Privacy Policy


Tushly (“Tushly,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the personal information of individuals who access or use Tushly.com (the “Site”), including members, visitors, broadcasters, models, content providers, and other users.

This Privacy Policy explains what information we collect, how we use and disclose that information, the choices available to you, and the measures we take to protect your information.

By accessing or using Tushly, you acknowledge the practices described in this Privacy Policy.

1. Age Restriction

Tushly is an adult-oriented service intended exclusively for individuals who are at least eighteen (18) years of age or the age of majority in their jurisdiction, whichever is higher.

Individuals under the applicable legal age are prohibited from accessing, registering for, or using Tushly.

We may use age-verification measures and third-party verification providers to confirm that users meet applicable age requirements.

2. Information We Collect

Depending on how you interact with Tushly, we may collect the following categories of information:

Account Information: This may include your name, username, email address, password or encrypted authentication information, account preferences, and other information submitted when creating or maintaining an account.

Age and Identity Verification Information: Where required, we or our verification providers may collect information necessary to verify your age or identity. This may include your legal name, date of birth, address, and information from a government-issued identification document.

Broadcasters, models, and content providers may be required to provide additional identity and age-verification documentation in accordance with applicable law and Tushly's compliance requirements.

Transaction and Payment Information: When you purchase tokens, memberships, paid content, private shows, or other services, payment information may be collected and processed by our third-party payment processors.

Tushly may receive transaction-related information such as transaction identifiers, purchase amounts, dates, payment status, and limited payment information. Complete payment-card information may be handled directly by our payment processor rather than stored by Tushly.

Broadcaster and Content Provider Information: We may collect information necessary to administer broadcaster accounts, including profile information, verification documentation, payout information, content, account activity, earnings information, and compliance records.

Content and Communications: We may collect information you voluntarily provide through profiles, customer-support requests, complaints, messages, uploaded content, reports, and other communications made through the Site.

Technical and Usage Information: When you access Tushly, we may automatically collect certain information, including your:

  • IP address;
  • browser type;
  • device type;
  • operating system;
  • referring pages;
  • pages viewed;
  • access dates and times;
  • session information;
  • approximate location derived from your IP address; and
  • interactions with Site features.

3. How We Use Information

We may use personal information to:

  • create, authenticate, and maintain user accounts;
  • provide and operate Tushly's services;
  • process purchases, transactions, payouts, and account activity;
  • verify users' ages and identities;
  • review and administer broadcaster and model accounts;
  • provide live streaming, private shows, tipping, fan clubs, and other platform functionality;
  • communicate with users about their accounts or transactions;
  • respond to customer-service requests and complaints;
  • detect, investigate, and prevent fraud, abuse, unauthorized access, and other prohibited activity;
  • moderate content and enforce our Terms of Service and other policies;
  • comply with legal, regulatory, recordkeeping, payment-processing, and compliance obligations;
  • protect the safety, security, rights, and property of Tushly, its users, and others;
  • analyze Site performance and improve our services;
  • troubleshoot technical problems;
  • maintain records required for business, legal, and compliance purposes; and
  • send marketing or promotional communications where permitted by law and subject to applicable consent requirements.

4. Age and Identity Verification

Because Tushly provides access to age-restricted services and content, age and identity verification are important parts of our compliance procedures.

We may provide information submitted for verification purposes to third-party age or identity verification providers. These providers may compare the information supplied by a user against available records or request additional documentation when necessary to complete verification.

Information collected for verification purposes will be handled in accordance with applicable law, this Privacy Policy, and, where applicable, the privacy policies of the third-party verification provider.

5. Payment Processing

Tushly uses third-party payment processors to facilitate certain purchases and financial transactions.

When you make a payment, information necessary to complete the transaction may be provided directly to the applicable payment processor. The payment processor's collection and handling of your information may also be governed by its own privacy policy and terms.

We may retain transaction records and other information necessary for accounting, fraud prevention, customer support, chargeback management, and legal or regulatory compliance.

6. Cookies and Similar Technologies

Tushly uses cookies and similar technologies to operate the Site and improve users' experiences.

These technologies may be used to:

  • maintain login sessions;
  • remember account or Site preferences;
  • provide security functionality;
  • understand how visitors use the Site;
  • measure Site performance;
  • prevent fraudulent or abusive activity; and
  • support analytics or promotional activities.

Where required by applicable law, we will request consent before using non-essential cookies.

Users may also control certain cookies through their browser settings. Disabling cookies may prevent some portions of Tushly from functioning correctly.

7. How We Share Information

We do not sell personal information merely because you create or maintain a Tushly account.

We may disclose information to third parties when reasonably necessary to operate our services, including:

Service Providers: We may work with hosting providers, payment processors, age and identity verification providers, security providers, analytics providers, email providers, technical service providers, and other companies that perform services on our behalf.

Payment and Financial Partners: Information necessary to process transactions, payouts, refunds, disputes, or chargebacks may be shared with payment processors and financial institutions.

Legal and Compliance Purposes: We may disclose information when we reasonably believe disclosure is required by law, regulation, subpoena, court order, legal process, or a lawful request from governmental or law-enforcement authorities.

We may also disclose information where reasonably necessary to investigate suspected fraud, exploitation, human trafficking, child sexual abuse material, non-consensual content, or other illegal activity and to make reports to appropriate authorities when required.

Protection of Tushly and Others: We may disclose information when necessary to enforce our agreements, investigate violations, protect the security of our services, or protect the rights, property, and safety of Tushly, our users, or others.

Business Transactions: If Tushly is involved in a merger, acquisition, financing, restructuring, bankruptcy, sale of assets, or similar corporate transaction, information may be transferred as part of that transaction subject to applicable law.

8. Public Information and Broadcaster Profiles

Certain information intentionally submitted to public areas of Tushly may be visible to other users or the public.

For example, broadcaster profile information, usernames, profile photographs, biographies, public streams, and other information designated for public display may be accessible to Site visitors.

Users should not submit information to publicly accessible areas that they do not want others to see.

9. Data Security

Tushly uses reasonable administrative, technical, and organizational safeguards designed to protect personal information from unauthorized access, disclosure, alteration, destruction, or misuse.

However, no website, network, transmission method, or electronic storage system can be guaranteed to be completely secure. Accordingly, we cannot guarantee the absolute security of information transmitted to or stored by Tushly.

Users are responsible for maintaining the confidentiality of their account credentials and should notify us promptly if they believe their account has been accessed without authorization.

10. Data Retention

We retain personal information for as long as reasonably necessary to provide our services, maintain accounts, process transactions, resolve disputes, enforce agreements, prevent fraud, and satisfy our legal, regulatory, tax, accounting, payment-processing, and compliance obligations.

Certain information may be retained after an account has been closed when required or permitted by law or where necessary for legitimate business or compliance purposes.

Records relating to broadcaster identity verification, content compliance, transactions, complaints, and other legally regulated activities may be subject to specific retention requirements.

11. Your Privacy Choices and Rights

Depending on where you reside and applicable law, you may have rights concerning your personal information, which may include the right to:

  • request access to certain personal information we maintain about you;
  • request correction of inaccurate personal information;
  • request deletion of certain personal information;
  • obtain information regarding how your personal information is processed;
  • withdraw consent where processing is based on consent; or
  • opt out of certain marketing communications.

These rights are subject to applicable exceptions and legal requirements. For example, we may be unable to delete information that we are legally required to retain.

We may take reasonable steps to verify your identity before processing a privacy request.

12. Marketing Communications

Where permitted by law, Tushly may send users promotional or marketing communications.

You may unsubscribe from promotional email communications by using the unsubscribe instructions contained in the applicable communication or by contacting us.

Even if you opt out of promotional communications, we may continue sending non-promotional messages relating to your account, transactions, security, legal notices, or other service-related matters.

13. Third-Party Websites and Services

Tushly may contain links to websites or services operated by third parties.

We do not control the privacy practices of third-party websites and are not responsible for their privacy practices. Users should review the applicable privacy policies before providing personal information to third-party services.

14. International Users

Tushly may be accessible from jurisdictions outside the United States.

If you access the Site from another jurisdiction, your information may be processed or stored in the United States or other jurisdictions where Tushly or its service providers operate.

Privacy and data-protection laws in those jurisdictions may differ from those in your country of residence.

15. Children's Privacy

Tushly is strictly prohibited for minors.

We do not knowingly permit individuals under eighteen (18), or under the applicable age of majority where higher, to maintain accounts or use Tushly's adult services.

If we become aware that a minor has provided personal information to Tushly or accessed services in violation of our policies, we will take appropriate action consistent with applicable law and our legal obligations.

16. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes to our services, business practices, technology, or legal and regulatory requirements.

When we make changes, we will update the "Last Updated" date at the top of this Policy. Material changes may also be communicated through the Site or by other appropriate means.

We encourage users to periodically review this Privacy Policy.

17. Contact Us

If you have questions about this Privacy Policy, our privacy practices, or would like to submit a privacy-related request, please contact Tushly through our Contact Us page.