Supplemental  Privacy Notice for certain U.S. state residents

This Supplemental Privacy Notice is meant to supplement our general Privacy Policy, and applies to residents of the States of California, Virginia, Colorado, Connecticut, and Utah who have certain privacy rights under the applicable laws in their state (collectively, “Certain State Privacy Laws”)

1. Personal Information We Collect

The Personal Information we collect, and have collected within the last twelve (12) months, is generally described in section 2 of our Privacy Policy, and specifically outlined below:

A.    Identifiers, consisting of an organization name, individual's name, email addresses, physical addresses, online identifier, IP address, phone, emergency contact name and phone numbers, any additional information you provide when answering customized registration questions, and, with respect to Providers, your “about us description”, slogan, website, social media links, and organization logo.

         B.    Personal information categories, consisting of address, phone number, credit card (via Stripe), payment billing information, saved payment method metadata consisting of brand, last 4 digits, expiration month/year, and Guildara login information. 

         C.    Protected classification characteristics under Certain State Privacy Laws, consisting of a participant's age (which is required), number of adults and minor children living in the household and household income (required when applying for scholarships), and medical condition, allergies and concerns (concerns provided by you via open text), gender, school state, school district, school name, student ID (all of which are optional).

         D.    Commercial information, consisting of your order history, scholarship redemptions, refunds, and, with respect to Providers, payouts.

         E.     Internet or other similar network activity, consisting of your usage history within our website, analytics, session replay, page views, clicks, and browser information.

         F.     Geolocation data, consisting of your physical address and information derived from IP.

         G.    Sensory data, consisting of images uploaded by Providers

         H.    Professional or employment-related information, consisting of any professional descriptions you may provide on our platform. 

         I.      Non-public education information you may provide, consisting of your school, state, school district, school name, student ID (all of which are optional).

         J.      Audio, electronic, visual, or similar information, consisting of some customer-support calls and sales calls, and images that may be uploaded by Providers.

K.    Inferences drawn from other personal information, consisting of recollected information regarding feature usage based on our analytics. 

We obtain this Personal Information from the various sources described in section 2 of our Privacy Policy. 

2. Uses and Disclosure Personal Information.  

With some exceptions related to marketing and advertising, we use, and have used in the past twelve months, each of the categories of Personal Information for one or more of the purposes described in section 3 of our Privacy Policy.  However, other than Provider name, images that may be uploaded by Providers, activity details, Provider social media information, and information contained in Provider reviews left by Families, we do not use the categories described under A, B, C, D, G, I or J for the marketing and advertising purposes stated under section 3(B) of our Privacy Policy. 

In addition, we may disclose, and have disclosed in the past twelve months, each of the categories of Personal Information for business purposes, as described in section  4 of our Privacy Policy, for the purposes outlined in that section.  However, other than Provider name,  images that may be uploaded by Providers, activity details, Provider social media information, and information contained in Provider reviews left by Families, we do not use the categories described under A, B, C, D, G, I or J for the marketing and advertising purposes stated under sections 4(B) and 4(C) of our Privacy Policy.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes other than those set forth in our Privacy Policy without providing you notice.

3. Sale and Sharing of Personal Information

We do not sell or share Personal Information to third parties or any of our affiliates as those terms are generally defined; we do not sell or share Personal Information in exchange for money or other payment.  However, some of the ways use and share certain Personal Information provided by you may be considered sharing under Certain State Privacy Laws.  Specifically, through cookies and other technologies, we collect certain Personal Information and share the same with advertising partners for targeted marketing and analytic purposes, to provide Giuldara and other Provider advertisements that may be of interest to you. 

We do not have actual knowledge that we sell or share Personal Information provided by you of anyone under the age of 16.

4. “Do Not Sell or Share” Personal Information.   If you do not want us to sell or share your Personal Information provided by you, please review our “Do Not Sell or Share My Personal Information” page.  Opting out of selling or sharing Personal Information will not opt you out of the use of previously sold or shared Personal Information.

6. Retention of Personal Information.  

We keep the Personal Information described above for as long as necessary or permitted for the purposes described in our Privacy Policy Notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:

     a. Your Personal Information is reasonably necessary to provide our services and operate our business; to analyze and improve our services and business model; or such information is needed in connection with another business purpose for which the Personal Information was collected;

b. We need to retain your Personal Information for safety, security and/or fraud prevention;

c. Your Personal Information is reasonably necessary to protect or defend our rights or property; or 

d.   We are otherwise required or permitted to keep your Personal Information pursuant to applicable law. 

When we use Personal Information for more than one purpose, we will retain it until the purpose with the latest period expires. Except as required by applicable law, we will not be obligated to retain your Personal Information for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.  We take reasonable measures to destroy or de-identify Personal Information in a secure manner when it is no longer required. 

7. Your Rights and Choices

Certain State Privacy Laws may provide you with specific rights regarding your Personal Information. If you are a resident of a state subject to Certain State Privacy Laws, you may exercise the following rights:  

a. Access to Specific Information and Data Portability Rights.  You have the right to request that we disclose certain information to you about our collection and use of your Personal

Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

i. The categories of Personal Information we collected about you;

ii. The categories of sources for the Personal Information we collected about you;

iii. Our business purpose for collecting or selling that Personal Information;

iv. The categories of third parties with whom we share that Personal Information;

v. The specific pieces of Personal Information we collected about you;

vi. The categories of Personal Information sold, the categories of third parties to whom the Personal Information was sold, by category or categories of Personal Information for each third party to whom the Personal Information was sold; and

vii. The categories of Personal Information disclosed for business purposes.

b. Deletion Request Rights.  You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

c. Opt-Out Request Rights.  You have the right to opt-out of the sharing of your Personal Information that we collected from you. Once we receive and confirm your verifiable consumer request to delete your Personal Information, we will delete (and direct our service providers to delete) your Personal Information from our records and stop sharing it, unless an exception applies.

d. Right to Request Correction of Inaccurate Information.  You have the right to request correction of inaccurate information. Once we receive and confirm your verifiable consumer request, we will correct any inaccurate information identified in the request our records, unless an exception applies.

e. Right to Appeal.  If you are a Virginia, Colorado or Connecticut resident and we were unable to fulfill your request, we will notify you. You may

appeal our decision by emailing us at legal@guildara.com within fourteen calendar days, including “Appeal Request” in the subject line, with a detailed reason for your appeal, as well as your state of residence. If you are dissatisfied with our decision on your appeal, you may contact your applicable state Attorney General.

8. Exercising Your Rights.

To exercise the rights described above, please submit a verifiable consumer request to us by submitting an email request to legal@guildara.com. 

Only you or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.  The verifiable consumer request must:

a. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.

b. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.  We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request, to process and fulfill the request, and for necessary record keeping.

9. Process Used to Verify an Access and/or Deletion Request.

You will be required to submit 4 pieces of information including your name, address, email, and phone number. We will use this information to search our systems and determine if we have Personal Information about you. If we are able to locate Personal Information about you, we will fulfill your access and/or deletion request. If we are not able to match all 4 pieces of information you submit, we may provide you with a report that includes the categories of Personal Information we collect, use, disclose, and sell.

10. Response Timing and Format

We try to respond to a verifiable consumer request within 45 days of its receipt, unless a shorter time period applies under Certain State Privacy Laws. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. 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 Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

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.

11. Non-Discrimination

We will not discriminate against you for exercising any of your rights under Certain State Privacy Laws.