GuidePal Privacy Policy

GuidePal, Inc. and its affiliates (collectively, “we,” “our,” “us,” or “GuidePal”) owns and operates www.guidepal.com (the “Site”) and the GuidePal mobile application (the “App”) (the Site and the App collectively referred to as the “Service”) and we are committed to protecting your privacy and Personal Information (as defined below) about you. This Privacy Policy is intended to describe our practices regarding information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual (collectively “Personal Information.”) relating to visitors to the Site and the users of the Service (“you” or “your”), for what purposes Personal Information may be used, and with whom we may share Personal Information.

1. When You Register in the Service Or Purchase Guides

When you set up an account in the Service or order guides available in the Service, we collect the following identifiers that may, alone or in combination with other information, constitute Personal Information:

• Name;
• E-mail;
• Password;
• Paypal ID;
• Photo;
• Phone number;
• [Email preferences]; and
• Biographical information.

We do not collect payment card information in connection with product purchases. Payment card information is processed by a third-party vendor. You have no obligation to provide the Personal Information described above, but if you don’t provide such Personal Information, we will not be able to process your order or send a newsletter to you. Please note that you have the right to opt out of receiving electronic direct marketing communications, such as newsletters, from us. All electronic direct marketing communications that you may receive from us, such as e-mail messages and SMS-messages, give you an option of not receiving such communications from us in the future. If you have any additional questions about electronic direct marketing received from us, please contact us at privacy@guidepal.com. You may edit Personal Information you have provided by logging into your account and making modifications there.

2. When You Communicate With Us

When you communicate with us in and through the Service, e-mail us, or otherwise communicate with us, we collect the following identifiers that may, alone or in combination with other information, constitute Personal Information:

• Name;
• Contact information such as email address and a street address; and
• Content of communications sent to us.

You have no obligation to provide the Personal Information described above, but if you don’t provide such Personal Information, we may not be able to respond to your communications to us.

3. When You Request Information From Us

When you use the “Contact” function on the Site, we collect the following identifiers that may, alone or in combination with other information, constitute Personal Information:

• Name;
• Contact information such as e-mail address; and
• Content of communications sent to us.

You have no obligation to provide the Personal Information described above, but if you don’t provide such Personal Information, we may not be able to respond to your requests.

4. Surveys, Sweepstakes, and Promotions

You may be able to participate in surveys, sweepstakes and other promotions in the Service (collectively “Promotions”). If you choose to participate in the Promotions, we may collect the following identifiers that may, alone or in combination with other information, constitute Personal Information:

• Name; and
• Contact information such as e-mail address, postal address and phone number.

You have no obligation to provide the Personal Information described above, but if you don’t provide such Personal Information, you may not be able to participate in Promotions.

5. Internet Activity Information

Software used in the Service collects Internet or other electronic network activity information that may, alone or in combination with other information, constitute Personal Information:

• The domain from which you access the Site;
• The type of browser and operating system used in the device you use to access the Site;
• Internet Protocol (IP) address;
• The date and time you visited the Site (time stamp);
• The pages browsed on the Site;
• The website used to link to the Site from;
• Any search terms used to navigate the Service;
• Guides purchased and viewed on the Site;
• Geo-location of your mobile device;
• A browsing session ID; and
• Whether you are a first-time visitor to the Site.

For additional information about cookies used on the Site, please review Section 10 below.

Google Analytics is an element of the Site. By using cookies, Google Analytics collects and stores data such as time of visit, pages visited, time spent on each page of the Site, the Internet Protocol address, and the type of operating system used in the devices used to access the Site. By using a browser plugin available at http://www.google.com/ads/preferences/plugin/ provided by Google, you can opt out of Google Analytics.

We collect Personal Information from the following categories of sources:

• You: When you voluntarily provide Personal Information to us; and
• Software: Information automatically collected via cookies, web logs, web beacons, and other software-based analytics tools.

We use Personal Information about you for the following purposes:

• To operate and improve the Service, including through analytics to help us understand how you use the Service, so that we can present content in the best manner;
• To provide the guides to you;
• To provide customer service;
• To provide you with any information that you request from us. If you do not provide us with the information we need to respond to your request, we may not be able to provide you with the information that you request from us;
• To notify you about changes to the Service;
• To enable us to issue a notice, administrative, or corrective action to you in relation to the Service, if required;
• To send you direct marketing messages that you have consented to receive;
• To protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities;
• To comply with applicable legal requirements, industry standards, and our own policies; and
• Where permitted by law, to provide you with information about other products and services we offer that are similar to those that you have already subscribed to or enquired about and we feel may interest you.

We may disclose the following categories of Personal Information with the following categories of third parties for business purposes:

1. Introduction

California Civil Code Section 1798.83 permits the users of the Service who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us at privacy@guidepal.com.

If you are a California resident you may also have the right:

• To request disclosure of the categories and specific pieces of Personal Information collected about you;
• To request the disclosure of the business purpose for collecting or selling Personal Information; the categories of third parties with whom it is shared, and the categories of sources from which Personal Information is collected;
• To request the deletion of Personal Information, subject to the limitations set forth in California Civil Code Section 1798.105(d); and
• Not to be discriminated against for exercising the rights guaranteed by California Civil Code Section 1798.100 et seq.

For a list of categories of Personal Information collected and the purposes for the processing of that Personal Information, please refer to Sections II and IV above.

2. Requests to Know

You have the right to request that we disclose:

• The categories of Personal Information we collect;
• The categories of Personal Information we have sold or disclosed for a business purpose;
• The categories of sources from which we collect Personal Information about you;
• Our business or commercial purpose for selling or collecting Personal Information;
• The categories of Personal Information sold or shared about you, as well as the categories of third parties to whom the Personal Information was sold, by category of Personal Information for each party to whom information was sold;
• The specific pieces of Personal Information collected about you.

Delivery may take place electronically or by mail. We are not required to respond to requests relating to Personal Information more than twice in a 12-month period.

3. Requests to Delete

With certain exceptions, you have the right to request that we delete any Personal Information we have collected about you. Upon receiving a verified request to delete Personal Information about you, we will do so unless otherwise authorized by law.

4. Verifiable Requests

We will acknowledge the receipt of requests to know or requests to delete Personal Information free of charge, within ten (10) business days. In order to protect your privacy and the security of Personal Information, we may verify your request by asking you to provide additional Personal Information for us to verify your identity. We will respond to your request within 45 calendar days of receipt, provided that we have been able to successfully verify your identity.

You may submit a request to know or a request to delete Personal Information via privacy@guidepal.com.

5. Sale of Personal Information

In the last 12 months, we have not sold Personal Information collected in and through the Service. Consequently, we do not have an opt-out functionality on the Site.

6. The Right to Non-Discrimination

You have a right not to receive discriminatory treatment for the exercise of your California privacy rights.

7. Authorized Agents

You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney pursuant to Probate Code sections 4000-4465 may submit a request on your behalf.

We will only retain Personal Information about you for as long as necessary to fulfill the purposes Personal Information was collected for, including the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Personal Information, the purposes for which we process Personal Information and whether we can achieve those purposes through other means, and applicable legal requirements. As a general rule, we retain Personal Information for a period of three (3) years following your latest interaction with the Service.

The Service may contain links to other websites of interest. However, once you have used these links to leave the Service, we do not have any control over third party websites. We cannot be responsible for the protection and privacy of any Personal Information which you provide whilst visiting such sites and such sites are not governed by this Privacy Policy. You should exercise caution and review the privacy policy applicable to the website in question.

The Site and the Services are not intended for children under the age of 16. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 16 years of age. We do not intentionally collect, sell, or process the Personal Information of individuals under 16 years of age.

Some of the features on the Site require the use of "cookies" - small text files that are stored on your device's hard drive. We use cookies to measure which pages are being accessed, and which features are most frequently used. This enables us to continuously improve the Site to meet the needs of our visitors.

The following sets out how we may use different categories of cookies and your options for managing cookie settings:

1. Legal Basis For Processing Personal Information

The legal bases for our processing of Personal Information about you are as follows:

• Contract: When you set up an account in the Service or purchase a guide from us, we collect Personal Information about that is necessary for completing that transaction and delivering the guide(s) to you;
• Consent: We obtain your consent to collect Personal Information for distinct purposes such as receiving marketing communications from us. You have the right to withdraw your consent at any time.
• Legitimate Interest: We have a legitimate interest to collect Personal Information about you for certain purposes such as data analytics and the protection and administration of the Service so that we can (i) understand our customers’ preferences and improve the product selection available in and through the Service; (ii) to protect the Service from information security threats and our company in connection with legal claims and proceedings; (iii) to communicate administrative changes in connection with the use of the Service; and (iv) to comply with laws that apply to us and the Service.
2. Transfers of Personal Information

GuidePal is based in the United States of America. If you are located in the European Economic Area ("EEA") or Switzerland, this means that we may transfer Personal Data outside of the EEA. Such transfers are made using adequate safeguards, such as the EU Standard Contractual Clauses for Controller-to-Controller Transfers.

3. Your Rights

You have the following rights with respect to the Personal Information we hold about you:

• The right to know what Personal Information we hold about you;
• The right to have incomplete, incorrect, outdated, or unnecessary Personal Information corrected, deleted, or updated;
• The right to request that we restrict the processing of Personal Information we hold about you in certain circumstances;
• The right to object to the processing of Personal Information we hold about you; and/or
• The right to receive any Personal Information we hold about you in a structured and commonly used machine-readable format or have such Personal Information transmitted to another company.

In connection with exercising your rights described above, we may request additional Personal Information for purposes of verifying your identity and for no other purpose.

Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Information about you. We encourage you to first reach out to us at privacy@guidepal.com so we have an opportunity to address your concerns directly before you do so.

To exercise any of the rights described above, please contact privacy@guidepal.com. We seek to promptly respond to your inquiry.

We take reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. Despite these efforts to store Personal Information collected on and through the Site and otherwise by us in a secure operating environment that is not available to the public, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Information, we cannot guarantee that our security measures will prevent third-parties such as so-called hackers from illegally obtaining access to Personal Information. We do not warrant or represent that Personal Information about you will be protected against, loss, misuse, or alteration by third parties.

This Privacy Policy may change from time to time, effective from the date mentioned in the updated version of the Privacy Policy. You can tell when this Privacy Policy was last updated by reviewing the Last Updated legend at the top of this page. Please check the Site periodically to review such changes in the Privacy Policy.

California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn’t an industry or legal standard for recognizing or honoring DNT signals, we don’t respond to them at this time.

If you have any questions or concerns about this Privacy Policy or about our privacy or data security practices, please contact us via the following:

privacy@guidepal.com.