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GiiLD U.S. Privacy Notice

GiiLD LLC, doing business as poqet ai (also referred to in this Privacy Notice as "GiiLD," "we," "our," and "us"), takes the protection of your Personal Data seriously. GiiLD is a Minnesota-based software company that pioneered poqet ai (the Software) to help AI developers use less data, smaller algorithms, fewer parameters, and less energy to understand and improve machine learning models. GiiLD's pursuit of excellence extends to our commitment to respecting your privacy rights in your various interactions with us including your use of our Services which include both the Software, subscription services, and our website located at https://GiiLD.com (the Site). We use this Privacy Notice to provide you with information about our privacy practices so that you know what Personal Data we have, where it goes, and what the Data is used for. If there is something you do not understand about our privacy practices, please feel free to contact us using the contact information listed at the end of this Privacy Notice. 

 

We may change this Privacy Notice from time to time so please check back often. If we significantly change our collection, use, or disclosure practices, we may send you an updated notice via email if you have provided us with an email address. Please keep in mind that some of the Services mentioned specifically in this notice may not be available in our Services at this time. If you are applying for a job with GiiLD or are completing our employee on-boarding processes, your use of the Site for those purposes is governed by our HR Privacy Policy.

This Privacy Notice is effective as of May 5th, 2024.

 

Table of Contents

1.         Scope of this Privacy Notice

2.         Data Minimization and Use

3.         What information do we collect from you?

4.         How do we collect information from you and how can you opt-out of collection?

A.         Direct Collection

B.         Indirect Collection – Cookies and Other Technology for Services Operation and Analytics

C.         Indirect Collection – Social Networking

5.         How do we use your Data?

6.         With whom do we share your Data?

A.         Service Providers

B.         Data in the Aggregate

C.         Other

7.         How can I control my Personal Data?

8.         How does GiiLD protect financial-related information?

9.         What security precautions are in place to protect against the loss, misuse, or alteration of your Data?

10.       How long do we keep your Personal Data?

11.       What else should you know about your privacy?

12.       Do Not Track Codes

13.       Your Privacy Rights in California and other States

A.         Our Collection, Use, and Disclosure of Personal Data.

B.         Privacy Rights and Choices.

C.         International data transfers.

D.         How to Submit a Request Regarding Your Privacy Rights?

E.          Authorized Agents.

F.          Verifying Requests.

G.         Right to Non-Discrimination and No Retaliation.

H.         Right to Appeal a Privacy Rights Request Decision.

I.          Responses to Requests.

14.       Who do you contact with questions or concerns about our Privacy Notice or to exercise your privacy rights?

 

 

1.  Scope of this Privacy Notice

 

GiiLD collects personal information relating to or that identifies individuals (Personal Data or Data) from several sources. This Privacy Notice describes how GiiLD collects, uses, discloses, and safeguards that Data. Unless otherwise indicated, GiiLD follows this Notice with respect to Data obtained from or about individuals in the United States.

 

This Notice applies only to GiiLD Services where we determine why and how we use the Personal Data we collect to deliver the Services including Software licensing sales and subscriptions, customer service, marketing, providing the Site, or other legitimate business purposes, (the Services) and how in that capacity we act as the "Controller" of the Data we collect. To be clear, this Notice does not cover Data that our customers collect and share with GiiLD where we are not the Controller, but rather a "Processor" or "Service Provider."

 

If you use a GiiLD Software product with an account provided by an organization you are affiliated with, such as your employer, that organization is the Controller and GiiLD is the Processor with respect to any Data connected with your use of that Software. Your organization can (1) control and administer your GiiLD software product and account, including controlling privacy-related settings; and (2) access and process your Data associated with that account. If your organization provides you with access to GiiLD Software, your use of the GiiLD Software is subject to your organization's policies, and not GiiLD's. You should direct your privacy inquiries, including any requests to exercise your Data protection rights, to your organization's administrator. However, GiiLD is the Controller of Data connected with your other interactions with us, such as your visits to the Site.

 

The Site, Software, or any of our communications may contain links to other websites, applications, and services from third parties (like YouTube, for example) which we have no control or authority over. The privacy and data security practices of those third-party sites are governed by the privacy policies of those third parties, and not by GiiLD.

 

We use this Notice to provide you with information and be clear about what we do with the Data we collect through our Site, Software, and other communications with us. However, additional terms and conditions apply to your use of the Site and Software. Use of the Software is governed by the terms of the end user license agreement available at https://GiiLD.com/EULA. Additionally, by accessing or using the Site, you accept and agree to be bound by the Site Terms of Use, which you can view at any time at https://GiiLD.com/terms.

 

2.  Data Minimization and Use

 

GiiLD requires a minimal amount of Personal Data to provide our Services. If you choose to share more information, we process that information in accordance with this Notice. We do not sell Personal Data and we do not share Personal Data with third parties for those parties' own business interests.

3.  What information do we collect from you?

 

We collect information in several ways. Some of the information we collect is personal to you. Other information is anonymous. We collect the following categories of information:

  • During registration, we ask for your name, email address, and the content of your message to us;

  • When you report a problem with our Services we will collect contact information along with a description of your problem;

  • When you contact us via the company email address, we will collect your contact information and any information you include in your email;

  • When you sign up for our newsletter, we collect the name and email address you provide to us;

  • When you order Software from us or renew your subscription we ask for transaction information including your mailing address, phone number, email address and payment information;

  • When you post information in interactive areas of our Site such as public forums, we collect the content you provide in your post;

  • When you pay for a Service using a payment card, we and our partners collect location data consisting of the country you select as the location of your transaction;

  • We collect location data based on your IP address;

  • When you visit and navigate our Site, use our applications or third party sites, or open our emails, we may collect technical information about your use of our Site including IP address, device identifier, and viewing information.

 

Our Services are not intended to solicit, collect or process Personal Data from any individual under the age of 13. If you are a parent or guardian of a child under the age of 13, please contact us if you believe information regarding a child has been collected by us through our Services.

4.  How do we collect information from you and how can you opt-out of collection?

 

A.  Direct Collection

We collect much of the information listed above directly from you when you submit it to us through email, on our Site, in the course of setting up a Software subscription, or in other interactions you have with us. This includes information such as registration information, contact information, subscriptions to newsletters or other marketing communications, user submissions, and public postings. The Personal Data that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your Personal Data (unless it is obvious from the context).

i.  Opting Out of Direct Collection

If you do not want to share your information, you can choose not to participate in a particular Service or activity.

 

To ensure that you will not receive recurring marketing or other information from us unless you choose to, we will provide you with simple instructions on each marketing email or subscription Service from us for you to let us know that you have chosen to stop receiving such emails or subscriptions from us.

 

B.  Indirect Collection – Cookies and Other Technology for Services Operation and Analytics

We and our third party service providers or partners may collect certain information automatically from your device when you visit our Site or use any Services we provide. In some states and countries, including countries in the European Economic Area and the United Kingdom, this information may be considered Personal Data under applicable data protection laws.

 

Specifically, the information automatically collected when you visit our Site may include information like your IP address, device type, unique device identification numbers, browser type, operating system, date and time of visit, referring website, the search engine queries used to get to our Site, broad geographic location (e.g. country or city-level location), and other technical information. It may also include information about how your device has interacted with our Site, including the pages accessed and links clicked. We also collect information related to your use of the Site, such as your Site usage information, transaction information including whether a Know Your Customer check was completed (if applicable), Site communication information and account activity information.

 

Collecting this information provides a better understanding of the visitors who come to our Site, where they come from, and what content on our Site is of interest to them. This information is used for our internal analytics purposes, to improve the quality and relevance of our Services to our visitors, and to enhance the security of our Site. We also use this information for detection and prevention of fraud, security threats or other illegal or suspicious behavior on our Site.

 

We also automatically collect information about your use of the Software and your subscription. The Software associated with your subscription contains a service control mechanism designed to limit your use of the Software to the period of time for which you subscribed to it. When your subscription ends, the service control mechanism will notify us that your subscription period is over.

 

In addition to collecting Personal Data for the purposes outlined in this Privacy Notice, we may use Personal Data for other compatible purposes including, without limitation, anonymizing or de-identifying data. To the extent we anonymize or de-identify data, we will not attempt to re-identify such data.

 

As part of offering and providing customizable and personalized Services, many websites use cookies and other online tracking technologies to store and sometimes track information about you. We may use these technologies to:

  • Enable you to more easily use our Site by remembering and using contact information, purchasing information, and registration information;

  • Evaluate, monitor and analyze the use of our Site and its traffic patterns to help improve our Services;

  • Assist us with ad reporting functions such as to learn which ads are bringing users to our Site.

 

However, we do not track your activity across the web.

 

i.  The types of technologies we use include:

Cookies. A cookie is a small amount of data that is sent to your browser from a web server and stored on your computer’s hard drive. Cookies enable us to identify your browser as a unique user. Cookies may involve the transmission of information from us to you and from you to us. Cookies may also be used by another party on our behalf to transfer information to us in accordance with their privacy notice. Some cookies are "persistent cookies." They are used by us each time you access our Site. Other cookies are called "session cookies." Session cookies are used only during a specific browsing session. We may use a session cookie, for example, to remember that you have already navigated through a particular menu, or that you have entered in age information for a portion of a Site that is restricted by age. We may also use "analytics cookies" that allow web analytics services to recognize your browser or device and, for example, identify whether you have visited our Site before, what you have previously viewed or clicked on, and how you found us. This information is provided anonymously for statistical analysis only. Analytics cookies are usually persistent cookies.

 

Our Site only uses only strictly necessary, functional, and analytics cookies for the following purposes: to distinguish humans from bots, to store your cookie consent preference for the Site, to present Site content, to identify and/or authenticate a user as being logged into the Site, to ensure a user connects to the right service if a change is made; and for security purposes.

 

We do not use targeting cookies.

 

Web Beacons. We also employ a software technology called a clear GIF (Graphics Interchange Format), also known as a pixel tag or web beacon. A clear GIF is a line of code that we place on our Site or in e-mails which allows us to analyze our advertising and the general usage patterns of visitors to our Site. These help us better manage content on our Site by informing us what content or promotions are effective.

 

Log Files. Like most standard website servers, we use log files. Log files track Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. We utilize this information to analyze trends, administer the Site, prevent fraud, track Site navigation in the aggregate, and gather broad demographic information for aggregate use.

 

ii.  Data from third party sources.

Although we do not track user activity across the web or sell Personal Data, our Site may contain links to third party websites, embedded content that comes from or relates to third party websites and services, and buttons from third party websites and services (such as social media sharing buttons). From time to time, we may receive Personal Data about you from third party sources.

 

These third party sources may include, but are not limited to, suppliers, third party web analytics services, and social media platforms, such as YouTube. The types of information we may receive from these third parties includes information on your web activity about how you interact with our Site and their services and aggregated analytics. We use this information to help improve our Services, provide information and advertising, and to be able to analyze aggregate click statistics and trends. We may also obtain aggregated information, including analytical results, about your use of the Site for fraud detection, prevention and reporting purposes.

 

GiiLD does not knowingly track your activities across the internet. However, Google, Inc., may utilize the data  it collects to track and examine the use of our Site, to prepare reports on its activities and share them with other Google, Inc. services. Google, Inc. may also use the data collected to contextualize and personalize the ads of its own advertising network to serve ads to you based on your visit to our Site and other sites on the Internet. You may view Google's privacy policy here: https://policies.google.com/privacy?hl=en, with more information located here: https://www.google.com/policies/privacy/partners/ (including information regarding how to control how Data is shared through your Ads Settings) and here: https://support.google.com/analytics/answer/6004245?hl=en.

 

Facebook similarly provides more information regarding the data it collects and how it is used in relation to advertising here: https://www.facebook.com/policy.php. Although Facebook provides statistical information about user interactions with GiiLD ads running on its platform, this information is not linked to any individual and cannot be used to identify you.

iii.  Opting Out of Indirect Collection

You may disable browser cookies in your browser or set your browser to warn you when a cookie is being sent. You may lose some features or functionality when you disable cookies. Remember, also, that disabling cookies is browser specific. If you log on using Microsoft Edge, you must also disable cookies in Safari, Google Chrome, Firefox or other browsers if you use those browsers at a different time.

 

You can prevent the collection of the data generated by Google Analytics in relation to your use of websites and the processing of this data by downloading and installing the browser plug-in, with more information regarding how you can opt out of Google Analytics data collection as instructed here: https://tools.google.com/dlpage/gaoptout. This link provides instructions for installing an opt-out cookie on your device. As a result, the collection of data by Google Analytics is prevented in the future for this browser as long as the opt-out cookie remains installed in your browser.

 

You may opt-out of Facebook's collection and sharing of data here: https://www.facebook.com/settings?tab=ads.

 

You may also opt-out of data sharing from other third party websites to us using the information provided in their privacy policies.

 

C.  Indirect Collection – Social Networking

The Site permits you to use a third party social networking platform YoutTube. From time to time, we may add social media plugins such as Facebook “Like”, or X "Tweet", buttons, etc. When you use these social networking platforms and plugins, your username and password for the available service or collected from you on these services may be shared with us. When you use social networking platforms and plugins, you share your Data with them and their privacy notice applies disclosure of such Data. In addition, they may be able to collect Data about you, including your activity or may notify your connections on the social networking platform about your use of the Site. Such services may allow your activity to be monitored across multiple websites for purposes of delivering more targeted advertising. Please note that their own privacy polices apply and we encourage you to read them.

5.  How do we use your Data?

 

Our main goal in collecting Data is to improve the Services and provide you with the best possible experience with those Services and on the Site. For example, by using the Data we collect, we can provide you with an easy to use and readily available forum to learn about our Software, Services, and access our YouTube Series "Practical AI".

 

We will also use your Personal Data to:

  • Notify you of other products or Services available from GiiLD;

  • Enable you to participate in online transactions;

  • Make our Software, Services, and Site better;

  • Compile, analyze and do research on our users' demographics and behavior;

  • Detect, investigate and prevent activities that may violate our policies or be illegal;

  • We use, and share location data only to provide and improve our Service.

 

6.  With whom do we share your Data?

 

We will not disclose any of your personally identifiable Data except when we have your permission or under special circumstances, such as when we believe in good faith that the law requires it or under the circumstances described below. These are some of the ways that your Data may be disclosed:

 

A.  Service Providers

We occasionally hire other companies to provide limited services on our behalf, including Site development and operation, sending email, analyzing Site use, processing payments, providing investor information and processing data. We will only provide those companies the information they need to deliver the service, and they are contractually prohibited from using that information for any other reason.

 

B.  Data in the Aggregate

We may disclose “blinded” aggregated data and user statistics to prospective partners and other third parties. Blinded data is data that does not identify an individual person.

 

C.  Other

We also may disclose your Data in special cases. For example, when we believe that we must disclose Data to identify, contact or bring legal action against someone who may be violating our Terms of Use, or may be causing injury to or interference with our rights or property, other Site users or customers and their Data, or anyone else who may be harmed by such activities. GiiLD and our service providers may disclose, access or monitor your Personal Data when we believe in good faith that the law requires it and for administrative and other purposes that we deem necessary to maintain, service and improve our products and Services and our information security. This includes third party partners and service providers we use to enable the detection of devices connected with fraud and other types of information security vulnerabilities, to prevent fraud, security threats and illegal or malicious behavior, and to enhance security on our Site and other pages on the internet.

 

As we continue to develop our business, we may buy or sell businesses or assets. In such transactions, confidential customer information generally is one of the transferred business assets. In the event of a transaction involving the sale of some or all of GiiLD’s businesses, customer and Site visitor information may be one of the transferred assets and may be disclosed in connection with negotiations relating to a proposed transaction. In such case, the transferred Data may become subject to a different privacy notice.

 

7.  How can I control my Personal Data?

 

We offer our customers choices for the collection, use and sharing of Personal Data. You may contact us using the contact information at the bottom of this Privacy Notice if you wish to view, edit, or delete your Personal Data from our database, and we will use commercially reasonable efforts to accommodate your request.

 

If you believe that any inaccurate or inappropriate information has been obtained or provided to others through your use of our Services, you should contact a representative of GiiLD using our contact information at the bottom of this Privacy Notice.

 

8.  How does GiiLD protect financial-related information?

 

Keeping your personal financial information private is very important to us. As a matter of policy and long-time business practice, we do not sell information provided by our users. Any user statistics that we may provide to prospective partners regarding financial matters are provided in the aggregate only and do not include any personally identifiable Data about any individual user. We use a third party payment processor to process your payments and do we do not collect or retain your credit card or bank account information.

9.  What security precautions are in place to protect against the loss, misuse, or alteration of your Data?

 

Because Data sent through the Internet travels from computer to computer throughout the world, when you give us Data, that Data may be sent electronically to servers outside of the country where you originally entered the Data. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. Our Site uses Transport Layer Security (TLS) which uses encryption to protect transfers of Personal Data. You will know that a webpage within our Site uses TLS when you see the padlock symbol 🔒 or "https" in the URL. Information that you disclose by use of this Site (as with any site that is non-secure), by posting a message or using e-mail, potentially could be collected and used by others. This may result in unsolicited messages from third parties or use of such information by third parties for their own purposes, legal or illegal. As a result, while we strive to protect your Personal Data, we cannot ensure or warrant the security of any information you transmit to us or from our Services, and you do so at your own risk. Once we receive your transmission, we use commercially reasonable efforts to ensure its security on our systems. We limit access to your Personal Data to those employees who reasonably need access to such Data in order to provide and improve our Services and process your Data appropriately.

 

10.  How long do we keep your Personal Data?

 

The length of time we retain Personal Data will be determined based upon criteria such as: the length of time your Personal Data remains relevant; the length of time it is reasonable to keep records to demonstrate that we have fulfilled our duties and obligations; any limitation periods within which claims might be made; any retention periods prescribed by law or recommended by regulators; or the type of contract we have with you, the existence of your consent, and our legitimate interest or business need in keeping such Data (for example, to provide you with a Service you have requested or to comply with applicable legal, tax, compliance, or accounting requirements).

 

When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.

 

11.  What else should you know about your privacy?

 

Please keep in mind that whenever you voluntarily disclose information online, that information is accessible to others. Ultimately, you are solely responsible for maintaining the secrecy of your passwords and/or any account information. Please be careful and responsible whenever you are online.

 

When you or we end your customer relationship with us, we will treat the Data we have about you as if you were still our customer.

 

12.  Do Not Track Codes

 

As mentioned above, we do not monitor or track activity across the web. However, the Site recognizes DNT and GPC signals.

 

Some browsers allow a "do not track" (DNT) setting to request a web application disable its tracking of a user. When a DNT setting is set in your browser, your browser will send a signal to websites, analytics companies, ad networks, and other web services to stop tracking your activity. Please feel free to visit the All About DNT (https://allaboutdnt.com/) page, to enable DNT signals for sites who do in fact use tracking technologies.  Our Site also adheres to the Global Privacy Control (GPC) which allows you enable your browser to send a universal opt-out signal. GPC is a technical specification used to inform websites of a privacy preference for ad trackers. To set up GPC, you can visit the Global Privacy Control (https://globalprivacycontrol.org/#about) page.

 

13.  Your Privacy Rights in California and other States

 

A.  Our Collection, Use, and Disclosure of Personal Data.

Residents of certain U.S. states may have rights under privacy laws in effect in their state, such as under the California Consumer Privacy Act (CCPA), Virginia Consumer Data Privacy Act, Colorado Privacy Act, Utah Consumer Privacy Act, Connecticut’s Act Concerning Personal Data Privacy and Online Monitoring, Montana's Consumer Data Privacy Act, Oregon Consumer Privacy Act, Texas Data Privacy and Security Act, and any other U.S. privacy law and implementing regulations (collectively, State Privacy Laws)). In the future, you may have rights under other state privacy laws that become effective. Please check back for updates as we may update this Privacy Notice to address those laws.

 

California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an email to or write us using the contact information at the bottom of this Privacy Notice. Make sure to state that you are a California Resident.

 

Nevada Rev. Stat. § 603A.340, permits customers in Nevada to opt-out of the sale of certain kinds of Personal Data. A sale under Nevada law is the transfer of this Personal Data to third parties for monetary consideration so these third parties can then re-sell or license the sold Data. We do not sell your Personal Data to third parties as defined in Nevada law.

 

Some of the State Privacy Laws do not apply to Personal Data covered by GLBA, or collected in the business to business context (B2B) or in the human resources (HR) context. We will not process privacy rights requests where these exceptions apply.

 

If you use a GiiLD Software product with an account provided by an organization you are affiliated with, such as your employer, your use of the GiiLD Software is subject to your organization's policies, and not GiiLD's. You should direct your privacy inquiries, including any requests to exercise your Data protection rights, to your organization's administrator. However, you can direct inquiries regarding other interactions with us, such as your visits to the Site, directly to GiiLD using the contact information at the end of this Notice.

 

Various State Privacy Laws including the CCPA require us to provide you with more detailed descriptions of the Personal Data we collect, how we use that Data, and the parties we disclose that Data to. Below is a table that details our Data practices.

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B.  Privacy Rights and Choices.

Certain consumers may have various rights under State Privacy Laws and are entitled to the various disclosures, which may include:

 

Right to Know.  The right to request that we disclose the Personal Data we collect, use, disclose, sell, and share. Please see the Submit a Request section below to request the Personal Data we collect, use, and disclose. Please also see the above table that includes the categories of Personal Data we collect, the sources of Personal Data, the business or commercial purposes for which Personal Data is used, whether Personal Data is sold or shared, as defined by the applicable State Privacy Law, and the categories of third parties with whom Personal Data is shared.

 

Right to Request Deletion. The right to request that your Personal Data be deleted. We may save Personal Data when permitted by applicable law including, without limitation, when the Data is needed to complete a transaction, to detect or protect against security incidents or illegal activity, and for a legal or compliance purpose. If we delete your Personal Data, you will lose a personalized experience with our Services and content might not be as relevant to you. If you have an account with us, it will be deleted and you will no longer be able to access it. You also will lose your account and purchase history. Please see the Submit a Request section below to submit a request to delete.

 

Right to Opt-Out of the Sale of Your Personal Data or Sharing of Personal Data for Targeted Advertising. The right to opt-out of having your Personal Data sold or your Personal Data shared for Targeted Advertising.

 

However:

  • GiiLD does not knowingly sell or allow third parties to sell your information.

  • GiiLD does not knowingly share Personal Information for purposes of targeted advertising.

  • GiiLD does not knowingly use technologies to track an individual's behavior across the internet and derive value from use of such technologies.

 

Right to Opt-Out of Profiling. The right to opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects on the consumer. GiiLD does not engage in such profiling.

 

Right to Obtain Copy of Your Personal Data. The right to obtain a copy of the Personal Data in a portable and readily usable format. Please see the Submit a Request section below to submit a request to a copy of your Personal Data.

 

Right to Correct. The right to request to correct any inaccuracies in your Personal Data. To do so, please refer to the how to Submit a Request Regarding Your Privacy Rights section below.

 

Right to Restriction. The right to submit a request to limit the use and disclosure of your sensitive Personal Data. GiiLD does not collect or share Sensitive Data. Sensitive Data includes information like your social security number, sexual orientation, religious beliefs, private health matters, union membership and other such information depending on the applicable privacy law.

 

C.  International data transfers.

 Your Personal Data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country and, in some cases, may not be as protective. Specifically, our Site servers are located in USA, and our third party service providers and partners operate around the world. This means that when we collect your Personal Data we may process it in any of these countries.

 

D.  How to Submit a Request Regarding Your Privacy Rights?

To submit a request to know the Personal Data we have about you or to submit a request to delete your Personal Data, please email us at the at the email address at the bottom of this Privacy Notice or submit a request using our web form available at the bottom of this page. When you submit a request to know or delete, you must provide your first name, last name, email address, and customer ID, if applicable.  Use the contact information at the end of this Notice to exercise any of your privacy rights.

 

E.  Authorized Agents.

You may designate an authorized agent to make a request on your behalf. To be able to act, authorized agents must submit proof that they are authorized to act on your behalf. We may deny requests from claimed authorized agents who do not submit adequate proof that they are authorized to act on your behalf. We do not process privacy requests sent to us using third party services that have not complied with our verification process. This is because such services often request that we click on hyperlinks which we will not do for data security reasons. These services are also susceptible to spoofing and other phishing attacks. One of our highest priorities is to treat your Data safely and securely. If you live in a state that permits you to make a privacy request using a third party agent, please have them contact us using the information above and we will take steps to identify them and ensure that they are your agent.

 

F.  Verifying Requests.

To help protect your privacy and maintain security, we will take steps to verify your identity before complying with your requests. For example, for requests to know and delete, we will attempt to match your identity to the Data stored in our files. If we cannot, we will ask you to provide additional identifying information. We will use information you provide in your request for the purpose of verifying your identity or authority to make the request.

 

G.  Right to Non-Discrimination and No Retaliation.

Residents of certain states have the right not to receive discriminatory treatment by us for opting out of sharing your Personal Data or exercising your privacy rights conferred by applicable privacy laws. Unless permitted by applicable privacy laws, we will not:

  • Deny you Services

  • Charge you different prices or rates for Services, including through granting discounts or other benefits, or imposing penalties

  • Provide you a different level or quality of Services

  • Suggest that you may receive a different price or rate for Services or a different level or quality of Services

 

However, we may offer you certain financial incentives permitted by applicable privacy laws that can result in different prices, rates, or quality levels. Any legally permitted financial incentive we offer will reasonably relate to your Personal Data'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.

 

H.  Right to Appeal a Privacy Rights Request Decision.

Certain consumers have the right appeal our denial or limitation of your privacy rights request under applicable State Privacy Law. If you wish to appeal a denial or limitation of your privacy rights request, you may email us at notify@giild.com.

 

I.  Responses to Requests.

Describe your request with sufficient detail that allows us to understand, evaluate, and respond to it. We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

 

We will only use Personal Data provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. We will try to respond to your request within 45 days of when we receive it. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Data that is readily usable and should allow you to transmit the Personal Data from one entity to another without hindrance, specifically by electronic mail communication.

 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee; we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

14.  Who do you contact with questions or concerns about our Privacy Notice or to exercise your privacy rights?

 

If you need further assistance, please send an e-mail with your questions or comments to notify@giild.com  or submit a request using our web form below.

Privacy questions/concerns form

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