Rugela Privacy Notice
Effective date: October 1, 2026
Thank you for entrusting Three Tablets, LLC ("Three Tablets", "we", "us" or "our") with your personal data. This Privacy Notice explains our practices regarding the collection, use, and disclosure of your data, including any personal data we collect and process in connection with providing the Rugela service (the "Service").
All capitalized terms have their definition in the Rugela Terms of Service, unless otherwise noted here.
Who is responsible for the processing of your information?
The data controller of your personal data is Three Tablets, LLC.
Rugela Is a Public Platform
Much of the information on the Service is public and accessible to everyone, even without an account. By using the Service, you are directing us to share this information publicly and freely.
When you submit content (e.g., a post, comment, or chat message) to a public part of the Service, or make a public vote, reaction, or other gesture, any visitors to and users of the Service will be able to see that content or activity, the username associated with it, and the date and time you originally submitted it. Public content and information may be accessed by third-party sites and services, meaning it may be available in search results on internet search engines like Google or resurfaced by third-party services, including AI services. You should take the public nature of the Service into consideration before posting.
Your Rugela account has a profile page that is public. Your profile contains information about your activities on the Service, such as your username, prior posts and comments, public votes, reactions, and other gestures, profile display name, about section, and social links, avatar or profile image, moderator status, communities you are active in, and how long you have been a member of the Service.
We offer social sharing features that let you share content or actions you take on our Services with other media. Your use of these features enables the sharing of certain information with your friends or the public, depending on the settings you establish with the third party that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the third parties that provide these social sharing features (e.g., Tumblr, Facebook, and X).
Rugela allows moderators to access Rugela content using moderator bots and tools. Rugela also allows other third parties to access public Rugela content using our developer services, including embeds, APIs, and similar technologies.
Sensitive Information and Religious Affiliation
Rugela is a forum service built by and for the Jewish community. Because of the nature of the Service, creating an account, joining or participating in communities, posting or commenting, or otherwise using the Service may indicate — or may be understood by others to indicate — your Jewish religious affiliation, your religious beliefs and practices, or your interest in Judaism and Jewish life. Information revealing religious or philosophical beliefs is treated as "special category" or sensitive personal data under some data protection laws, including the EU and UK GDPR.
We want you to understand and control this before and while you use the Service:
- You are never required to disclose your religion or beliefs. You can browse public parts of the Service without an account, use a username unrelated to your real name, and leave optional profile fields blank.
- Public participation is public. When you post or comment in public parts of the Service, make a public vote, reaction, or other gesture, join public communities, or fill in public profile fields, you make that information — including anything it reveals about your religious affiliation or beliefs — public by your own deliberate action, and it may be viewed, indexed, and shared as described in "Rugela Is a Public Platform" above.
- How we lawfully process this data. Where our processing of your data reveals or may reveal religious or other special category information, we process it only (i) with your explicit consent, which we ask for when you create an account and which you may withdraw at any time; (ii) where you have manifestly made the information public through your own use of the Service; or (iii) where otherwise permitted by applicable law (for example, to establish, exercise, or defend legal claims). See "Additional Information for EEA and UK Users" below.
- What we will not do with it. We do not use information revealing your religious affiliation or beliefs for advertising, we do not sell it, and we do not disclose it except as described in this Privacy Notice.
- Withdrawing consent. You may withdraw your consent at any time by contacting us at privacy@rugela.com. Withdrawal does not affect the lawfulness of processing before withdrawal. Because processing data that may reveal religious affiliation is inherent in operating a community service of this kind, withdrawing this consent may require closing your account.
Content you submit (including private messages) may also contain other sensitive information about you or others, such as information about health or political opinions. We process such content only to provide the Service and as described in this section, and we encourage you to be thoughtful about the sensitive information you include in content, particularly public content.
What Information We Process
The personal data we process depends on how you interact with us, the services you use, and the choices you make. We collect information about you from different sources and in various ways when you use our Service, including information you provide directly, information collected automatically, third-party data sources, and data we infer or generate from other data.
Information users provide directly to us
We collect personal data you provide to us directly when you use the service. This includes:
Account information
You don't need an account to access Rugela. If you create a Rugela account, your account will have a username, which you provide or which is automatically generated. Your username is public, and it doesn't have to be related to your real name. You may need to provide a password, depending on whether you register using an email address or via Single Sign-On (SSO) from an account on another service. If your account does not have a password, we may send you a SMS message for verification purposes. We may also ask you to select interests during account creation to help generate a home feed for you, or to select communities to join.
You may also provide other profile information, such as a bio, gender, age, location, profile picture, or social link. This information is optional and you may remove it at any time.
We also store your user account preferences and settings.
Registration may require an invitation from an existing member. Where it does, we record which member issued the invitation and which account accepted it, and we keep that record after the invitation is used. The member who sent the invitation can see the username of the account that accepted it and the date it was accepted, and the account that accepted it is told who invited them. This record is not otherwise public.
Your Non-Public Content
In addition to the public content you submit to the Service, we also collect non-public content. This includes your saved drafts of posts or comments, your messages with other users (such as private messages), and your reports and other communications with moderators and with us. Your content may include text, links, images, gifs, audio, videos, software, and tools.
Your Actions
We collect information about the actions you take when using the Service. This includes your interactions with the platform and content, like voting, saving, hiding, and reporting. It also includes your interactions with other users, such as following, and blocking. We collect your interactions with communities, like your subscriptions or moderator status.
Transactional Information
If you purchase an invite from us, you will have to provide payment information in order to complete your purchase. We use industry-standard payment processor services (such as Stripe) to handle payment information, and those services are subject to separate terms and conditions and privacy policies. We will collect information about the product or service you are purchasing (for example, purchase dates, and amounts paid or received).
Other
You may choose to provide other information directly to us. For example, we may collect information when you fill out a form, survey, participate in Rugela-sponsored activities, promotions, or programs, apply for a job, request customer support, or otherwise communicate with us.
Information we automatically collect
When you visit or use our Service, we collect some information automatically. This includes:
Usage information and Interactions
If you're accessing or using our Service, we may automatically collect information about how you use and how your device interacts with the Service, such as the pages you view, the referring site, your IP address and information about your device, session information, the date and time of each request, device type and ID, operating system and application version, and telemetry data (i.e., information about how a specific feature or service is performing) regarding your use of other features and functionality of the Service. As further described below, we automatically collect usage information and interaction data using cookies (which may use a cookie ID), depending on your settings or preferences, in connection with our Service. We also collect data about your activity on the Service, including links that you click, comments, and likes.
Geolocation information
In connection with certain features and depending on the functionality of the Service, we collect geolocation information such as through browser-based location sharing, IP addresses, or the location information you choose to provide in your Account profile.
Information collected from cookies and similar technologies
We may receive information from cookies, which are pieces of data your browser stores and sends back to us when making requests, and similar technologies. We use this information to deliver and maintain our Service, improve your experience, understand user activity, personalize content, and improve the quality of our Services. For example, we store and retrieve information about your preferred language and other settings. See Our use of cookies and tracking technologies below for more information about how we use cookies. For more information on how you can disable cookies, please see "Your Choices" below.
Information we collect from third parties
We may receive information about you from other sources, including from other users and third parties, and combine that information with the other information we have about you. This includes:
Linked services
If you authorize or link a third-party service, such as an unofficial mobile app client, to access your Rugela account, we receive information about your use of that service when it uses that authorization. Linking services may also cause the other service to send us information about your account with that service. For example, if you sign in to Rugela with a third-party identity provider, that provider may share an email address with us. To learn how information is shared with linked services, see "How Information About You Is Shared" below.
Information collected from integrations
We also may receive information about you, including log and usage data and cookie information, from third-party sites that integrate with our Service, including our embeds. For example, when you visit a site that uses Rugela embeds, we may receive information about the web page you visited.
Service Providers
We may also receive information from processors or service providers who process the data on our behalf, such as our payment processor who process payment and billing information in connection with our Service.
Inferences
We may infer or generate data from the other data we collect, such as inferences about your likely interests, in order to recommend content and communities and for analytics. We design our inference practices so that we do not draw inferences about your religious or other special category characteristics except as described in "Sensitive Information and Religious Affiliation" above.
How We Use Your Information
We may use your information to provide, administer, analyze, manage, and operate our Service. For example, we use your information for the following purposes:
- Provide our products and deliver our services including troubleshooting, improving, and personalizing the features on the Service.
- Business operations such as billing, accounting, improving our internal operations, securing our systems, detecting fraudulent or illegal activity, and meeting our legal obligations.
- Improve and develop our products and services including to develop new services or features, and conduct research.
- Personalization of our Service by understanding you and your preferences to enhance your experience and enjoyment using our Service.
- Provide customer support and respond to your questions.
- Deliver promotional communications with you about new services, features, offers, promotions, and other information about our Service, with your consent where required by law.
- Send you information, including confirmations, invoices, technical notices, updates, security alerts, support and administrative messages.
We may combine data we collect from different sources for these purposes and to give you a more seamless, consistent, and personalized experience.
The table below describes, for each category of personal data we process, the purposes for which we use it and, for users in the EEA and UK, the legal basis on which we rely for each purpose. The legal bases are explained further in "Additional Information for EEA and UK Users" below.
| Personal Data Category | Use / Purpose | Legal Basis (EEA/UK) | | :---- | :---- | :---- | | Account information — username, email address, phone number, password/SSO credentials, preferences and settings | Provide, administer, and operate the Service, including account creation, authentication, and login | Contract | | Account information — email address, phone number | Send administrative and transactional communications (confirmations, invoices, technical notices, updates, security alerts, support and administrative messages) and SMS verification | Contract | | Account information — email address | Deliver promotional communications about new services, features, offers, and promotions | Consent | | Account information; geolocation information | Secure our systems and detect fraudulent or illegal activity | Legitimate interests | | Account information — interests you select at account creation | Generate your home feed and recommend communities to join | Contract | | Optional profile information — bio, gender, age, location, profile picture, social links, display name, about section | Display on your public profile page and personalize your experience | Consent | | Public content — posts, comments, public chat messages, votes, reactions, and other gestures, and associated usernames and timestamps | Provide and operate the Service, including public display and distribution through embeds, APIs, and other developer services | Contract | | Public content | Improve and develop our products and services; conduct research | Legitimate interests | | Public content | Enforce our Terms of Service, rules, and policies, including moderation | Legitimate interests | | Non-public content — drafts, private messages, reports, and communications with moderators and with us | Provide the Service, including delivering messages, storing drafts, and processing reports | Contract | | Non-public content — reports and communications with moderators and with us | Promote the safety and security of the Service and enforce our rules and policies | Legitimate interests | | Your actions — votes, saves, hides, reports, follows, blocks, community subscriptions, moderator status | Carry out the actions you request | Contract | | Your actions | Improve and develop the Services | Legitimate interests | | Your actions; inferences | Personalize your feed and recommendations | Legitimate interests | | Transactional information — payment information, items purchased, purchase dates, amounts | Complete purchases and billing | Contract | | Transactional information | Accounting, tax, and record-keeping | Legal obligation | | Transactional information | Detect fraudulent or illegal activity | Legitimate interests | | Other information you provide — forms, customer support requests, other communications with us | Provide customer support and respond to your questions | Contract | | Other information you provide — surveys, Rugela-sponsored activities, promotions, and programs | Conduct research and administer promotions and programs | Consent | | Job application information | Evaluate your application | Contract (steps taken at your request prior to entering a contract) | | Usage information and interactions — pages viewed, referring site, IP address, device information, session information, telemetry | Provide, maintain, and troubleshoot the Service | Contract | | Usage information and interactions | Ensure network and information security and detect fraud | Legitimate interests | | Usage information and interactions | Improve and develop the Services; analytics; research | Legitimate interests (Consent where collected through non-essential cookies) | | Geolocation information — browser-based location sharing and location you provide in your profile | Customize your feed and recommendations | Consent | | Geolocation information — derived from IP address | Provide the Service; prevent fraud | Contract; Legitimate interests | | Cookie and similar-technology data — strictly necessary (login state, preferences and language, security and fraud identification) | Provide and secure the Service | Contract; Legitimate interests | | Cookie and similar-technology data — non-essential (analytics, personalization, developing inferences) | Understand user activity, personalize content, develop inferences, and improve the Services | Consent | | Linked services information | Interface with services you link and operate single sign-on | Contract | | Integration and embed information — log, usage, and cookie data from third-party sites that integrate with the Service | Provide, secure, and improve the Service | Legitimate interests (Consent where required for cookies and similar tracking) | | Inferences | Recommend content and communities; analytics | Legitimate interests |
How We Share Information
In addition to the content that is displayed publicly as described above, we may share information in the following ways:
- With your consent. We may share information about you with your consent or at your direction. For example, with your consent we share content with third-party sites and services like Tumblr, Facebook, and X when you direct us to through our social sharing features, and we share the information you authorize with third-party services you choose to link to your Rugela account. You may withdraw your consent at any time — for example, by disconnecting a social sharing feature or revoking a linked service's access from your account dashboard.
- With linked services. If you link your Rugela account with a third-party service, Rugela will share the information you authorize with that third-party service, on the basis of the consent you give when you link the service. You can control this sharing, and revoke your consent, as described in "Your Rights and Choices" below.
- With our service providers. We may share information with vendors, consultants, and other service providers who need access to such information to carry out work for us. Their use of personal data will be subject to appropriate confidentiality and security measures. Examples of these services providers are payment processors who process transactions on our behalf, and cloud providers who host our data and our services.
- To comply with the law. We may share information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, legal process, or governmental request, including, but not limited to, meeting national security or law enforcement requirements. To the extent the law allows it, we will attempt to provide you with prior notice before disclosing your information in response to such a request.
- In an emergency. We may share information if we believe it's necessary to prevent imminent and serious bodily harm to a person.
- To enforce our rights and promote safety and security. We may share information if we believe your actions are inconsistent with our Terms of Service, rules, or other Rugela terms and policies, or to protect the rights, property, and safety of the Services, ourselves, and others.
- With our affiliates. We may share information between and among Three Tablets and any of our parents, affiliates, subsidiaries, and other companies under common control and ownership, where they assist in providing, operating, and improving the Services.
- Aggregated or de-identified information. We may share information about you that has been aggregated or anonymized such that it cannot reasonably be used to identify you. For example, we may show the total number of times a post has been upvoted without identifying who the visitors were, or we may tell an advertiser how many people saw their ad.
The table below describes, for each of these sharing cases, the categories of personal data involved, the categories of recipients, and, for users in the EEA and UK, the legal basis on which we rely.
| Sharing Case | Data Categories Shared | Recipients | Legal Basis (EEA/UK) | | :---- | :---- | :---- | :---- | | Public display on the Service | Public content and publicly displayed activity | All visitors and users of the Service; search engines and other third-party sites and services; third parties using our developer services (embeds, APIs); moderators using moderator bots and tools | Contract | | Public display on the Service | Public profile information (username, display name, bio, avatar, social links, moderator status, communities, membership tenure) | All visitors and users of the Service; search engines and other third-party sites and services; third parties using our developer services (embeds, APIs); our service providers and partners; moderators using moderator bots and tools | Contract (Consent for optional profile fields you choose to complete) | | With your consent / at your direction | Content and actions you choose to share through social sharing features; information you authorize us to share with services you link | Third-party social platforms (e.g., Tumblr, Facebook, X); third-party services you link to your account | Consent | | With linked services | Information you authorize when you link the service | Third-party services you choose to link to your Rugela account | Consent | | With our service providers | Any of the categories described in "What Information We Process," as needed for the work the provider performs for us (for example, payment and billing information to payment processors; hosted data to cloud providers) | Vendors, consultants, and service providers acting on our behalf | Same basis as the underlying processing purpose (Contract or Legitimate interests, as described in the table above) | | To comply with the law | Any category responsive to the legal requirement or request | Courts, regulators, law enforcement, and other governmental authorities | Legal obligation | | In an emergency | Any category necessary in the circumstances to prevent imminent and serious bodily harm | Law enforcement, emergency responders, and other parties in a position to prevent the harm | Vital interests | | To enforce our rights and promote safety and security | Account information; public and non-public content; your actions; usage information | Our personnel and advisors; where appropriate, law enforcement or affected third parties | Legitimate interests | | With our affiliates | Any of the categories described in "What Information We Process," as needed to assist in providing the Services | Three Tablets parents, affiliates, subsidiaries, and companies under common control and ownership | Contract | | Aggregated or de-identified information | Aggregated or anonymized data that cannot reasonably be used to identify you | Advertisers; the public | Not applicable once anonymized (Legitimate interests for the process of aggregating and de-identifying) |
Your Rights and Choices
You have choices about how to protect and limit the collection, use, and sharing of information about you when you use the Service. Depending on where you live, you may also have the right to correction/rectification of your personal information, to opt out of certain advertising practices, or to withdraw consent for processing where you have previously provided consent. Below we explain how to exercise each of these rights. Three Tablets does not discriminate against users for exercising their rights under data protection laws.
Accessing, Correcting, and Deleting your Information
You may access, update, alter, or delete your profile information through your account dashboard.
You may also delete content you have submitted. When you delete content, it is no longer visible to other users. We may retain deleted content, and earlier versions of content you have edited, where our staff can access it, for legitimate business purposes and as described in "Retention of personal data" below.
You can control the information we collect about you by limiting what information is in your profile, by keeping your information current, or by changing your cookie preferences.
Deleting Your Account
You may request deletion of your account at any time by contacting us at support@rugela.com. When we delete your account, you can no longer access the Service, your profile is no longer visible to other users, and content and activity associated with your account are no longer attributed to you. We delete or anonymize account, profile, and activity information according to our retention practices. We may retain certain information where necessary for legitimate business purposes or as required or permitted by applicable law.
Withdrawing Consent
Where we process your information on the basis of your consent — including your explicit consent to processing that may reveal your religious affiliation — you may withdraw that consent at any time using the controls described in this section, through your account dashboard, or by contacting us at privacy@rugela.com. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.
Controlling Linked Services' Access to Your Account
You can review the services you have permitted to access your account and revoke access to individual services by visiting your account dashboard.
Controlling the Use of Cookies
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject first- and third-party cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Service. For more information on controlling how cookies and similar technologies are used on Rugela, see Our use of cookies and tracking technologies below.
Do Not Track
Most modern web browsers give you the option to send a Do Not Track signal to the sites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard for how a site should respond to this signal, and we do not take any action in response to this signal. Instead, in addition to publicly available third-party tools, we offer you the choices described in this policy to manage the collection and use of information about you.
Controlling Promotional Communications
We send promotional communications on the basis of your consent, where the law requires it. You may withdraw your consent to, or otherwise opt out of receiving, some or all categories of promotional communications from us by following the instructions in those communications or by updating your email options in your account preferences. If you opt out of promotional communications, we may still send you non-promotional communications, such as information about your account or your use of the Service.
Controlling Mobile Notifications
With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
Controlling Location Information
We use browser-based location sharing and profile location information for feed and recommendations customization only with your consent. You can control how we use location information for feed and recommendations customization, and withdraw your consent, via your account dashboard.
Communication with you
We use your email address to communicate with you about your account and to respond to your support requests. Please note that you cannot opt out of receiving important communications from us, such as emails from our support team or system emails.
We do not track whether you open our emails or whether you click links in them.
Our use of cookies and tracking technologies
Cookies and tracking technologies
Three Tablets uses cookies to provide and secure our Service. For example, we use them to (i) keep you logged in, (ii) remember your preferences, and (iii) identify your device for security and fraud purposes, including as needed to maintain the integrity of our Service. These are cookies we set, the needs we have for those cookies, and the cookies' expiration period:
| Purpose | What it does | How long it lasts* | | :---- | :---- | :---- | | Signing in | Keeps you signed in as you move between pages | Up to two weeks | | Form security | Protects form submissions from being forged by another site | Up to a year | | One-time messages | Carries confirmations such as "your post was deleted" across a page load | Cleared as soon as it is shown | | Display preferences | Remembers choices such as how you like comments sorted | Until you close your browser |
Every cookie we set is our own. We do not use advertising or analytics cookies, and we do not allow third parties to set cookies through the Service.
The length of time a cookie will stay on your browser or device depends on whether it is a "persistent" or "session" cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay until they expire or are deleted. The expiration time or retention period applicable to persistent cookies depends on the purpose of the cookie collection and tool used. Expiration times apply on a rolling basis, meaning they may be reset each time you interact with the Service. You may be able to delete cookie data using your browser's settings.
What are cookies and similar technologies?
We use cookies and similar technologies, such as web beacons, local storage, and mobile analytics, to operate and provide our Service. Cookies are small text files stored by your browser on your device. A cookie can later be read when your browser connects to a web server in the same domain that placed the cookie. The text in a cookie contains a string of numbers and letters that may uniquely identify your device and can contain other information as well. This allows the web server to recognize your browser over time, each time it connects to that web server.
Web beacons are electronic images (also called "single-pixel" or "clear GIFs") that are contained within a website or email. When your browser opens a webpage or email that contains a web beacon, it automatically connects to the web server that hosts the image (typically operated by a third party). This allows that web server to log information about your device and to set and read its own cookies. In the same way, third-party content on our websites (such as embedded videos, plug-ins, or ads) results in your browser connecting to the third-party web server that hosts that content.
How do we and our partners use cookies and similar technologies?
The Service uses cookies and similar technologies for a variety of purposes, including to store your preferences and settings, enable you to sign-in, track your interaction with the Service, develop inferences, combat fraud, and fulfill other legitimate purposes. Some of these cookies and technologies may be provided by third parties, including service providers. Cookies that are strictly necessary to provide and secure the Service do not require your consent. Where required by applicable law, we set all other (non-essential) cookies and similar technologies — such as those used for analytics, personalization, and developing inferences — only with your consent, which you can change or withdraw at any time through our cookie preferences settings.
Retention of personal data
We retain personal data for as long as necessary to provide the services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations. For example, we may retain your personal data for longer periods, where necessary, subject to applicable law, for security purposes.
How Three Tablets secures your information
Three Tablets takes reasonable measures necessary to protect your personal data from unauthorized access, alteration, or destruction; maintain data accuracy; and help ensure the appropriate use of your personal data. To help us protect personal data, we request that you never share your login information with anyone.
Cross-border data transfers
Three Tablets may store and process your personal data in your region, in the United States, and in any other country where Three Tablets or its service providers operate facilities.
We transfer personal data from the European Union, the United Kingdom, and Switzerland to other countries, some of which have not yet been determined by the European Commission to have an adequate level of data protection. For example, their laws may not guarantee you the same rights, or there may not be a privacy supervisory authority there that is capable of addressing your complaints. When we engage in such transfers, we use the Standard Contractual Clauses approved by the European Commission to help protect your rights and enable these protections to travel with your data.
Changes to our Privacy Notice
We may change this Privacy Notice from time to time for a variety of reasons, including to comply with new laws and regulations, to cover new features and functionality, and to increase transparency. We will provide notice of material changes to this Privacy Notice by publishing a notice via the Service or sending email to the primary email address associated with your Account.
Contacting Three Tablets
Questions regarding Three Tablets's Privacy Notice or information practices should be directed to privacy@rugela.com.
Additional Information for EEA and UK Users
Users in the European Economic Area ("EEA") and United Kingdom ("UK") have the right to request access to, rectification of, or erasure of their personal data; to data portability in certain circumstances; to request restriction of processing; to object to processing (including processing based on our legitimate interests); and to withdraw consent for processing where they have previously provided consent. These rights can be exercised as described in the "Your Rights and Choices" section above. EEA users also have the right to lodge a complaint with their local supervisory authority.
As required by applicable law, we collect and process information about individuals in the EEA and UK only where we have a legal basis for doing so. Our legal bases depend on the Services you use and how you use them. The tables in "How We Use Your Information" and "How We Share Information" above identify the legal basis we rely on for each category of personal data and each purpose. In summary, we process your information where:
- It is necessary to fulfill our contract with you (Article 6(1)(b) GDPR), including to provide, operate, and improve the Services, provide customer support, and protect the safety and security of the Services. This covers, for example: processing your account information to operate your account and communicate with you about it; generating your home feed from the interests you select; processing and displaying your public content; processing your non-public content; carrying out the actions you request on the Service; processing your payment information; processing information about your accounts on linked services and integrations for purposes of interfacing with those services; sharing information with service providers and with affiliates who assist in providing the Services; and evaluating job applications at your request.
- It satisfies a legitimate interest which is not overridden by your data protection interests (Article 6(1)(f) GDPR), such as preventing fraud, ensuring network and information security, enforcing our rules and policies, protecting our legal rights and interests, research and development, and personalizing the Services. This covers, for example: processing information about your actions on the Services, and your public content, for the purpose of improving the Services; personalizing your feed and recommendations based on your actions and our inferences; processing your account and geolocation data for purposes of fraud prevention; processing usage information for security and analytics; enforcing our Terms of Service and legal rights; and sharing information to protect the Services and our users.
- You have consented for us to do so for a specific purpose (Article 6(1)(a) GDPR). This covers, for example: your optional profile information; promotional communications; push notifications to your mobile device; non-essential cookies and similar technologies; browser-based location sharing and profile location used to customize your feed and recommendations; surveys and Rugela-sponsored activities, promotions, and programs; and sharing at your direction through social sharing features and with linked services you choose to enable. You may withdraw your consent at any time as described in "Your Rights and Choices."
- We need to process your information to comply with our legal obligations (Article 6(1)(c) GDPR), including responding to valid legal process requesting user information and retaining transactional records for accounting and tax purposes.
- It is necessary to protect vital interests (Article 6(1)(d) GDPR), such as sharing information in an emergency where we believe it is necessary to prevent imminent and serious bodily harm to a person.
Special category data
As explained in "Sensitive Information and Religious Affiliation," your use of the Service may reveal your religious beliefs or affiliation, and content you submit may contain other special category data. Where we process special category data, we rely on the following conditions under Article 9(2) GDPR in addition to the legal bases above:
- Explicit consent (Article 9(2)(a)): when you create an account, we ask for your explicit consent to our processing of personal data that may reveal your religious affiliation or beliefs in connection with providing the Service. You may withdraw this consent at any time as described above.
- Data manifestly made public by you (Article 9(2)(e)): where you have manifestly made special category data public through your own deliberate actions on the Service, such as posting content to public parts of the Service, joining public communities, or completing public profile fields.
- Legal claims (Article 9(2)(f)): where processing is necessary for the establishment, exercise, or defense of legal claims.
Additional Information for California Users
The California Consumer Privacy Act ("CCPA"), as amended, requires us to provide California residents with some additional information, which we address in this section.
We collect, or expect to collect, the following categories of personal information from California residents, depending on the Services used:
- Identifiers and account information, like your Rugela username, email address, phone number, IP address, and cookie information.
- Commercial information, including information about transactions you undertake with us.
- Internet or other electronic network activity information, such as information about your activity on our Service.
- Geolocation information based on your IP address and browser location information.
- Your messages with other users.
- Audiovisual information in pictures, audio, or video content submitted to the Service.
- Professional or employment-related information or demographic information, but only if you explicitly provide it to us, such as by applying for a job or filling out a survey.
- Sensitive personal information, such as information that may reveal your religious beliefs through your use of the Service, as described in "Sensitive Information and Religious Affiliation."
- Inferences we make based on other collected data, for purposes such as recommending content and analytics.
You can find more information about (a) what we collect and sources of that information in the "What Information We Process" section of this notice, (b) the business and commercial purposes for collecting that information in the "How We Use Your Information" section, and (c) the categories of third parties with whom we share that information in the "How We Share Information" section.
If you are a California resident, you have additional rights under the CCPA, including the right to opt out of any sales or sharing of your personal information, to request access to and information about our data practices, and to request deletion or correction of your personal information, as well as the right not to be discriminated against for exercising your privacy rights. Three Tablets does not "sell" or "share" personal information (including for cross-context behavioral advertising) as those terms are defined under the CCPA. We do not use or disclose sensitive personal information except to provide you the Services or as otherwise permitted by the CCPA, and we do not use or disclose sensitive personal information for purposes of inferring characteristics about you.
You may exercise your rights to access, delete, or correct your personal information as described in the "Your Rights and Choices" section of this notice. When you make a request, we will verify your identity by asking you to sign into your account or if necessary by requesting additional information from you. You may also make a rights request using an authorized agent. If you submit a rights request from an authorized agent who does not provide a valid power of attorney, we may ask the authorized agent to provide proof that you gave the agent signed permission to submit the request to exercise rights on your behalf. In the absence of a valid power of attorney, we may also require you to verify your own identity directly with us or confirm to us that you otherwise provided the authorized agent permission to submit the request. If you have any questions or concerns, you may reach us using the methods described under "Your Rights and Choices" or by emailing us at privacy@rugela.com.