We welcome you to Guru, our website at www.myguru.app. and/or our iOS and Android Mobile application (our “Platform”). In the below Privacy Policy, we inform you about the scope of the processing of your personal data. Guru proceeds with all data processing procedures (e.g., collection, processing, and transmission) in accordance with the Delaware Online Privacy and Protection Act (“DOPPA”) and the General Data Protection Regulation (“GDPR”).

Responsible for data processing

Responsible for data processing in accordance with the provisions of the DOPPA and GDPR is:

Guru Corp

17507 South DuPont Highway

Harrington, Delaware, 19952, USA

Web: www.myguru.app

E-Mail: admin@myguru.app

General information on data processing

In the course of our business and platform operations, we process data, and this data is generally transferred to our Headquarters in Delaware, USA and stored at our privately leased "A2 hosting" server and we use Wix.com Ltd for the provision of our website. However, this also includes disclosure by transmission to third parties and to so-called third countries outside the USA and EEA.

All personal data that we obtain from you via the platform will only be processed for the purposes described in more detail below. This is done within the framework of the respective legal regulations mentioned or only with your consent. In particular, the DOPPA and GDPR specify when data processing is permitted. Guru collects personal data if:

• you have given your consent,

• the data is necessary for the fulfillment of a contract / pre-contractual measures,

• the data is necessary for the fulfillment of a legal obligation or

• the data is necessary to protect the legitimate interests of our company, provided that your interests are not overridden.

Guru processes and stores your personal data only for the period of time required to achieve the respective processing purpose or for as long as a legal retention period (in particular Delaware`s commercial and tax law) exists. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.

Processing of Automatically Collected Data

a) Collection of access data and log files

We also collect data on every access to our website. The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is stored for security reasons (e.g., for the clarification of abuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the respective incident is finally clarified. The legal basis for the data processing is our legitimate interest in providing an appealing website.

b) Use of cookies

We think it's important that you have full control over your privacy online and that's why we refrained from placing cookies that are non-essential such as functional and performance cookies. As set out in the EU`s Privacy and Electronic Communications Directive (PECD), we don’t need to obtain consent when we don’t use them, and this is why we don’t need one of these annoying cookie pop ups.

c) Downloading the APP

The APP can be downloaded from the "Google Playstore" a service offered by Google Inc, 1600 Amphitheatre Parkway Mountain View, CA 94043, US, if you are resident outside the EU and Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland if you are a resident within the EU, or the Apple App service "App Store" a service of Apple Inc., 1 Infinite Loop, Cupertino, CA 95014, US, if you are resident outside the EU and Apple Distribution International Ltd, Hollyhill Industrial Estate, Hollyhill Ln, Knocknaheeney, Cork, Ireland, if you are a resident within the EU, to install our APP. Downloading it may require prior registration with the respective App store and/or installation of the respective App store software.

d) Installing the APP

As far as we are aware, Google collects and processes the following data: License check, network access, network connection, WLAN connections, and location information. However, it cannot be ruled out that Google also transmits the information to a server in a third country. We cannot influence which Personal Data Google processes with your registration and the provision of downloads in the respective App store and App store software. The responsible party in this respect is solely Google as the operator of the Google Play Store.

As far as we are aware, Apple collects and processes the following data: device identifiers, IP addresses, location information, it cannot be excluded that Apple also transmits the information to a server in a third country. This could in particular be Apple Inc. One Apple Park Way, Cupertino, California, USA, 95014. We cannot influence which Personal Data Apple processes with your registration and the provision of downloads in the respective app store and app store software. The responsible party in this respect is solely Apple as the operator of the Apple App Store.

e) Device information

Google and Apple may collect information from and about the device(s) you use to access the APP, including hardware and software information such as IP address, device ID and type, device-specific and APP settings and properties, APP crashes, advertising IDs (AAID), information about your wireless and mobile network connection such as your service provider and signal strength; information about device sensors such as accelerometer, gyroscope, and compass.

f) Purchases

When you make In-app purchases, we (Google and Apple on our behalf) may collect the following data from you to process the purchase:

• Android or Apple user ID

• Email address

• Payment confirmation from the payment data collected by Apple or Google; and

• Device IP and device serial number to link the story history to the device.

g) Firebase

We use the Google Firebase developer platform and related features and services provided by Google LLC and Google Ireland Limited. Google Firebase is a platform for developers of apps for mobile devices. The Google Firebase developer platform offers a variety of features. A list of these features can be found at: https://firebase.google.com/terms/. Firebase's key security and privacy information can be found here: https://firebase.google.com/support/privacy

Data processing when you use our services

a) Contacting us

If you contact us, we process the following data from you for the purpose of processing and handling your request: first name, last name, e-mail address, and, if applicable, other information if you have provided it, and your message. The legal basis for the data processing is our obligation to fulfill the contract and/or to fulfill our pre-contractual obligations (Art. 6 para. 1 lit. b GDPR) and/or our overriding legitimate interest in processing your request (Art. 6 para. 1 lit. f GDPR).

b) Profile and account

If you create a user account, you consent to the storage of your account and log-in data (Username, phone number, birth date and preferred "screen name"). This allows us to identify you as a user and gives you the opportunity to manage your account, use our services and manage your purchases. Within your profile you are able to delete your account at any time. Your data will be processed on the basis of your consent (Art. 6 para. 1 lit. a GDPR).

c) When using our services

We process the data of our registered users in order to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop it further. The required information is identified as such in the context of the information required for the provision of services and billing as well as contact information.

Unless otherwise specified the purposes of processing are contractual performance and service, contact requests and communication, office and organizational procedures, administration, and response to requests, visit action evaluation, interest-based and behavioral marketing.

Some of the Personal Data you provide may be considered “special” or “sensitive”. This includes Personal Data concerning for example your health, racial or ethnic origins, sexual orientation, and religious beliefs. By choosing to provide this data, you consent to our processing of that data.

You have choices about the Personal Data you upload and share. You don’t have to provide Personal Data; however, Personal Data helps you to get more from our Services. It’s your choice whether to include special category data and to make that special category data public. Please do not upload or add data that you would not want to be available.

The legal basis for the processing of your personal and special category data is the establishment and implementation of the user contract for the use of the service as well as your consent. We store the data until you delete your user account. Insofar as legal retention periods are to be observed, storage also takes place beyond the time of deletion of a user account.

You may withdraw your consent and request us to stop using and/or disclosing your personal and special category data by submitting your request to us in writing to admin@myguru.app.

The legal basis for the data processing is the fulfillment of our contractual obligations (Art. 6 para. 1 lit. b GDPR) and, in individual cases, the fulfillment of our legal obligations (Art. 6 para. 1 lit. c GDPR) as well as your Consent (Art. 6 para. 1 lit. a GDPR).

d) Marketing

Insofar as you have also given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.

Direct Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.

Duration of data storage

We only store personal data for as long as it is necessary for the purposes for which it is processed or for as long as any consent you have given us has been revoked by you. Insofar as statutory retention obligations must be observed, the storage period for certain data may be up to 7 years, irrespective of the processing purposes.

Obligation to provide Personal Data

You are not obliged to provide us with Personal Data. However, depending on the individual case as described above, the provision of certain Personal Data may be necessary for the provision of the services. If you do not provide us with this Personal Data, we may not be able to provide the requested service.

Do Not Sell

We do not sell data to third parties.

Authorisations and Access

We may request permission to store your APP data including your Internet Connection and Network, Camera, Microphone, Messenger, Photos and Gallery of your device. The legal basis for data processing is our legitimate interest and the provision of contractual or pre-contractual measures. You can deny access on your device via the Settings/Notifications/ options of your device; however, this means that our APP may not function as intended.

Push messages

When you use the app, you will receive so-called push messages from us, even if you are not currently using the App. These are messages that we send you as part of the performance of the contract. You can adjust or stop receiving push messages at any time via the device settings of your device.

Transfer of personal data

We will not disclose or otherwise distribute your personal data to third parties unless this:

• is necessary for the performance of our services,

• you have consented to the disclosure,

• or the disclosure of data is permitted by relevant legal provisions.

However, we are entitled to outsource the processing of your personal data in whole or in part to external service providers acting as processors within the framework of the DOPPA and GDPR. External service providers support us, for example, in the technical operation and support of the platform, data management, the provision and performance of services, marketing, as well as the implementation and fulfillment of reporting obligations.

The service providers commissioned by us however will process your data exclusively in accordance with our instructions and we remain in accordance with the DOPPA and the GDPR responsible for the protection of your data. Doing so we always make sure that service providers commissioned by us are carefully selected, follow strict contractual regulations, technical and organizational measures, and additional controls by us.

We may also disclose Personal Data to third parties if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or proceedings at home or abroad or to fulfill our legitimate interests.

Automated decision-making

Automated decision-making including profiling pursuant to Art. 22 (1) and (4) GDPR does not take place at Guru.

Your data subject rights

DOPPA Rights

As a Delaware Resident or Citizen, you may have the right to request, twice in a 12-month period, the following information about the Personal Data we have collected about you during the past 12 months:

• the categories and specific pieces of Personal Data we have collected about you;

• the categories of sources from which we collected the Personal Data;

• the business or commercial purpose for which we have collected or sold the Personal Data;

• the categories of third parties with whom we have shared the Personal Data; and

• the categories of Personal Data about you that we have sold or disclosed for a business purpose, and the categories of third parties to whom we old or disclosed that information for a business purpose.

GDPR Rights

Every data subject has:

• the right to information according to Art. 15 GDPR,

• the right to rectification according to Art. 16 GDPR,

• the right to deletion according to Art. 17 GDPR,

• the right to restriction of processing pursuant to Art. 18 GDPR, and

• the right to data portability under Art. 20 GDPR.

Furthermore, you can revoke consent, in principle with effect for the future.

Furthermore, you have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR). We would, however, appreciate the chance to deal with your concerns before you approach a data protection supervisory authority.

Finally, you also have a right to object according to Art. 21 GDPR. This applies, on grounds relating to data processing on the basis of my legitimate interest and also to profiling.

If you object, we will no longer process your Personal Data unless we can demonstrate compelling legitimate reasons for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

Please contact us at any time with questions and suggestions regarding data protection and to enforce your rights as a data subject.

We encourage you to contact us if you have any information requests, requests for information or objections about data processing or concerns. However, you also have the right to file a complaint with your local supervisory authority. However, we would appreciate it if you would contact us with your concern before turning to a supervisory authority.

Security

State-of-the-art internet technologies are used to ensure the security of your data. During the online enquiry process, your details are secured with SSL encryption. For secure storage of your data, the systems are protected by firewalls that prevent unauthorized access from outside. In addition, technical and organizational security measures are used to protect the personal data you have provided against accidental or intentional manipulation, loss, destruction, or access by unauthorized persons.

Updating your information

If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so within your account or by contacting us using admin@myguru.app.

Withdraw your consent

You may withdraw your consent and request us to stop using and/or disclosing your Personal Data for any or all purposes by submitting your request to us using admin@myguru.app.

Please note that your withdrawal of consent will not prevent us from exercising our legal rights (including any remedies) or undertaking any steps as we may be entitled to at law.

Changes and updates

We kindly ask you to regularly inform yourself about the content of our Privacy Policy and Privacy Policy. We will amend our Privacy Policy and Privacy Policy as soon as changes to the information processing activities we carry out make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g., consent) or other individual notification.

Concerns and Contact

If you have any concerns about a possible compromise of your privacy or misuse of your personal information on our part, or any other questions or comments, you can contact us using admin@myguru.app.

This Privacy Policy was last updated on Thursday, December 15, 2022