This Privacy Policy describes the types of information gathered by GORICO INC. (“GORICO”, “us” or “we”) in the process of providing our websites and services, including but not limited to gorico.io, (the “Site”), and the associated services, data, information, tools, functionality, updates and similar materials (collectively, the “Service”), how we use it, with whom the information may be shared, what choices are available to you regarding collection, use and distribution of information and our efforts to protect the information you provide to us through the Service. It is important that you take the time to read and understand this Privacy Policy so that you can appreciate how we use your personal information.By using the Service, you hereby consent to allow us to process information in accordance with this Privacy Policy. Please also refer to our Terms of Service, available here Terms & Conditions, which are incorporated as if fully recited herein. Terms defined in the Terms of Service that are not defined herein shall have the same definition as in the Terms of Service.This policy is subject to change. If our information retention or usage practices change, we will let you know by posting the Privacy Policy changes on the Service and/or otherwise making you aware of the changes. Your continued use of the Service following our notice of changes to this Privacy Policy (or other method of legal acceptance) means you accept such changes. Please refer to the “Effective Date” above to see when this Policy was last updated.

Regardless of where our servers are located, your personal data may be processed by us in the United States, where data protection and privacy regulations may or may not be to the same level of protection as in other parts of the world. In all instances in this Privacy Policy, “our servers” means servers that we own or on which the Service is hosted, or which are otherwise utilized by the Service. By visiting the Site and using the Service, you consent to the collection and processing of information in the United States as described in this Privacy Policy. You acknowledge that data protection laws in the United States may differ from those in your jurisdiction. To the extent permitted by applicable law, U.S. law governs the collection and processing of your information. If you are located in the European Economic Area (EEA), United Kingdom, or other jurisdictions with specific data protection requirements, additional protections may apply as described in the relevant sections below.

We do. We collect information from you on the Service, and we are responsible for the protection of your personal information, sometimes also referred to as personally identifiable information, (collectively, “PII”).If you are located in the EEA or UK, we process your personal data based on the following legal grounds:
• Contract Performance: Processing necessary to provide the Service you've requested
• Consent: Where you have given explicit consent for specific processing activities
• Legitimate Interests: For improving our Service, security, and fraud prevention, where not overridden by your rights
• Legal Obligations: To comply with applicable laws and regulations

We collect certain personal information about you, which may be supplied when you register for the Service, when you create or update your account, when you use the Service, from third parties, or otherwise when you submit such information. The types of PII that we collect and save include:

• Contact and account information, such as name, email address, phone number, payment account information (e.g. credit card number, cvv, and/or bank account numbers), username, and employment information; and

• Technical information, collected in our logs and via cookies. Such information may include standard web log entries that contain your device identifiers (including mobile devices) and information, operating system information, usage statistics, clickstream data, IP address, previous page URL, referring page URL and timestamps.

You may provide us with information when you interact with us through email, submit a review or a post, or through other use of the Service. We may retain such information in order to provide you with services, and you agree that we may share this information as needed with other users in order to resolve any issues that may arise between you and another user of the Service.

The Service may record photos, audio, or video, and request permission to access your photo gallery, camera roll or other device storage area holding your images, in order for you to upload and transmit them through the Service. The Service also has the ability access the internet or use your mobile data plan in order to use certain features of the Service.

We do not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data, health data, or data concerning sex life or sexual orientation. If you choose to provide such information, you consent to our processing of it in accordance with this Privacy Policy.

Non-personal information is non-personally identifiable or anonymous information about you, including but not limited to links and materials posted, the type of device you used and its operating system, browser information, the pages accessed most frequently, how pages and features are used, time spent on a page, when and how you use the App, search terms entered, and similar non-personal information.

Automatically tracking Internet Protocol (IP) addresses is one method of automatically collecting information about your activities online and information volunteered by you. An IP address is a number that is automatically assigned to your device whenever you surf the internet. Further, the Service may utilize web beacons, pixel tags, first (both session and persistent) and third-party cookies, embedded links, and other commonly used information-gathering tools.

If non-personal information is paired to any of your PII, we will treat the non-personal information as if it were also PII.

Part of the purpose of the Service is to share materials you make available. Anything you publicly post will not be considered personal information.

We may also collect anonymous, non-identifying and aggregate information such as the type of browser you are using, the type of operating system you are using, the date and time of any request, language preference, referring site, and the domain name of your Internet service provider.

Payment processing is handled entirely by third-party payment service providers ("Payment Processors"). We do not receive, process, transmit, or store any payment card information (including credit card numbers, CVV codes, or banking information) on our servers. Payment information is collected and processed directly by our Payment Processors in compliance with Payment Card Industry Data Security Standards (PCI-DSS). We only receive confirmation of transaction completion and non-sensitive transaction identifiers necessary to fulfill your order. Our Payment Processors' privacy policies govern their collection and use of your payment information.

We need to collect your PII so that we can provide the Service, respond to your requests for information to enforce our Terms of Service, and to process your requests to access, and make payment for or receive payment from, the Service. We also collect aggregate information to help us better design the Service. We collect log information for monitoring purposes to help us to diagnose problems with our servers, administer the Service, calculate usage levels, and otherwise provide services to you.

A. We use the PII you provide for the purposes for which you have submitted it including:
• Internal Uses. We may use your PII to respond to your inquiries, fulfill your requests for information, track usage trends, conduct experiments, prevent fraud, develop and improve the Service and other offerings, and perform research and analytics.
• Creating and Maintaining Your User Account. We use your PII to create and maintain an account for you to allow you to purchase and use the Service.
• Paying for the Service. Your payment information is collected and processed through our Payment Processor.
• Sending Administrative Communications. We may use your PII to send you emails or push notifications to: (a) confirm your account information and your other PII; (b) process your transactions to purchase our Service; (c) provide you with information regarding the Service; or (d) inform you of changes to this Privacy Policy, our Terms of Service, or our other terms, conditions, or policies.
• Sharing with Third Parties Necessary for the Services. We will share or disclose certain PII with auditors, assessors, security partners, and other third parties that you have approved and who are necessary to provide the Services to you. Such transfers are subject to confidentiality obligations, including limitations on the use of such PII and its disclosure.
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We may share your information with the following categories of third-party service providers:• Cloud hosting and infrastructure providers (for data storage and Service operation)
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• Analytics providers (to understand Service usage and improve functionality)
• Customer support and communication platforms (to respond to your inquiries)
• Security and fraud prevention services (to protect the Service and users)
• Payment processors (as described in the section on finance)
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All third-party service providers are contractually required to maintain the confidentiality and security of your information and are prohibited from using it for purposes other than providing services to us.
B. We may use anonymous information that we collect to improve the design and content of our Service, and to enable us to personalize your internet experience. We also may use this information in the aggregate to analyze how our Site is used, as well as to offer you programs or services.

We will not share your PII except: (a) for the purposes for which you provided it, including for the Service to function; (b) with your consent; (c) as may be required by law or as we think necessary to protect our organization or others from injury (e.g., in response to a court order or subpoena, in response to a law enforcement agency request, or when we believe that someone is causing, or is about to cause, injury to or interference with the rights or property of another); or (d) with persons or organizations with whom we contract to perform services for us, including the performance, or development of, aspects of the Service and other internal operations or business activities.

We may also share aggregate information with others, including affiliated and non-affiliated organizations.

Finally, we may transfer your PII to a third party, or our successor-in-interest, in relation to, or in the event of, a merger, acquisition, sale of all or substantially all of our assets, reorganization, recapitalization, bankruptcy, or other change of control. After such disclosure or transfer, the third party or successor in interest may use the information in accordance with applicable law. We will provide notice of such transfer and any choices you may have regarding your information.

You may elect to share certain personal information with individuals or with the public via your use of the Service. In this case, you will control such sharing via settings that we provide. Be aware that when you choose to share information with friends, or with the public at large, you may be disclosing sensitive information, or information from which sensitive information can be inferred. Always use caution when sharing information through the Service. You understand and agree that we are not responsible for any consequences of your sharing of information through and beyond the Service.

After becoming a user of the Service, you may view, revise or edit certain personal information associated with you by logging into the Service and proceeding to your profile, or by sending an email to legal@gorico.io.For instructions on how you can further access your personal information that we have collected, or how to correct errors in such information, please send an email to legal@gorico.io. We will promptly stop processing your information and remove it from our servers and database at any time upon your e-mail request to legal@gorico.io, where required by law.You may opt-out of any of the following by emailing us at legal@gorico.io with "Opt-Out" in the subject line: sharing information with third parties; using your information for other than the primary purpose; being included in an online directory; and receiving any promotional emails from GORICO.You have the following rights regarding your personal information:
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• Right to Access: Request a copy of the personal information we hold about you
• Right to Correction: Request correction of inaccurate or incomplete information
• Right to Deletion: Request deletion of your personal information (subject to legal retention requirements)
• Right to Restriction: Request limitation of processing in certain circumstances
• Right to Data Portability: Receive your data in a structured, commonly used format (where applicable)
• Right to Object: Object to processing based on legitimate interests or for direct marketing
• Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent
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To exercise these rights, contact us at legal@gorico.io with your specific request. We will respond within 30 days (or as required by applicable law). For EEA/UK residents, you also have the right to lodge a complaint with your local supervisory authority.

A. After receiving your PII, we will store it on our servers for future use. We have physical, electronic, and managerial procedures in place to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect. Unfortunately, no data transmission over the internet or data storage solution can ever be completely secure. As a result, although we take industry-standard steps to protect your information (e.g., strong encryption), we cannot ensure or warrant the security of any information you transmit to or receive from us or that we store on our or our service providers' systems.

B. If you are accessing the Service from outside of the USA, you understand that your connection will be through and to servers located in the USA, and the information you provide will be securely stored in our servers and internal systems located within the USA.
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C. We store your PII until the earlier of (i) your PII no longer being necessary for the purposes for which it was being processed; (ii) our deletion of your PII in accordance with our data retention decisions as well as retention and other internal policies; or (iii) your request that we remove it from our servers, except in cases where we have the legal obligation, or authority, and we elect, to maintain that information. We store our logs and other technical records indefinitely.

A. To enhance your online experience with us, our web pages may use "cookies." Cookies are text files that our web server may place on your hard disk to store your preferences. Cookies, by themselves, do not tell us your email address or other PII unless you choose to provide this information to us. Once you choose to provide PII, however, this information may be linked to the data stored in the cookie. Certain features of the Services may not function properly without the aid of cookies. GORICO uses session cookies, which are necessary to allow you to seamlessly navigate from one page or area of the Site to another during your visit, and these are normally deleted when you close your web browser. We also use persistent cookies for your convenience so that you can log in faster, your preferences are remembered from visit to visit, and that you have an overall more convenient experience while visiting our Site.

Note: If you are located in the EEA or UK, we will not place non-essential cookies without your prior consent.

B. Our Service may use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). For more information on how Google uses data when you use our Site or Service, please follow this link: https://policies.google.com/technologies/partner-sites. You may be able to opt-out of some or all of Google Analytics features by downloading the Google Analytics opt-out browser add-on, available at, https://tools.google.com/dlpage/gaoptout. Google may additionally use your information as described here, https://policies.google.com/technologies/partner-sites?hl=en-US. You may be able to opt-out of Google's collection and/or use of your information. Please visit Google's Ads Preferences Manager or the Google Analytics opt-out browser add-on for more information.

C. We or our service providers may also use "pixel tags," "web beacons," "clear GIFs" or similar means (collectively, "Pixel Tags") in connection with some GORICO Site pages and HTML-formatted email messages for purposes of, among other things, compiling aggregate statistics about website usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1x1), that is ordinarily not visible to website visitors and may be associated with cookies on visitors' hard drives. Pixel Tags allow us and our service providers to count users who have visited certain pages of the GORICO Site, to deliver customized services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can inform the sender of the email whether and when the email has been opened.

D. As you use the internet, you leave a trail of electronic information at each website you visit. This information, which is sometimes referred to as "clickstream data", can be collected and stored by a website's server. Clickstream data can reveal the type of computer and browsing software you use and the address of the website from which you linked to our Site. We may use clickstream data as a form of non-personally identifiable information to determine how much time visitors spend on each page of our Site, how visitors navigate through the Site, and how we may tailor our web pages to better meet the needs of visitors. We will only use this information to improve our Site, the App, and the Services.

E. Do Not Track. At present, the Service does not specifically respond to browser do-not-track signals. However, you can manage cookies and tracking technologies through your browser settings and the methods described in this section.

For your convenience, our Terms of Service may provide links, and that you may access through our Service, to certain third-party websites and services. When you leave our Service, please check the privacy policies of these other websites to learn how they collect, use, store and share information that you may submit to them or that they collect. We are not responsible for the privacy practices of such other sites. This Privacy Policy applies solely to information collected by GORICO through the Service.

We do not knowingly collect any information from any minors, and we comply with all applicable privacy laws including the Children's Online Privacy Protection Act ("COPPA"), and associated Federal Trade Commission ("FTC") rules for collecting personal information from minors. Please see the FTC's website (www.ftc.gov) for more information. If you have concerns about this Site, wish to find out if your child has accessed our services, or wish to remove your child's personal information from our servers, please contact us at legal@gorico.io. Our Site will not knowingly accept personal information from anyone under 13 years old in violation of applicable laws, without consent of a parent or guardian. In the event that we discover that a child under the age of 13 has provided PII to us, we will make efforts to delete the child's information in accordance with the COPPA. If you believe that your child under 13 has gained access to our Site without your permission, please contact us at legal@gorico.io.

California law allows California residents to request information regarding our disclosures to third parties in the prior calendar year, if any, of their personally identifiable information. To make such a request, please contact us at legal@gorico.io with "Request for Privacy Information" in the subject line. Please include enough detail for us to locate your file; at a minimum, your name, email, and username, if any. We will attempt to provide you with the requested information within thirty (30) days of receipt. We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one posted in this notice. Please note that this law does not cover all information sharing. Our disclosure only includes information covered by the law.

If you are located in the European Economic Area (EEA) or United Kingdom, you have specific rights under the General Data Protection Regulation (GDPR) and UK GDPR:
Data Controller: GORICO INC. is the data controller for your personal information.
Legal Bases for Processing: As outlined in Section 1 above.
Your Rights:
• Rights described in Section 7 above
• Right to lodge a complaint with your supervisory authority
Data Protection Officer: For privacy inquiries, contact legal@gorico.io.

We may update this Privacy Policy from time to time. When we make material changes, we will:
• Update the "Effective Date" at the top of this policy
• Notify you via email (if you have an account with us)
• Post a notice on our Service
• For material changes that affect your rights, obtain your consent where required by law.
We encourage you to review this Privacy Policy periodically. Your continued use of the Service after changes indicates your acceptance of the updated policy.

If you have any questions or concerns about this Privacy Policy you may email us at legal@gorico.io.©
GORICO INC. All rights reserved. The Site and Service are the property of GORICO, and are protected by United States and international copyright, trademark, and other applicable laws. This includes the content, appearance, and design of the Site and Service, as well as the trademarks, product names, graphics, logos, service names, slogans, colors, and designs.