(Last Updated 9/8/2023)
This Privacy Policy (this “Policy”) of Guroo, LLC (“Guroo”, “we” or “us”) explains our policies and procedures with respect to the information that we collect from you through our website (“Site”) and/or mobile applications (“Services”). Specifically, it describes the information we collect, how and for which purposes we may use such information, where we store it and for how long we retain the information, with whom we may share it, our use of tracking technologies and communications, our security practices, your choices and rights regarding such information, our policy concerning children, and how to contact us if you have any concerns regarding this Policy or your privacy.
Please read this Policy and make sure that you fully understand and agree to it. If you do not agree to this Policy, please discontinue and avoid using our Services.
We collect the following main categories of information (and to the extent one or more of them may enable the identification of a specific person or is linked to such potentially identifying data, we will deem it “Personal Information”):
Device Information. When you visit the Site, interact with or use our Services, we automatically collect certain information about your device, either independently or with the help of third-party services, including through the use of “cookies” and other tracking technologies (as further detailed below). Such data consists of sensor, location, connectivity, technical and aggregated usage data, such as your GPS/GNSS location data; home and work locations; IP addresses, wireless networks, cell towers and Wi-Fi access points; non-identifying data regarding a device, operating system, and browser; activity, communication, and performance logs; issues and bugs; and user activity on our Services. This data does not enable us to learn your true identity or contact details, and serves mostly to improve the overall performance of our Services, and to better understand how our users typically use our Services and how we could improve their user experience. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site.
We collect Device Information using the following technologies:
Use Information: We collect information about how you use our Services, including your access times, log-in and log-out information, browser types and language, Internet Protocol (“IP”) addresses, mobile device and operating system, any specific page you visit on our platform, content you view, features you use, the date and time of your visit to or use of the Services, your search terms, and date about how you interact with our Services.
Information You Provide. Additionally, when you register or attempt to register for our Services, we collect certain information from you which may include your name, billing address, shipping address, payment information (including bank account and credit card numbers), email address, and telephone number. We also require you to provide us with additional personal information to confirm verification and identification.
Financial information. We collect information such as billing address, credit card numbers, photograph, and/or other proof of identification in order to verify your identity and other publicly available information. We store credit card information, and save your credit card information to facilitate scheduled and future payment purposes for your convenience. We may also collect withholding allowances and tax filing status.
Transaction Information. When you use our Services to make or accept payments, we collect information about the transaction, as well as other information associated with the transaction such as the date of the transaction, description of the transaction, the payment amounts, and any merchant information, including information about any payment instrument used to complete the transaction, device information, and geolocation information.
We also collect information about you from third parties relating to identity and account verification process, credit investigation, fraud detection process, or collection procedures, in addition to any publicly available information. We also may receive information about you from outside records of third parties, such as marketing-related or demographic information. We may supplement the information we collect about you through the Website and the Services with such information from third parties in order to enhance our ability to serve you, to tailor our content to you and/or to offer you opportunities to purchase products or services that we believe may be of interest to you. If we combine such data with information we collect through the Website or the Services, such information is subject to this Policy unless we have disclosed otherwise.
We may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a survey.
MyAccount payment capabilities are facilitated by Guroo Solutions and Dwolla, Inc. In order to use the payment functionality of the MyAccount application, you must open a "Dwolla Account" provided by Dwolla, Inc. and you must accept the Dwolla Terms of Service and Privacy Policy.
Any funds held in or transferred through your Dwolla Account are held or transferred by Dwolla's financial institution partners. You must be at least 18 years old to create a Dwolla Account. You authorize Guroo to collect and share with Dwolla your personal information including full name, email address and financial information, and you are responsible for the accuracy and completeness of that data. You understand that you will access and manage your Dwolla Account through the MyAccount application, and that Dwolla account notifications will be sent by Guroo, not Dwolla. Guroo will also provide customer support for your Dwolla Account activity, and can be reached via our website (www.GurooSolutions.com) or via email (AskGuroo@GurooSolutions.com).
GUROO DOES NOT KNOWINGLY COLLECT PERSONAL INFORMATION FROM CHILDREN UNDER THE AGE OF 13. If you are under the age of 13, please do not submit any Personal Information through this Site. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce this Policy by instructing their children bever to provide Personal Information on this Site without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to Guroo via this site, please contact us and we will endeavor to delete that information from our databases.
Guroo and its affiliates may use your Personal Information for a number of purposes, including as necessary for the performance of our Services; for complying with applicable law; and based on our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, optimizing our marketing, customer service and support operations, and protecting and securing our users, ourselves, and members of the general public.
The personal information collected on this Site will be used to provide and improve the Services you have requested or authorized to provide for a better user experience. This includes collecting Personal Information for monitoring and analyzing trends and usage; identifying you when you sign in to your accounts and verify your identity; developing new products and services; send you information and support you request (for example, in the form of emails, mailings and the like) regarding to respond to support inquires, to share information about our products, to enhance the safety and security of our Services; services and promotional offers that we think may interest you, and for billings and collection purposes; processing or recording transactions; displaying and maintaining your historical transaction information; improving and analyzing performance of the Site and the Services; tracking and analyzing trends and usage in connection with your use or our performance of the Services; comparing information with third parties for verification purposes; preventing potentially fraudulent, prohibited or illegal activities; enforcing our Terms of Services and other usage policies; delivering information and support you request; complying with legal requirements; and for any other purposes discloses at the time the information is collected or to which you consent.
We also use Personal Information to verify and authenticate the identity of our users in order to comply with fraud monitoring, prevention and detection obligations, laws associated with the identification and reporting of illegal and illicit activity, such as AML (Anti-Money Laundering) and KYC (Know-Your-Customer) obligations, and financial reporting obligations to prevent money laundering and financial crimes. These obligations are imposed on us by the operation of law, industry standards, and by our financial partners, and may require us to report our compliance to third parties, and to submit to third party verification audits.
We also may use Personal Information for research purposes, and we may provide such information in the aggregated form as well as unaggregated form to third parties. For example, we might inform third parties regarding the number of users of our Site and the activities they conduct while on our Site. Other ways we may use your information and share with third parties are further elaborated below in this section. We may also disclose aggregated user statistics in order to describe our Services to current and prospective business partners, and to other third parties for other lawful purposes.
We may release personal information to third parties: (1) to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order; or (2) in special cases, such as in response to a physical threat to you or others, to protect property or defend or assert legal rights. In the event that we are legally compelled to disclose your personal information to a third party, we will attempt to notify you unless doing so would violate the law or court order. When we share information with third parties, we ask that they agree in writing to abide by our Privacy Policy.
We, like many businesses, sometimes hire other companies to perform certain business-related functions to enable our Services to work better. Examples include banking and processing partners, credit card companies, security and audit providers, hosting service providers, and payment processing providers. When we employ another company to perform a function of this nature, we provide them with the information that they need to perform their specific function, which may include Personal Information.
If we or all or substantially all of our assets are acquired, we expect that the information that we have collected, including personal information, would be transferred along with our other business assets.
We also may use your Personal Information to provide you with targeted advertisements or marketing and events-related communications we believe may be of interest to you relating to our Services, promotional offers, events and surveys.
We may use your contact information in the future to notify you of important things, including but not limited to new or expanded Services capabilities, pending payment deadlines, or promotions from Guroo or our partners. We may contact you via email, mail and/or through SMSs or text messages. If we send you marketing emails, each email and/or SMSs or text messages will contain instructions permitting you to “opt out” of receiving future marketing or other communications.
We do not disclose, sell or rent your personal information to third parties for their direct marketing purposes.
We have implemented technology and security policies, rules and other measures to protect the personal data that we have under our control from unauthorized access, improper use, alteration, unlawful or accidental destruction, and accidental loss. We also protect your information by requiring that all our employees and others who have access to or are associated with the processing of your data respect your confidentiality.
Although Guroo makes every reasonable attempt to secure your information, no data transmission or storage can be guaranteed 100% secure and free of errors. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. We encourage you to ensure your device has up-to-date security and anti-virus software.
We will keep your Personal Information for as long as it remains necessary for the operation of the Site and the Services or as required by law, which may extend beyond the termination of our relationship with you. However, even after you close your account, we can retain copies of information about you and any transactions or Services in which you may have participated for a period of time that is consistent with applicable law, applicable statute of limitations or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce our Terms of Service or other applicable agreements or policies, or to take any other actions consistent with applicable law.
If you no longer desire to receive marketing-related emails from Guroo you have the choice to opt out via the unsubscribe link included in the emails or contact customer support at AskGuroo@GurooSolutions.com. We will attempt to comply with your request as soon as reasonably possible. If you elect to opt out of receiving marketing-related emails from us, we may still send you important administrative, business-related messages that are needed to continue providing you with the Services.
You can also request that we stop using all or a portion of your personal information if we have no legal right to keep using it or to limit our use of the information if it is inaccurate or unlawfully held by AskGuroo@GurooSolutions.com.
If you’re a California resident, you have certain privacy rights under California law, including the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this Policy.
The following summarizes the categories of information we may collect about you pursuant to definitions provided within.
You have the right to request that we tell you what personal information we have collected about you and how we have used it over the past 12 months. You may make this request for free, twice per year.
Once we receive and verify your request, we will provide you a report showing:
Please note that we may deny your deletion request if retaining the information is necessary for us or our service providers to:
We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by the CCPA, we will not:
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by either: emailing us at AskGuroo@GurooSolutions.com or contacting us via postal mail, proper postage prepaid at 2100 W. Loop South, Suite 801, Houston, Texas 77027, Attn: Your California Privacy Rights.
Please indicate your preference as to how you would like us to respond to your request (i.e., email or postal mail).
All requests sent via postal mail must be labeled “Your California Privacy Rights” on the envelope or postcard and clearly stated on the actual request. For all requests, please include your name, street address (if you would like a response via postal mail), city, state, and zip code.
Only you, or a personal registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. We may need to verify your identity before responding to your request, such as verifying that the email address or contact information from which you send the request matches your email address or contact information that we have on file. Authentication based on a government-issued and valid identification document may be required. We will not accept requests via telephone or fax. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
We may update this Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at AskGuroo@GurooSolutions.com.