GUT Agency LLC (“GUT,“ “we,“ “our“ or “us“) respects your privacy and is committed to protecting your privacy through its compliance with this privacy policy (the “Privacy Policy”). This Privacy Policy explains our policies and procedures regarding the collection, use, disclosure, and security of certain information that we receive, in particular “personal information“ that can identify you.

This Privacy Policy describes the types of information we may collect from you or that you may provide when you access or use the Sites (as defined in the Terms, as defined below). By accessing and using the Sites, you are accepting the practices described in this Privacy Policy. This Privacy Policy is incorporated by reference into the Terms of Service that govern your access and use any of the Sites (the “Terms“). Capitalized terms used but not otherwise defined herein are defined in the Terms.

This Privacy Policy applies to information we collect when you:

+ Access or use any of the Sites;
+ Register and create an account for the Sites;
+ Send an email, text or other electronic messages through the Sites or to GUT;
+ Submit content through any of the Sites; and/or
+ Through services provided to us or to you by third-party companies, agents or contractors.

This Privacy Policy does not apply to information collected by third parties not controlled by GUT, including through any link that may be accessible from or on the Sites.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your only choice is not to access or use the Sites. By accessing or using any of the Sites, you agree to this Privacy Policy. This Privacy Policy may change from time to time as described in Changes to Our Privacy Policy below.

Minors under the Age of 18

None of the Sites are intended directly for minors under 18 years of age. No one under age 18 may provide any information on or through the Sites. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on or through any of the Sites or any of its features or register on the Sites, use any of the interactive or public comment features of any of the Sites or provide any information about yourself to us, including your name, address, telephone number, email address or any screen name, username you may use or any pictures of you. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 18 without the consent from a parent or legal guardian, please contact us at privacy@gut.agency.

Information We Collect and How We Collect It

We collect or may collect several types of information if you access and use the Sites, including information by which you may be personally identified:

Your Internet Protocol (“IP”) address, including when you create an account (if applicable);

Information that you voluntarily provide if you register, create accounts or fill in forms or applications on or through any of the Sites;

Analytics information when you access and use any of the Sites (see Use of Cookies and Other Tracking Technologies below); and

Information that is about you but individually does not identify you, such as the date and time of your website visit.

We may also collect information from and about you when you:

Report a problem or concern with any of the Sites;

Contact us (records and copies of your correspondence, including email address, or recordings of support calls for staff training and quality assurance purposes); and/or

Carry out transactions through any of the Sites.

We collect this information:

Directly from you when you provide it to us;

Automatically as you navigate through or use any of the Sites; and/or

From third parties, such as our business partners and other third parties that provide us or you with certain services.

Some of the information that we collect automatically may be statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties or you provide to us.

Data Minimization

We take reasonable steps to limit the volume of your personal information that we process to what is reasonably necessary.

How We Use Your Information

We will only use information that we collect about you or that you provide to us, including any personal information, as described in this Privacy Policy to:

Provide the Sites;

Send you news or information about any of the Sites that may be of interest to you (if you have not opted-out);

Publish or distribute any User Content that you provide;

Provide technical and other support to you;

Provide you with notices about any of the Sites, including any changes to the Sites;

Verify your identity and prevent fraud or other unauthorized or illegal activity;

Enhance the safety and security of all of the Sites;

Comply with a legal or regulatory obligation;

In any other way we may describe when you provide information to us; or

For any other purpose with your consent.

Use of Cookies and Other Tracking Technologies

When you use any of the Sites, we collect information from you automatically using cookies, web beacons, and other tracking technologies. We use functional cookies on our websites to deliver the desired functionality and user experience and analytics cookies, including Google Analytics, to collect and analyze aggregate visitor behavior.

This collected information may include the URL of the site you came from, your browser, your IP address, date/time of access, data transferred, pages visited, amount of time on the websites, transactions conducted, and other “clickstream“ data. This information may be used to:

Provide visitors the benefit of not having to re-enter the same data over and over again;

Assist us in our marketing efforts;

Help diagnose technical problems;

Monitor system usage, server and software performance;

Improve system design, create benchmarks and conduct trending analyses; and

Perform statistical analyses and generate data related to how visitors use our websites.

Do Not Track Policy

We do not honor any web browser “Do Not Track“ signals or other mechanisms that allow you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. At present, no universally accepted standards exist on how companies should respond to “Do Not Track“ signals. In the event a final, universally accepted standard is established, we will assess and provide an appropriate response to these signals.

Third-party Responsibilities and Services

GUT may use or partner with third-party companies, agents or contractors for various purposes in connection with our business and operations (“Service Providers“). GUT may share your information with these Service Providers, or they may otherwise have access to your information in the course of performing their responsibilities and providing services. The Service Providers may also transmit cookies to your computer or device when you click on ads or links that appear on or through the Sites.

These Services Providers may have adopted their own privacy policies, which are not subject to control by GUT. You should always review the policies of these Service Providers to make sure that you are comfortable with the ways in which they collect, use, maintain, protect and disclose your information. We do not list our current Service Providers because they change from time to time. If you would like the names of any of the Service Providers, please email us at privacy@gut.agency.

It`s important to guard your privacy when you are online. If the Sites contain links to other websites, this Privacy Policy does not govern those websites. Whether we have posted those links or other organizations, or individuals have, you should read their privacy policies and make an informed decision about whether you want to use those websites or services.

We do not have any control over that or how they collect, use, maintain, protect and disclose your information. Please be aware that cookies placed by third parties may continue to track your activities online even after you are no longer using any of the Sites, and those third parties may not honor “Do Not Track“ requests you have set using your web browser.

Disclosure of Your Information

We have no current intent to sell your personal information without your consent to do so. If that ever changes, we will notify you as described in Changes to Our Privacy Policy below.

We may disclose personal information that we collect, or you provide as described in this Privacy Policy:

To fulfill the purpose for which you provide it;

To Service Providers, contractors and other third parties to support and deliver the Sites but only to the extent necessary for them to provide this support and delivery;

To Service Providers from whom you have elected to receive services;

To a potential or actual buyer, assignee or other successor (including its related advisors and agents) of GUT, including in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of GUT`s equity and/or assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by GUT about users of any of the Sites is among the assets that may be or are actually transferred;

To our affiliates and business partners;

For any other purpose disclosed by us when you provide the information; and/or

With your consent.

We may also disclose your information:

To comply with any court order, law or legal process, including to respond to any government or regulatory request;

To enforce or apply the Terms and other agreements, including for billing and collection purposes; and/or

If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of GUT, our users or others.

Anonymized or Aggregated Information.

GUT may use, share, disclose and sell information that is anonymized or in an aggregated form (i.e., in a form that does not identify you) without restriction so long as it does not violate the Terms, this Privacy Policy or any applicable law.

Choices About the Use of Your Personal Information to Market to You

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your personal information:

If you do not wish for the Sites to use your email address/contact information to market or otherwise promote our own or third parties` products or services to you, you can opt-out through the unsubscribe mechanism at the bottom of marketing emails. This opt-out does not apply to information GUT provides about any of the Sites, for example product updates and transactions.

We do not control third parties` collection or use of your information to serve interest-based advertising. You may be able to opt-out of receiving personalized advertisements from companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance`s Self-Regulatory Principles for Online Behavioral Advertising. For more information about this practice and to understand your options, please visit: http://www.aboutads.info and http://www.networkadvertising.org/choices/. You may also use TRUSTe`s Preference Manager at http://preferences-mgr.truste.com.

Accessing and Correcting Your Personal Information

You may change, correct or delete any personal information that you have provided to us by emailing us at privacy@gut.agency. We may need to verify your identity to make any changes.

Deleting Your Account

You may delete your account (if applicable) at any time by emailing us at privacy@gut.agency. We will need to verify your identity to confirm that you have the authority to delete the account before we delete your account. If you delete your account, you will no longer be able to use your account or access any information related to your activities on your account.

To dispose of personal information, we may anonymize it, delete it or take other appropriate steps. Information may persist in copies made for backup and business continuity purposes for additional time.

Storage and Transfer of Your Information

We may store information that we collect (personal or otherwise) ourselves or in databases and servers owned and maintained by us, our affiliates, agents or Service Providers. If you access or use any of the Sites outside of the United States, information that we collect about you may be transferred to servers inside the United States and maintained in accordance with this Privacy Policy. By allowing GUT to collect information about you, you consent to such transfer and processing of such information without restriction. We may also store some information locally on your computer or other devices. For example, we may store information as local cache so that you can open the Sites and view content faster.

General Data Protection Regulation 2016/679 (“GDPR”) Notice

People who are residents of the European Economic Area (“EEA”) may have additional rights under the GDPR. All residents of the EEA should review our Supplemental GDPR Privacy Notice before using the Sites.

Your California Privacy Rights

Residents of California may have additional rights under the California Consumer Privacy Act of 2018, Cal. Civ. Code §§ 1798.100 – 1798.199, as amended from time to time (“CCPA”). The CCPA permits users of the Sites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. For additional information, please go to the following: https://www.oag.ca.gov/privacy/ccpa.

To make requests to exercise any of your CCPA rights, including related to our disclosure of personal information to third parties, please send an email to privacy@gut.agency or write to us at the contact information below.

How Long We Store Your Personal Information

GUT retains personal information only as long as necessary to fulfill the identified purpose or as permitted or required by law, which may extend beyond the termination of our relationship with you.

We may retain certain information as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally identifiable data, or if required by law. All retained personal information will remain subject to this Privacy Policy.

Note that we will delete your personal information upon your request as described above subject to all applicable provisions of the Terms and this Privacy Policy.

Information Security

We understand that the security of your personal information is important. We provide reasonable administrative, technical, and physical security controls to protect your personal information. However, despite our efforts, no security controls are 100% effective. GUT cannot ensure or warrant the security of your personal information. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures for any of the Sites.

The safety and security of your data also depends on you. Where you have chosen (or we have given you) a password for access to and use of your account, you are responsible for keeping this password confidential. We ask that you not to share your password with anyone.

Changes to Our Privacy Policy

We may make changes to this Privacy Policy from time to time. If we do make any such changes, we will post a notice that this Privacy Policy has been updated on the home pages of the Sites. The date the Privacy Policy was last updated is identified above. You are responsible for ensuring that we have an up-to-date active and deliverable email address for you, and for periodically visiting the Sites and this Privacy Policy to check for any changes. Your continued use, and/or continued use after our efforts to contact you, of any of the Sites, means that you agree to be bound by such changes.

Survival

The policies indicated in this Privacy Policy will remain effective, even if the Terms and the other agreements between us are terminated and you are no longer using any of the Sites.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at privacy@gut.agency or write us at:

GUT Agency LLC

6400 Biscayne Blvd

Miami, FL 33138

Attention: Privacy Officer