or client. TGL is not responsible for a third party's independent privacy practices. At launch, Stripe is the external payment processor identified by TGL; this Policy should be updated before additional external providers begin receiving personal information through the app.

14 Changes to This Policy

TGL may update this Policy as the Services, data practices, or legal requirements change. TGL will post the updated Policy and revise the effective date. If a change is material, TGL will provide additional notice when required, such as through the app, by email, or through the applicable client administrator. Continued use after an updated Policy takes effect is subject to applicable law.

15 Contact TruGen Labs

Questions, privacy requests, complaints, and account-deletion requests may be directed to:

TruGen Labs Inc.

Attn: Privacy

730 MacCabe Avenue

Las Vegas, Nevada 89123

Email: info@trugenlabs.com

Phone: (725) 347-2321

Website: https://trugenlabs.com

If your request concerns records maintained for a particular client business, identify that business so TGL can route and process the request correctly.