Guguguru, Corp. Security & Privacy Statement

This Privacy Statement sets forth the information gathering, use, and dissemination practices of Guguguru, Corp. (“Gugu Guru”) in connection with the World Wide Web site located at www.guguguru.com (the “Site”). This Privacy Statement addresses Gugu Guru’s practices regarding information collected only directly through or from the Site – it does not address or govern any information gathering, use, or dissemination practices related to information collected other than directly through or from the Site, including, without limitation, from or via telephone, facsimile, postal mail, personal delivery, or other offline means or media.

This website is owned and operated by Guguguru, Corp., and together with its affiliate brands, are referred to in this privacy policy as “we”, “us”, “our”, other similar pronouns, “GuguGuru.com” or “Gugu Guru”.

Contact

If you have any questions or need additional information regarding Guguguru, Corp.’s Privacy Policy, please contact us via our contact form. If you wish to reach us via snail (postal) mail, please write to us at Guguguru, Corp., 154 Grand St, New York, NY 10013.

Information Collection Principles

We are committed to conducting our business in accordance with the following principles in order to ensure that the confidentiality of personal information is protected and maintained:

Before or at the time of collecting personal information, we will identify the purposes for which information is being collected.

• We will collect and use of personal information solely with the objective of fulfilling those purposes specified by us and for other compatible purposes, unless we obtain the consent of the individual concerned or as required by law.
• We will only retain personal information as long as necessary for the fulfillment of those purposes.
• We will collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.
• Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.
• We will protect personal information by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
• We will make readily available to customers information about our policies and practices relating to the management of personal information.

Use of Information Collected

The information gathered from your visit to our website(s) will help us enhance your shopping experience and services offered, as well as improve communications regarding our product/brand recommendations. Gugu Guru takes your privacy seriously. Except as expressly provided below, we will never give, sell, lease or in any way make available the information you supply us with to any organization or individual other than Guguguru, Corp.

Personal data collected by Gugu Guru may be used by Gugu Guru for many reasons, for example, for providing a personalized shopping experience; for providing customer service; for editorial and feedback purposes; to improve your experience on the site; to communicate with you about promotions, services, and contests; to maintain your account; for administration and review of the Site content; for product development; for content and service improvement; for fulfillment of a requested transaction or recordkeeping; for marketing and promotional purposes; for a statistical analysis of users’ behavior; or to customize the content and layout of the Site. Aggregate data regarding member visitors’ home servers may be used for internal purposes, and individually identifying information, such as names, postal and e-mail addresses, phone numbers, and other personal information which visitors voluntarily provide to Gugu Guru may be added to Gugu Guru’s databases and used for future calls and mailings regarding Site updates, new products and services, and upcoming events. Gugu Guru also may use member visitor data to contact the member visitors regarding account status and changes to the Web Site Terms and Conditions, Online Agreement, Privacy Statement, and any other policies or agreements relevant to member visitors. Additionally, Gugu Guru may send members electronic mail regarding administrative, or legal matters relating to the Site or services available or provided via the Site or notifying you of special offers or promotions.

We will not distribute or sell your Personal Information to any outside company for marketing or solicitation of any product or service not affiliated with Guguguru, Corp. (or our partners or providers), and your Personal Information will only be used to support your relationship with Guguguru, Corp. and its partners and providers. In each case, where we share such information with an outside company, such outside company will be under agreement with Guguguru, Corp. to protect your Personal Information in a manner at least as restrictive as we protect your Personal Information, and to use it solely as Guguguru, Corp. directs.

Gugu Guru collects and may track (1) the e-mail addresses of member visitors that communicate with Gugu Guru via e-mail, (2) information knowingly provided by the visitor in online forms, registration forms (including registration forms completed through a Partner Website (“Partner Website” is defined as a third party company that is using the Gugu Guru registry software to allow you to sign up for the Site), forms, surveys, e-mail, the “Contact Us” section of the Site, other inquiries visitors may make through the Site, and other online avenues (including, but not limited to, information such as demographic, business profile, and personal profile data), (3) the home server domain names, e-mail addresses, type of client computer, files downloaded, search engine used, operating system, and type of Web browser of member visitors to the Site, and (4) aggregate and user-specific information regarding which pages Site member visitors access. Gugu Guru web servers may seek to place a “cookie” (a small data file) on your computer’s hard drive which allows the server to identify the computer when it visits Gugu Guru again, in order to track statistical information about navigation to, and throughout, certain areas of our Site, and navigation to Gugu Guru promotions on third party Web sites. This cookie is not used to obtain your name or any personal data, and the information that is tracked is used only for internal purposes. However, if you prefer not to accept cookies, you can set your browser to reject them or to alert you before one is placed. When a member visitor performs a search within the Site, Gugu Guru may record information identifying the member visitor or linking the member visitor to the search performed. Gugu Guru may also record limited information for every member visit and search request, for example, in the form of a Web or Site log, and use that information to provide member visitors with a better experience while visiting our Site, to solve technical problems with the services available directly or indirectly in connection with the Site, and to calculate overall usage statistics.

Partners

We may use and/or share your personal information with our agents, contractors or partners in connection with services that we perform or that these individuals or entities perform for, or with, Guguguru, Corp., such as making phone solicitations, sending mailers or email messages, managing data, hosting our databases, providing data processing services or providing customer service. Any such agents, contractors or partners are restricted from using this data in any way other than to provide services for Guguguru, Corp., or services for the collaboration in which they and Guguguru, Corp. are engaged (for example, some of our product recommendations are developed and marketed through joint agreements with other industry experts).

Third Parties

GuguGuru.com will never sell, rent or share your personal information with any third parties, except to share your personal information with the Partner Website to whom you provided your information as a part of the sign-up process for the Site. For use by the company who operates the Partner Website for its own marketing and business purposes. We may disclose personal information when legally required, or in the good faith belief that such action is necessary in order to comply with the law or legal process. Identifiable and non-identifiable user information and data may be disclosed or distributed to another party with which Gugu Guru enters or reasonably may enter into a corporate transaction, such as, for example, a merger, consolidation, acquisition, or asset purchase, or if determined by Gugu Guru in its sole judgment that such disclosure or distribution is appropriate to protect the life, health, or property of Gugu Guru or any other person or entity. Personal information will never be shared for profit. Gugu Guru also may disclose information about member visitors’ Site usage and demographics to third parties on an aggregate basis. Aggregate data regarding member visitors’ home servers and individually identifying information, such as names, postal and e-mail addresses, and phone numbers, may be disclosed or distributed: to another party with which Gugu Guru enters or reasonably may enter into a corporate transaction, such as, for example, a merger, consolidation, acquisition, or asset purchase; or to a third party pursuant to a subpoena, court order, or other form of legal process; in response to a request by or on behalf of any local, state, federal, or other government agency, department, or body, whether or not pursuant to a subpoena, court order, or other form of legal process; or if determined by Gugu Guru in its sole judgment that such disclosure or distribution is appropriate to protect the life, health, or property of Gugu Guru or any other person or entity. Gugu Guru is not responsible for, and will not be liable for, the conduct, actions, omissions, or information handling or dissemination practices of any third party. This Site may contain links to other World Wide Web sites or advertisements for or placed by third parties. Gugu Guru has no control over Web sites that we provide links to, and is not responsible for the privacy practices of such Web sites, advertisers, or third parties, or for the content of such sites or advertisements. It is possible that these links or advertisements, themselves, may be used by third parties or others to collect personal or other information about Site visitors. It is solely the visitors’ obligation to review and understand the privacy practices and policies of these other Web sites and of these advertisers and third parties.

Promotions/Sweepstakes/Contests/Registries/Discount Opportunities/Newsletters/Other Marketing Activities – Such offerings may be presented to you on a periodic basis on behalf of Guguguru, Corp. If you choose to participate in such program(s) or offering(s), your information may be collected, stored and/or shared for marketing purposes. If you do not wish to participate, you will be provided with an opportunity to opt-out, unsubscribe from such communication(s), and/or notify us later via email at Reviews/Testimonials – Guguguru, Corp. welcomes your comments and feedback regarding our service(s). We appreciate your input and recognize the importance of sharing this information with others. If you send us a testimonial, we may use your first name to share your thoughts on our websites, as well as other marketing collateral both online and offline. By providing Guguguru, Corp. with your review(s) and or testimonial(s) you agree and accept that your submittal will be read and shared with others across all channels.

Sharing Options/Features – We may present you with the opportunity or opportunities to share your registry or your interest in our brand(s) and/or service(s), with family, friend(s), those person(s) of your choosing and/or those in which you share similar interests. This opportunity or opportunities will be presented to you in an opt-in or opt-out fashion or similar fashions(s). This may include referral program(s) in which you may be asked to provide the information of the person(s) in which you share your interest(s) with, in which case the information of the “person(s)” may be captured and used for future marketing efforts on behalf of Guguguru, Corp.

Legal Reasons/Compliance

Guguguru, Corp. will share personal information to respond to duly authorized subpoenas or information requests of governmental authorities, to provide internet security or where required by law. In exceptionally rare circumstances where national, state or company security is at issue, Guguguru, Corp. reserves the right to share our entire database of visitors and customers with appropriate governmental authorities.

Transfer(s) of Business

We may also provide personal information to a third party in connection with the sale, assignment, or other transfer of the business of this website to which the information relates, in which case we will require any such buyer to agree to treat personal information in accordance with this Security and Privacy statement.

Security – Guguguru, Corp. has taken many measures to protect the security of your personal information with regards to certain sensitive data, through the use of firewalls, secure payment options, etc. While we strive to maintain the protection of such data, we cannot guarantee the safety or security due to the unforeseeable nature of the Internet.

Minors – We do not knowingly collect, use or retain any Personal Information from visitors to our Websites who are under eighteen (18) years of age for any purpose whatsoever (including internal or external marketing purposes). Where appropriate, we will instruct children not to submit information to our Websites or advertisements. We will delete any records of any such Personal Information that comes to our attention. If it comes to your attention that you (should you live outside of the United States and its Territories) or your child under 18 has provided any Personal Information to our websites, we invite you to notify us via the “Contact Us” section of our Websites so that we may delete the information from our records and discontinue any related features. While our policy prohibits the collection of information from children under 18, parents should supervise their children’s online activities and consider using parental control tools available from online services and software manufacturers that help provide a kid-friendly online environment. These tools can also prevent children from disclosing online their name, address and other personal information without parental permission.

Links to Other Sites and Financial Information

The Site may also contain links to other sites or advertisements for or placed by third parties, including sites that enable you to purchase products and services, such as those of Gugu Guru’s partners. If you access a third party site from a link on this Site, any information you disclose on that site is not subject to this Privacy Statement. It is possible that these links may be used by third parties to collect personal or other information about you. Gugu Guru is not responsible for the privacy practices of such Web sites, advertisers, or third parties or the content of such sites and it is your sole obligation to review and understand the privacy practices and policies of these other web sites. Gugu Guru does not control these third parties’ use of cookies, collection of information, or how they manage such information. It is solely your obligation to review and understand the privacy practices and policies of these other Web sites, advertisers and any third parties.

Opt-Out Right

Except as necessary for Gugu Guru to provide the services, information, or products requested by a visitor, the visitor may opt out of having his or her personally identifiable information, which has been voluntarily provided to Gugu Guru through an account registration or other account activity, prospectively retained by Gugu Guru, prospectively used by Gugu Guru for secondary purposes, or prospectively disclosed by Gugu Guru to third parties by contacting Gugu Guru via postal mail or e-mail at the addresses set out above. (This does not apply to collection of the type of Web browser of the visitor to the Site or to information provided or collected that does not meet the description in this Section).

Access and Ability to Correct Personal Data

Upon a visitor’s request via the Site, postal mail or e-mail, Gugu Guru will provide to the visitor a summary of any personally identifiable information retained by Gugu Guru regarding the visitor, which information has been voluntarily provided by a visitor to Gugu Guru through an account registration, customer order, or electronic news or information subscription. A visitor may modify, correct, change or update their personally identifiable information by contacting Gugu Guru via the Site, postal mail or e-mail at the addresses or numbers above.

Changes to Privacy Policy

We may revise this online privacy policy at any time. Notice of any new or revised Privacy Statement, as well as the location of the new or revised statement, will be posted on the Site for at least 20 days after the change. It is the obligation of users returning to the Site to learn of changes to the Privacy Statement since their last visit. Any change to this Privacy Statement shall be effective as to any visitor who has visited the Site before the change was made.