Gaugr Privacy Policy

Effective Date: October 1, 2025

Contact: For questions, privacy rights exercise, or requests—email privacy@gaugr.com.

Introduction

Gaugr Holdings LLC ("we," "our," or "us") respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our consumer experience survey application ("Application" or "Service"). By accessing or using our Service, you agree to the practices described in this Privacy Policy. If you do not agree, please discontinue use of our Service.

1. Information We Collect

a. Personal Identifiable Information (PII)

• Name, email address, phone number, mailing address
• Account login credentials (if applicable)
• Payment information (if applicable for incentives/rewards)

b. Survey Data

• Responses you provide in surveys, which may include personal opinions, preferences, or demographic information.

c. Technical & Usage Information

• Device identifiers, IP address, browser type, operating system, and app version
• Location data (if permission granted)
• Log data (access times, pages viewed, interactions)

d. Sensitive Data (Only if Explicitly Provided)

• Health, biometric, racial/ethnic, political, or other sensitive information (only where required and with explicit consent under applicable laws such as GDPR, HIPAA, or local equivalents).

2. How We Use Your Information

We use the information collected for purposes including:

• Administering and analyzing survey responses
• Providing, personalizing, and improving the Service
• Communicating with you about surveys, updates, and rewards
• Ensuring legal compliance and security
• Aggregating and anonymizing data for research and insights

3. Legal Bases for Processing (International Compliance)

We process personal information under the following lawful bases:

• Consent – when you voluntarily provide data or agree to participate in surveys
• Contractual necessity – to deliver survey services you requested
• Legal obligation – to comply with applicable laws and regulations
• Legitimate interests – to improve our services, prevent fraud, and ensure security

4. Sharing of Information

We may share information with:

• Service Providers & Vendors – hosting, analytics, cloud storage, payment processors
• Business Partners – for survey research collaboration (aggregated and anonymized data only, unless explicit consent given)
• Legal Authorities – when required by law, court order, or government regulation
• Corporate Transactions – in case of merger, acquisition, or asset sale

We do not sell personal information to third parties.

5. International Data Transfers

As a global service, your data may be transferred and processed outside your home country, including in jurisdictions that may not provide the same level of data protection. Where applicable, we implement safeguards such as Standard Contractual Clauses (SCCs), adequacy decisions, or data transfer agreements to protect your data.

6. Data Retention

We retain your information only as long as necessary to:

• Fulfill the purposes described in this policy
• Comply with legal, contractual, or regulatory obligations
• Resolve disputes and enforce agreements

Survey responses may be anonymized and retained indefinitely for research purposes.

7. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights:

• Access & Portability – request a copy of your data
• Correction – request corrections of inaccurate data
• Deletion – request deletion of your data ("Right to be Forgotten")
• Restriction – request limits on how we process your data
• Objection – object to processing based on legitimate interests or direct marketing
• Consent Withdrawal – withdraw consent at any time without affecting prior processing
• Opt-Out of Sale/Sharing – where applicable under laws like CCPA/CPRA

To exercise your rights, contact us at: privacy@gaugrholdings.com.

8. Security of Your Information

We use administrative, technical, and physical safeguards to protect personal information, including:

• Encryption in transit and at rest
• Role-based access controls
• Regular security assessments and monitoring

However, no system is 100% secure, and we cannot guarantee absolute security.

9. Children's Privacy

Our Service is not directed toward individuals under the age of 16 (or lower age where permitted by local law). We do not knowingly collect personal data from children. If we learn that we have collected such data without consent, we will delete it promptly.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The updated version will be posted with a new "Last Updated" date. Significant changes will be notified to you directly (via email or app notification).

11. Contact Us

If you have questions about this Privacy Policy or your rights, please contact us:

Gaugr Holdings LLC
Email: privacy@gaugr.com

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