We recommend that you read this Privacy Policy in its entirety to ensure you are fully informed; if you only want to access a particular section, click the relevant link in the navigation section on the left hand side to jump to that section.

Overview

Gustav Technologies, Inc., doing business as Gustav VMS, Candidately and World Staffing Summit collectively referred to as the Gustav Services (“Gustav Services,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains who we are, how we collect, use and share personal information about you and how you can exercise your privacy rights. Please read this Privacy Policy to understand how we collect and use your personal data, for example when you contact us, visit or use one of our websites, applications, portals, or other parts of our network (each a “Site”), apply for a job, or use our products and services, regardless of how you access them. This Privacy Policy describes (unless a different privacy notice is displayed) our privacy practices regarding the personal information we collect from individuals in the usual course of business, including when you:

Visit any of our websites (such as https://hellogustav.com/, https://www.candidate.ly/, or https://www.worldstaffingsummit.com/ ); visit our social media pages; receive communications from us; or register for, attend and/or otherwise take part in any of our events, tutorials, webinars or contests (collectively “Visitors”);

Register to or otherwise use any of the Gustav Services as a team member or employee of one of our Customers (collectively “Users”), when we act as a controller of your Personal Information; and

Submit a job application or inquiry directly to Gustav Technologies, Inc. (rather than using our platform), you may provide us with a copy of your resume or other relevant information. We may use this information for the purpose of assessing your application or inquiry. We may also keep this information on file to contact you about future opportunities, unless you ask us not to do this. Please note that personal data collected from our employees is subject to our internal employee privacy policy and not this Policy. Please also note you may be given the opportunity to apply for job openings online through an applicant tracking system operated by a third party which shall collect relevant information related to a job application or inquiry.

"You" may, depending on the context, be a Visitor, a User or an Applicant of one or more of the Gustav Services.  

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Definitions and interpretation

Data: Collectively all information that you submit to Gustav Technologies, Inc. via our websites and by using the Gustav Services. This definition incorporates, where applicable, the definitions provided in the European Union’s 2018 General Data Protection Regulation (GDPR);

Credit & Debit Card Data: We rely on third parties to process your transactions. We do not store credit card details nor do we share customer details relating to financial data with any 3rd parties; 

Cookies: A small text file may be placed on your computer by our websites and Gustav Services when you visit certain parts of our websites and/or when you use certain features of the Gustav Services. Details of the cookies used by us are set out in the clause “Cookies and Similar Tracking Technologies” below.

UK and EU Cookie Law: the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 and the European Union’s 2018 General Data Protection Regulation;

User or you: any third party that accesses our websites or Gustav Services and is not either (i) employed by Gustav Technologies, Inc. and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Gustav Technologies, Inc. and accessing the our websites or Gustav Services in connection with the provision of such services; and

Websites: the websites that you are currently using such as https://www.candidate.ly/ https://www.hellogustav.com/, https://www.worldstaffingsummit.com/ and any sub-domains of this sites unless expressly excluded by their own terms and conditions.
 

In this privacy policy, unless the context requires a different interpretation:

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• the singular includes the plural and vice versa;
• references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
• a reference to a person includes firms, companies, government entities, trusts and partnerships;
• “including” is understood to mean “including without limitation”;
• reference to any statutory provision includes any modification or amendment of it;
• the headings and subheadings do not form part of this privacy policy.

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About us

Gustav Technologies, Inc. offers cloud-based software-as-a-service products and services for the recruiting and staffing industry, including but not limited to software that helps to distribute jobs to recruiting and staffing companies, receiving and reviewing submitted candidates, managing the communication between each staffing company, reviewing performance KPIs, sending candidate resumes/CVs to clients, managing resumes/CVs, as well as other services including but not limited to educational events and webinars.

The following products and services are collectively referred to as the “Gustav Services” and include but are not limited to:

Candidately - a software that supports staffing and recruiting teams with candidate presentation and candidate marketing.

Gustav VMS -  a vendor management software that enables staffing and recruiting firms to manage the distribution of jobs and candidate submittals to and from their sub-vendors and partners.

World Staffing Summit - an online conference for staffing and recruiting professionals.

If you are resident in the European Economic Areas ("EEA"), UK or Switzerland, the controller of your Personal Information that we process for the purposes described in this Privacy Policy is Gustav Technologies, Inc., (doing business as Gustav VMS, Candidately and World Staffing Summit).

Status Determination

Gustav Technologies, Inc. is both a Controller and a Processor, depending on the circumstance.

Gustav Technologies, Inc as the Controller of Data‍

If you are a Customer, you (or your team administrator) may provide certain Personal Information to us through the Gustav Services - for example, when you register for an account to access and use the Gustav Services, when you consult with customer support, send us an email or communicate with us in any way (for example, to make a support request). You have the ability to access and modify your data when it is on our platform. Learn more about what type of data we collect in the section “What information do we collect”.

Gustav Technologies, Inc as the Processor of Data‍

Customers of Gustav Technologies, Inc. are organizations who use the Gustav Services to distribute jobs to recruiting and staffing companies, receiving and reviewing submitted candidate resumes, managing the communication between each staffing company and sending candidate resumes/CVs to clients. Gustav Technologies, Inc. processes Personal Information in these services only according to our Customer's and their User's instructions. If you have questions about Personal Information that was entered into the Gustav Services used by one of our Customers, or want to exercise any of your rights regarding your Personal Information, our Customer contract requires that we redirect your inquiry back to that Customer.  This Privacy Policy does not apply to the Personal Information we process as a service provider or processor on behalf of our Customers.  

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Gustav Technologies, Inc. is not responsible for the privacy or security practices of our Customers, which may differ from those set out in this Privacy Policy. Please review the relevant Customer's privacy policy to understand more about their data processing activities.

Our commitment to privacy

Gustav Technologies, Inc. follows these principles in order to protect your privacy:

• We do not collect any more Personal Information than is necessary to provide the Services or to fulfill our legitimate business purposes;

• We only use your Personal Information for the purposes we specify in this Privacy Policy, unless you are notified otherwise;      

• We do not keep your Personal Information after it is no longer needed; and

• Other than as specified in this Privacy Policy, we do not share your Personal Information with third parties and are not in the business of selling your Personal Information.

What Information do we collect

The information we collect depends on the ways you interact with the Gustav Services and the choices you make (including your privacy settings), the products and features you use, your location and applicable law.

A. Information We Collect

(i) Information You Provide to Us

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Visitors

‍When a Visitor to our website contacts us and/or registers for information, content or an event sponsored by Gustav Technologies, Inc., we will collect certain personal information so that we may fulfill the Visitor’s request or keep in touch with them in connection with our sales and marketing activities (always in accordance with a Visitor's marketing preferences). The Personal Information we collect and we may have collected in the past twelve (12) months include:

• Identifiers, such as your name and business e-mail address;
• Professional or employment-related information, such as company name, job level, functional role and title;
• Inferences, such as your contact preferences; and
• Any other information you provide to us when completing any "free text" boxes in our forms or when you interact with us in the context of troubleshooting and support.

‍Users‍

If you are a User, you (or your team administrator) may provide certain Personal Information to us through the Gustav Services - for example, when you register for a Gustav VMS or Candidately account to access and use the Gustav Services, when you consult with customer support or send us an email or communicate with us in any way (for example, to make a support request).

The Personal Information we collect may include:

• Business information (such as your name, job title, the person you report to, phone number, email address and country);
• Marketing information (such as your contact preferences);
• Account log-in credentials (such as your email or username and password when you sign up for an account with us and the unique User/ team ID assigned to you in our systems);
• Troubleshooting and support data (which is data you provide or we otherwise access in connection with support queries we receive from you. This may include, for example, contact or authentication data, the content of your chats and other communications with Gustav Technologies, Inc., and the product or service you are using related to your help inquiry); and
  

• Billing information (including your credit card numbers and associated identifiers, billing address and background information, but only where you pay for the Gustav Services).

If you ever communicate directly with us, we will maintain a record of those communications and responses.

‍(ii) Information We Collect Automatically

Visitors

‍As is true of most websites, when you visit our sites or interact with our emails, we gather certain technical information from your browser or device automatically and store it in log files. In some (but not all) countries, including countries in the European Economic Area ("EEA"), UK and Switzerland, this information is considered  Personal Information under data protection laws. To the extent that this automatically-collected data includes, or is linked to, Personal Information, we will treat the data in accordance with this Privacy Policy.  

This information we collect includes:

• Identifiers, such as your internet protocol (IP) addresses and browser type; and
• Internet or other electronic network activity, such as your internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

We use this information to analyze trends, to improve and personalize our marketing activities and websites, to administer our websites and guarantee their security and continued proper functioning, to track Visitors’ movements around the website and to gather non-identifiable, demographic information about our user base as a whole. We may link this automatically-collected data to Personal Information provided by Visitors, or to other publicly available information hosted on the internet, so that we can better gauge our Visitors’ needs and provide specific information to best serve them.

In some cases, we may use cookies and related technologies to collect or manage certain information from your browser and computer. Please see the section on Cookies below for more information.

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Users

‍When you use or interact with the Gustav Services, we automatically collect or receive certain information through our Services (for example in log files) and through other technologies (such as cookies) about your device and usage of the Gustav Services. In some (but not all) countries, including countries in the European Economic Area ("EEA"), UK and Switzerland, this information is considered 'personal data' under data protection laws. Please see the section on Cookies below for more information.

The information we collect includes:

Log and usage data, which is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use the Gustav Services and which we record in log files. This log data may include the Internet Protocol (IP) address, device information, browser type and settings and information about your activity in the Services (such as the date/ time stamps associated with your usage, pages and files viewed, searches and other actions you take (for example, which features you use), device event information (such as system activity, error reports and hardware settings).

Device data, such as information about your computer, phone, tablet or other device you use to access the Gustav Services. This device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system and system configuration information.

Location data, such as information about your device's location, which can be either precise or imprecise. How much of this information we collect depends on the type and settings of the device you use to access the Gustav Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address).  You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Gustav Services.

This information is used to:

• maintain the security of the Gustav Services;
• provide necessary functionality;
• improve performance of the Gustav Services;
• assess and improve your experience of the Gustav Services;
• review compliance with applicable usage terms;
• identify future opportunities for development of the Gustav Services;
• assess capacity requirements;
• identify customer opportunities and for the security of Gustav Technologies, Inc. generally (in addition to the security of the Gustav Services); and
• analyze overall trends, to help us provide and improve the Gustav Services, and to improve their security and proper functioning. 

(iii) Information We Collect from Third Parties

‍In order to enhance our ability to provide relevant marketing, offers and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, as well as from other third parties. This information may include your:  mailing address, job title, functional role, business email, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, social media URLs and custom profile.  We process this data for the purposes of: updating our records; targeted advertising; event promotion; optimizing our sites and the Gustav Services; for our sales and marketing activities, including to send marketing emails.

How do we use your Personal Information?

Gustav Technologies, Inc. processes personal information for the following business and commercial purposes, and if you are a resident in the EEA or UK, on the legal basis identified below:

Providing our websites, apps and Gustav Services: In reliance on our legitimate interest, we process your personal information to operate and administer our websites, and to provide, operate, and maintain the Gustav Services;

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Communicating with you about the Gustav Services: We may send you service, technical and other administrative or technical email, messages and other types of notifications (such as distribution and product updates and product patches and fixes) in reliance on our legitimate interests in administering the Gustav Services and providing certain features. These communications are considered part of the Gustav Services and in most cases you cannot opt-out of them.  If an opt-out is available, you will find that option within the communication itself;

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Providing necessary functionality: We process your personal information in reliance on our legitimate interest to provide you with the necessary functionality required during your use of our websites and Gustav Services.

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Transactional considerations: We process your personal information to complete transactions, and send you related information, including purchase confirmations and invoices, to perform our contract with you and to the extent necessary in reliance on our legitimate interest;

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Handling contact and support requests: If you fill out a “Contact Us” web form or request support as a User, or if you contact us by other means including via a phone call, we process your Personal Information to perform our contract with you and/or (if we have not entered into a contract with you) to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you;

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Administering Events: We process your personal information to plan and host events or webinars for which you have registered or that you attend, including sending related communications to you, billing, registration and to connect you with other event attendees, to perform of our contract with you, or to the extent necessary for our legitimate interests in fulfilling your requests to attend any such events;

‍Developing and improving our websites and services:  We process your Personal Information to analyze trends and to track your usage of and interactions with our websites, marketing activities and Gustav Services to the extent it is necessary for our legitimate interest in developing, improving and troubleshooting our websites, marketing activities and the Gustav Services and providing you with more relevant content and service offerings, or where necessary, in reliance on your consent;

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Sending marketing communications: We will process your Personal Information for marketing purposes in accordance with your preferences, such as to communicate with you via email, SMS or telephone about services, features, surveys, newsletters, promotions or events we think may be of interest to you and/or to provide other news or information about Gustav Technologies, Inc. and/or our select partners, in each case in reliance on our legitimate interest in conducting direct marketing or where necessary with your consent. Please see the "Your Privacy Rights" section below, to learn how you can control the processing of your Personal Information by Gustav Technologies, Inc. for marketing purposes;

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Displaying personalized advertisements and content: We process your Personal Information to conduct marketing research, advertise to you, provide personalized information about us on and off our websites and to provide other personalized content based upon your activities and interests to the extent it is necessary for our legitimate interest in supporting our marketing activities or advertising the Gustav Services or, where necessary, to the extent you have provided your prior consent (please see the "Your Privacy Rights" section, below, to learn how you can control how the processing of your Personal Information for personalized advertising purposes);

Promoting the security of our websites and services: To the extent necessary for our legitimate interests in promoting the safety and security of our websites and services, we use your Personal Information to investigate and prevent fraudulent transactions, unauthorized access to the websites, Gustav Services, and other illegal activities;

For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products and features, enhancing, improving or modifying our products and services, identifying usage trends and expanding our business activities in reliance on our legitimate interests; and

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Complying with legal obligations: We process your Personal Information when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Information to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our websites, the Gustav Services, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests.

Reviewing compliance with applicable usage terms: We process your Personal Information to review compliance with our contract with you or your organization (where applicable) to the extent that it is in our legitimate interest to ensure adherence to the relevant terms; and

Other purposes: We will process your Personal Information for other purposes about which we notify you in advance, or for which we receive your consent.

What Information We Share or Disclose to Others?

Gustav Technologies, Inc. will not share Personal Information, or otherwise make your Personal Information available to any other parties except as provided in this Privacy Policy. Parties with whom we may share your Personal Information, pursuant to any applicable agreements, include:

Event Co-Sponsors: If you sign up for an event or content that is co-hosted by Gustav Technologies, Inc. and one of its partners or co-sponsors, your  Personal Information may be shared with that partner or co-sponsor. Please see our partner or co-sponsors’ privacy policies for further information about how they use Personal Information. If you do not wish to have your information shared with partners or co-sponsor please send us a message to team@hellogustav.com.

Legal or regulatory bodies and agencies: Gustav Technologies, Inc. will share your information, including Personal Information, in order to respond to investigations, court orders, legal processes, or to investigate prevent or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person, violations of our Terms of Service, or as otherwise required by law. If Gustav Technologies, Inc. is required by law or an order of a court of competent jurisdiction to disclose your information, we will promptly notify you of this requirement, if permitted by the court or applicable law, so that you may seek a protective order or other appropriate relief.

Service providers: In order to provide our websites, the Gustav Services to you and undertake our marketing and business activities, it may be necessary for us to disclose your information to contracted third parties and service provider partners who perform certain functions on our behalf.  Examples include payment providers (to authorize, record, settle and clear payment card transactions); cloud hosting providers (to provide data storage and processing services); communications providers (to process new queries and to manage our emails); and analytics companies to perform analysis. These third-party service providers or vendors may use data we provide to them only as instructed by Gustav Technologies, Inc. Please view a full list of our Sub-processors here.

Business transfers: If Gustav Technologies, Inc. is involved in a merger, acquisition, or sale of all or apportion of its assets, Personal Information may be transferred to the acquiring person or entity, in which case you will be notified via email and/or a prominent notice on our website of any such change in ownership or uses of Personal Information, as well as any choices you may have regarding Personal Information.

Links To Third Party Websites

Our websites and Gustav Services include links to other websites whose privacy practices may differ from those of Gustav Technologies, Inc. If you submit information to any of those sites, your information is governed by the privacy policies that apply to those sites. This privacy policy does not extend to your use of such websites. We encourage you to carefully read the privacy policy of any website you visit.

How We Protect Your Information

All of your Personal Information remains private and confidential. The security of your Personal Information is important to us. When you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL).

Your data consists of things like your user name, notifications, passwords, linked accounts like Google or Slack, chat messages, and so on. The majority of this data is stored on an encrypted database at both rest and in-transit within AWS. Access to this server is restricted.

Gustav Technologies, Inc. maintains a comprehensive written information security program that complies with applicable law and generally accepted industry standards. Our program includes appropriate administrative, technical and physical safeguards, procedures and practices to protect Personal Information submitted to us, both during transmission and once we receive it. No method of transmission over theInternet, or method of electronic storage, however, is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our website, the Gustav Services, web applications owned and operated by Gustav Technologies, Inc., or the Gustav Services, please contact us using the contact information below.

Gustav Technologies, Inc. and its representatives will never request your account credentials. You should never share your account information, including your username and password, with anyone else. We recommend that you use a unique password for your Gustav Services account that is not associated with other websites. You should check your Gustav Services account regularly to ensure that your Personal Information has not been tampered with or altered. Any suspicious activity regarding your account, including automated messages or calls from parties you cannot identify, should be reported to your site administrator and Gustav Technologies, Inc. using the contact information below.

For more information about Security at Gustav Technologies, Inc please visit our Security page.

Social Media Features

Our websites may use social media features, such as the Facebook “like” button, the “Tweet” button and other sharing widgets (“Social Media Features”). You may be given the option by such Social Media Features to post information about your activities on a website to a profile page of yours that is provided by a third-party social media network in order to share with others within your network. Social Media Features are either hosted by the respective social media network or hosted directly on our websites. To the extent the Social Media Features are hosted by the respective social media networks and you click through to these from our website, the latter may receive information showing that you have visited our website. If you are logged in to your social media account, it is possible that the respective social media network can link your visit to our websites with your social media profile. Your interactions with Social Media Features are governed by the privacy policies of the companies providing the relevant Social Media Features.

Your Privacy Rights

When acting as a controller, and depending on your location, your jurisdiction, and subject to applicable law, you may have the rights below with regard to the Personal Information we control about you. We will respond to your requests within the appropriate timeline under applicable law.

The right of access: You have the right to request that we disclose what Personal Information we have collected, used and disclosed about you. You can do so at any time by contacting us using the contact details provided under the "How to Contact Us" heading below.

The right to erasure: You have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions. You can do so at any time by contacting us using the contact details provided under the "How to Contact Us " heading below.

The right to rectification: You have the right to request that Gustav correct any information you believe is inaccurate. You also have the right to request Gustav Technologies, Inc. to complete the information you believe is incomplete. You can do so at any time by contacting us using the contact details provided under the "How to Contact Us " heading below.

The right to restrict processing: You have the right to request that Gustav Technologies, Inc restrict the processing of your personal data, under certain conditions. You can do so at any time by contacting us using the contact details provided under the "How to Contact Us " heading below.

The right to object to processing: You have the right to object to Gustav Technologies, Inc.’s processing of your personal data, under certain conditions. You can do so at any time by contacting us using the contact details provided under the "How to Contact Us " heading below.

The right to data portability: You have the right to request that Gustav Technologies, Inc. transfer the data that we have collected to another organization, or directly to you, under certain conditions.You can do so at any time by contacting us using the contact details provided under the "How to Contact Us " heading below.

The right to non-discrimination: You will not receive any discriminatory treatment when you exercise one of your privacy rights.

You can also ask us to correct or update your Personal Information; object to the processing of your personal information; ask us to restrict processing of your Personal Information or request the portability of your Personal Information. Again, you can exercise these rights by contacting us using the contact details provided under the "How to Contact Us " heading below

While you cannot opt out of service-related emails if you are an account holder, as this is an essential part of the Gustav Services, you have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you, or you can contact us using the contact information below.

Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent

You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority.

If your Personal Information has been submitted to us by or on behalf of our Customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable Customer directly. For more information on how your employer uses your Personal Information, please see your employer’s privacy policy.

If you make a request, we have one month to respond to you. If you would like to exercise any of the rights above, please contact us at our email: security@hellogustav.com with the subject line of “GDPR Request”. Emails with any other subject line cannot be guaranteed to be responded to within the same timeframe or recognized as a valid request.

Cookies and Similar Tracking Technologies

Gustav Technologies, Inc. uses a technology called "cookies" to store session information. A cookie is a small amount of data, which often includes an anonymous unique identifier, which is sent to your browser from a website's computers and stored on your computer's hard drive.When you visit our websites, we may collect information from you automatically through cookies or similar technology. For further information, visit allaboutcookies.org.

Before our websites or Gustav Services place Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Gustav Technologies, Inc.  to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of our websites and Gustav Services may not function fully or as intended.

How do we use cookies?

Gustav Technologies, Inc. uses cookies in a range of ways to improve your experience on our website, including:

• Keeping you signed in
• Understanding how you use our website
• To improve website usability
• To improve your website experience

What types of cookies do we use?

There are a number of different types of cookies, however, our website uses:

Functionality – we use these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.

Advertising – we use these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Gustav sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

How to manage cookies

You can set your browser to not accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
 

You can choose to delete Cookies at any time; however you may lose any information that enables you to access our websites and Gustav Services more quickly and efficiently including, but not limited to, personalisation settings.
 

It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

‍“DO NOT TRACK” SETTING” Currently, various browsers offer a “do not track” or “DNT” option which sends a signal to websites’ visited by a user about the user's browser DNT preference setting. Gustav does not currently respond to browsers' DNT signals with respect to the website, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. Gustav takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

California Consumer Privacy Act (CCPA) Sale of Personal Information Notice

As mentioned above, Gustav Technologies, Inc. may provide third parties with certain personal information to provide or improve our products and services, for example to deliver products or services at your request. In such cases, we require those third parties to handle the information in accordance with applicable laws and regulations. Gustav Technologies, Inc. does not sell personal information to third parties (pursuant to California Civil Code §§ 1798.100–1798.199, also known as the California Consumer Privacy Act of 2018), nor does Gustav share personal information with third parties for their direct marketing purposes (pursuant to California Civil Code Sec.1798.83).

For more information review our California Privacy Notice.

How to Contact Us

You can exercise your rights yourself or depending on your country or state, you may be able to designate an authorized agent to exercise these rights on your behalf. Please note that to protect your personal information, we will verify your identity by a method appropriate to the type of request you are making. For example, this could include sending an email to an account on record, or asking you to identify a recent transaction or communication. We may also request that your authorized agent sign a declaration under the penalty of perjury attesting to their designation as your authorized agent, and that they have written permission from you to make requests on your behalf. We may also need to verify your authorized agent's identity to protect your personal information.

Please use the contact details below, if you would like to:

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· Access this policy in an alternative format;

· Exercise your rights;

· Contact Gustav Technologies, Inc’s Data Protection Officer;

· Learn more about your rights or our privacy practices;

· Designate an authorized agent to make a request on your behalf; or

· For questions related to this Privacy Policy, or about any of your rights. 

Email us at: security@hellogustav.com with the subject line of “GDPR Request”

or write to us at:

Data Protection Officer

Gustav Technologies, Inc.

61 Greenpoint Ave #684

Brooklyn, NY 11222

United States

Data Retention

We will retain your Personal Information for as long as is necessary to fulfill the services that you have requested, comply with any laws or regulations, resolve disputes, and enforce our agreements. Gustav Technologies, Inc. may retain your data longer for a legitimate business interest where business benefit is not outweighed by your personal rights and freedoms. Data entered into the Gustav Services and processed on behalf of our Customers as a service provider or processor is retained in accordance with any applicable agreement between Gustav Technologies, Inc. and its Customer.

Information About Minors 

Our website and services are not targeted at children under sixteen (16) years of age. As such, Gustav Technologies, Inc. does not process or disclose Personal Information of minors under sixteen years of age. If you believe we have collected personal information about a child under sixteen, please contact us using the How to Contact Us Section above.

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European Representative

If you are an individual in the EU, you can contact Jack Baylor, who is based in the Republic of Ireland and has been appointed as Gustav Technologies, Inc’s representative in the EU pursuant to Article 27 of the GDPR on matters related to the processing of personal data activities that take place in the EU. To make such an inquiry, please write to Jack Baylor at 2 Ashton Place, Gardiner’s Hill, Cork, Ireland.

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International Data Transfers

Your personal information may be transferred to, and processed in the United States and in any other country where Gustav Technologies, Inc. or its affiliates, subsidiaries or third party service providers maintain facilities or personnel.  These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective). We follow applicable data protection laws when transferring personal data. If you are resident in or a visitor from the EEA, United Kingdom or Switzerland, we will protect your Personal Information when it is transferred outside of such locations by processing it in a territory which the European Commission has determined provides an adequate level of protection for Personal Information; or otherwise implementing appropriate safeguards to protect your Personal Information, including through the use of Standard Contractual Clauses or another lawful transfer mechanism approved by the European Commission.  

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Disclaimer

IF YOU USE INFORMATION PROVIDED TO YOU THROUGH GUSTAV SERVICES, LINKS, OR THIRD PARTY SITES YOU DO SO AT YOUR SOLE RISK. INFORMATION PROVIDED THROUGH GUSTAV SERVICES AND ALL RELATED SERVICES IS “AS IS” AND “AS AVAILABLE”. WE EXPRESSLY DISCLAIM, AND YOU WAIVE, ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING, WITHOUT LIMITATION, IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT. 5 WE DO NOT WARRANT THAT INFORMATION PROVIDED TO YOU VIA GUSTAV SERVICES (A) WILL MEET YOUR REQUIREMENTS; (B) BE UNINTERRUPTED, TIMELY, SECURE, OR ERROR-FREE; (C) WILL NOT BE DISCLOSED TO THIRD PARTY USERS OR THEIR EMPLOYEES OR AGENTS, (D) WILL BE ACCURATE OR RELIABLE; OR (D) WILL MEET YOUR EXPECTATIONS. IF YOU ACCESS OR TRANSMIT ANY INFORMATION THROUGH GUSTAV SERVICES YOU DO SO AT YOUR OWN DISCRETION AND YOUR SOLE RISK. YOU ARE SOLELY RESPONSIBLE FOR ANY LOSS OR DAMAGE ARISING OUT OF SUCH ACCESS OR TRANSMISSION.

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Termination of Use

You agree that we may, in our sole discretion, terminate or suspend your access to all or any part of the Gustav Services with or without notice and for any reason. Any suspected fraudulent, abusive or illegal activity may be grounds for terminating your access to and use of the Gustav Services, and if we believe that you have committed such acts, we may report you to appropriate law enforcement authorities.

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Notification of changes

We reserve the right to amend or vary this Policy from time to time to reflect evolving legal, regulatory or business practices. When we update our Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make (which, for minor changes, may include posting the revised Policy to our Site with immediate effect). We will obtain your consent to any material Policy changes if and where this is required by applicable data protection laws.

We encourage you to periodically review this page for the latest information on our privacy practices. We may also place a prominent notice on our website. 

You can see when this Policy was last updated by checking the “last updated” date displayed at the top of this Policy Policy page.

This Policy was last updated June 28th 2021.