Privacy Policy

This Privacy Policy explains how Tuncan Technology & Consulting DOO (Podgorica, Montenegro), operating under the UGY and Viaworks brands (“we”, “us”), collects, uses, and protects information in connection with the UGY mobile application and the ugy.app website (together, the “Service”). UGY is a free event-discovery app that helps people find local events across Montenegro.

We are the data controller for the personal data described here. We process personal data in accordance with the Montenegro Law on Personal Data Protection and, for users in the European Economic Area, the EU General Data Protection Regulation (GDPR). Where the two differ, we apply the stronger protection to everyone.

1. Who we are & how to contact us

Controller: Tuncan Technology & Consulting DOO, Podgorica, Montenegro.
Privacy contact: [email protected] · General support: [email protected]

2. Information we collect

2.1 Account & profile information

• Your email address and, optionally, a display name (used to create and secure your account via Firebase Authentication).
• Your app language (Turkish, English, or German) and the event interests and city you choose, so we can personalise your feed.
• Your onboarding progress and app preferences.
• Your optional profile photo, username (public @handle), and a short bio, if you choose to add them. Profile photos are stored in Firebase Cloud Storage.

2.2 Feedback you send us

If you send feedback from within the app, we store the message text together with your user identifier so we can understand and follow up on it.

2.3 Device permissions you grant

• Location (optional): if you allow it, we use your device location to show events near you. Your precise GPS location is processed transiently to find nearby events and is not stored on our servers; we only store the city you select.
• Calendar (optional): if you allow it, you can add an event to your device calendar. This happens on your device; we do not read your calendar.
• Notifications (optional): if you allow it, we store a push notification token to send you event notifications you opt into.

2.4 Consent records

When you accept our terms, privacy policy, or analytics, we keep an audit record (the type and version of what you accepted, the date, and the IP address at the time) so we can demonstrate compliance.

2.5 RSVPs & activity

The events you RSVP to (“interested” or “going”) within the app.

2.6 Public event content (event sources)

UGY aggregates events that venues, promoters, festivals, and ticketing or listing platforms announce publicly on their own public websites — for example official venue and festival sites, tourism portals, and public event-listing and ticketing platforms. From each public source we extract only event-relevant information:

• the event title, description, date and time, and venue,
• the event image, where available,
• a link back to the original public source, and
• the ticket price and purchase link, where the source publishes them.

2.7 Usage analytics & diagnostics

• Analytics (PostHog): collected only if you consent in the app (analytics are off by default). We record a small set of in-app events — for example, app opens, completing onboarding, viewing or saving an event, and performing a search — to understand how the app is used and improve it.
• Error diagnostics (Sentry): if the app crashes or errors, we collect technical diagnostic data (device and app information, and an identifier to correlate the report) to fix problems. This is disabled in development builds.
• Website analytics (Google Analytics 4, on the ugy.app website): loaded through our cookie-consent tool (CookieYes) and active only if you accept analytics cookies. Analytics storage is denied by default (Google Consent Mode) until you consent. We use it to understand how the website is used and improve it.

2.8 Website waitlist

If you join the waitlist on the ugy.app website, we collect the email address you enter and your consent choices (agreeing to these terms, and optionally opting in to occasional product-update emails). We send a confirmation email to verify your address (double opt-in) and, once confirmed, use it only to notify you when UGY launches and to send the updates you opted into. You can unsubscribe at any time. Waitlist entries are stored on Cloudflare (Cloudflare D1) and confirmation and notification emails are sent via Resend.

3. How we use information

• To provide and personalise event discovery, including showing events near you.
• To create, secure, and manage your account.
• To send notifications you have opted into.
• To aggregate publicly-posted event announcements into a single local discovery feed.
• To maintain compliance records, secure the Service, and fix bugs.
• With your consent, to measure and improve the app.
• To operate the ugy.app waitlist and let you know when UGY launches, if you sign up.

4. Legal bases for processing

• Performance of a contract: providing your account and the core Service.
• Consent: location, push notifications, analytics, website waitlist sign-up, and any marketing. You can withdraw consent at any time.
• Legitimate interests: aggregating publicly-available business event announcements to offer a local event-discovery service, and keeping the Service secure and functional. We balance these interests against your rights.
• Legal obligation: retaining consent records where required.

5. Who we share information with

We do not sell your personal data. We use trusted service providers who process data on our behalf, under contract:

We may also disclose information if required by law or to protect the rights, safety, and security of our users and the Service.

6. How long we keep information

7. Your rights

Subject to applicable law, you have the right to:

• access the personal data we hold about you;
• correct inaccurate data;
• delete your data — in the app or via our Account & Data Deletion page;
• restrict or object to certain processing;
• receive your data in a portable format;
• withdraw consent at any time; and
• lodge a complaint with a supervisory authority.

To exercise these rights, email [email protected]. In Montenegro, the supervisory authority is the Agency for Personal Data Protection and Free Access to Information (AZLP). EEA users may also contact their local data protection authority.

8. Event organizers & source removal

If you organize an event whose public information appears in UGY and you would like it removed, email [email protected]. We honour valid removal requests within 7 days, process only publicly-published event information, and link back to the original public source.

9. International data transfers

Some of our providers process data outside Montenegro (for example, in the EU or the United States). Where data is transferred internationally, we rely on appropriate safeguards such as adequacy decisions or standard contractual clauses.

10. Children

UGY is not directed to children under 16, and we do not knowingly collect personal data from children under 16. If you believe a child has provided us data, contact [email protected] and we will delete it.

11. Changes to this policy

We may update this policy from time to time. We will post the updated version here and revise the “Last updated” date above. Material changes will be communicated in the app where appropriate.

12. Contact

Tuncan Technology & Consulting DOO, Podgorica, Montenegro
[email protected] · [email protected]