Privacy Policy

Effective Date: May 2026

Effective date: 10.05.2026
Last updated: 20.08.2026

This Privacy Policy explains how Gugu collects, uses, stores, shares, and protects personal data when you use the Gugu app, website, and related services.

1. Who we are

The data controller for personal data covered by this Privacy Policy is:

Guguworks LLC
1209 Mountain Rd PL NE Ste N

87110, Albuquerque,

NM, United States
Email: privacy@guguworks.com

2. Who Gugu is for

Gugu is intended for parents, legal guardians, and authorized caregivers. Gugu is not intended for direct use by children.

If you submit information relating to a child, including recordings, labels, notes, or metadata, you represent that you are authorized to do so.

3. Categories of data we collect

Depending on how you use Gugu, we may collect the following categories of data:

a. Account data

name
email address
sign-in credentials or authentication tokens
subscription tier
account preferences
country or region

b. Device and technical data

device type
operating system
app version
language
time zone
IP address
crash data
diagnostic logs
session and request metadata

c. Audio and audio-related data

raw audio recordings you create, upload, or save
timestamps and clip duration
audio features
spectrograms
embeddings
labels and annotations
model outputs, classifications, and confidence scores
result history and related metadata

d. Support and communications data

support emails
support chat or help tickets
feedback
survey responses
bug reports

e. Payment and subscription data

Where purchases are made through Apple or another platform, we may receive limited subscription or transaction-status information, but payment card information is usually handled by the platform provider.

4. How we collect data

We collect data:

directly from you when you create an account, submit audio, save history, contact support, or change settings;
automatically from your device and app usage;
from platform providers such as Apple when needed for account, subscription, or app-delivery functionality; and
from service providers acting on our behalf.

5. Why we use data

We use personal data to:

a. Provide the core service

We process uploaded audio and related metadata to generate results, display history, and operate the app.

b. Maintain and secure the service

We use data to authenticate accounts, prevent abuse, detect fraud, monitor reliability, debug technical issues, and protect the Services.

c. Store history and saved items

If you use history or save recordings, we store related audio and result data in your account so you can review them later.

d. Improve product performance

We use diagnostic, usage, and operational data to improve speed, stability, reliability, and usability.

e. Help improve Gugu

Gugu may provide a setting called “Help improve Gugu.”

When this setting is enabled, we may store uploaded recordings, results, labels, annotations, spectrograms, embeddings, confidence scores, and other derived audio features to test, train, evaluate, and improve Gugu’s baby-sound models and related services.

Unless otherwise stated in the app or required by local law, Help improve Gugu may be enabled by default. You can disable it in the app settings.

If you disable Help improve Gugu, Gugu still uploads audio for analysis, but raw recordings should not be kept after the result is generated or used for model improvement or ordinary trained review, except for short-lived technical processing, security, debugging, retries, legal compliance, or protection of the Services.

f. Trained review

When Help improve Gugu is enabled, the improvement process may include automated processing and review of selected recordings or related results by trained personnel or service providers for labeling, quality assurance, support, safety, and model improvement.

If Help improve Gugu is disabled, raw recordings should not be used for ordinary trained review, except where necessary for support, security, debugging, legal compliance, safety-related investigation, or protection of the Services.

g. Legal and compliance purposes

We may use data to comply with law, enforce our Terms, resolve disputes, and protect rights, safety, and security.

6. Audio processing and data-use levels

Gugu currently processes audio on its servers. When you submit a recording for analysis, the full audio recording is sent from your device to Gugu’s servers or infrastructure providers.

The server processes the recording, creates technical acoustic representations such as log-mel or similar model-input features, runs Gugu’s analysis models, and returns a result to the app.

This means that the original recording leaves your device when you use Gugu’s audio-analysis feature.

Your first recording

Your first recording may be processed before you have selected your continuing data-use level.

After Gugu returns the first result, you will be asked to choose between Level 1 and Level 2 before continuing to use the analysis service.

While that choice is pending, Gugu may temporarily retain the original recording and derived acoustic information necessary to complete the analysis and apply your choice.

Pending recordings are not eligible for ordinary model-improvement training, dataset export or trained review before the choice is finalized.

If you do not complete the choice, pending recording data will be automatically deleted after the applicable short retention period.

Level 1 — Improve Gugu without saving the original recording

Under Level 1:

the original audio recording is deleted after processing and any strictly necessary short-lived technical retry period;
Gugu may retain a reduced recording-level acoustic representation derived from the recording;
Gugu may retain related model results, confidence information, labels, user confirmations or corrections, and necessary technical and governance metadata;
retained information may be used for model evaluation, calibration, threshold tuning, training and improvement; and
the recording is not ordinarily eligible for human listening for model-improvement purposes.

The retained derived acoustic information remains recording-level information. We do not treat it as anonymous merely because it does not contain the original waveform.

Level 2 — Full improvement

Level 2 includes the processing described under Level 1.

In addition, Gugu may retain the original audio recording for a bounded period and use it for approved model-improvement purposes, including:

model training and evaluation;
new or alternative audio preprocessing;
re-segmentation or waveform-level processing;
development and testing of future model architectures;
quality analysis and labeling.

Selected Level 2 recordings may also be reviewed or listened to by authorized trained Gugu personnel or contracted service providers for labeling, quality assurance and model improvement.

Access to recordings used for trained review is restricted according to Gugu’s internal access and data-handling controls.

Changing your level

You can view and change your selected data-use level through the available app settings.

If you change from Level 2 to Level 1:

future recordings follow Level 1;
previously retained original recordings become subject to deletion under the applicable deletion process;
ordinary trained-review eligibility ends; and
eligible derived acoustic information may remain where it continues to qualify for Level 1 processing.

If you change from Level 1 to Level 2, the new level applies prospectively. Original recordings that were already deleted cannot be restored.

Withdrawal and deletion

You may request deletion of eligible retained data and, where applicable, withdraw from the model-improvement processing described in this Policy.

A withdrawal prevents new recordings from entering Level 1 or Level 2 model-improvement processing until an eligible level is selected again. Because Gugu does not currently offer an ongoing analysis-only level, withdrawal may prevent further audio analyses until you make a new eligible selection.

Deletion requests may apply, as relevant, to:

retained original recordings;
source audio chunks;
derived acoustic representations;
associated model-improvement metadata;
labels and annotations;
pending trained-review material; and
active model-improvement datasets.

Some limited information may be retained where reasonably necessary for legal obligations, security, fraud prevention, dispute resolution, or rolling backup integrity.

Retention

Gugu retains personal data only for as long as reasonably necessary for the stated processing purpose.

Different retention periods apply to:

first recordings awaiting a privacy-level choice;
temporary raw audio used for Level 1 analysis;
Level 1 derived acoustic information;
Level 2 original recordings;
trained-review queues;
failed, abandoned or incomplete uploads;
operational and security logs; and
backups.

The specific retention periods stated in this Policy will reflect the technical retention limits enforced by Gugu’s production systems.

We periodically review retained model-improvement information and delete or de-identify information that is no longer reasonably necessary for the purpose for which it was retained.

7. Legal bases for processing

Where GDPR, UK GDPR, or similar laws apply, we rely on one or more of the following legal bases:

Contract: processing needed to provide the Services you request.
Legitimate interests: security, fraud prevention, debugging, service administration, and proportionate service improvement.
Consent: where required, including for optional model-improvement uses, optional human review, and certain optional retention or communications choices.
Legal obligation: where processing is necessary to comply with law.

Under GDPR-style regimes, retention should be limited to what is necessary for the stated purpose, and users should be told the retention period or the criteria used to determine it.

8. Retention

We keep personal data only for as long as reasonably necessary for the purposes described in this Policy, unless a longer period is required by law, needed for dispute resolution, or required for security and fraud prevention.

Our retention schedule is:

Raw audio when Help improve Gugu is disabled: raw recordings should not be kept after the result is generated, except for short-lived technical processing, security, debugging, retries, legal compliance, or protection of the Services.
Raw audio when Help improve Gugu is enabled: uploaded recordings may be stored for up to 12 months to test, train, evaluate, and improve Gugu’s models and related services, unless deleted earlier or retained longer where legally required.
Saved recordings and cloud history: kept until you delete them, your account is deleted, or they are removed under our retention rules.
Derived data: spectrograms, embeddings, labels, annotations, outputs, confidence scores, and related metadata may be kept for up to 24 months, unless deleted earlier, de-identified, or no longer needed.
Operational logs, security logs, crash logs, and diagnostics: generally kept for 30 to 90 days, except where longer retention is required for investigations, security, debugging, fraud prevention, or legal compliance.
Backups: deleted data may persist in encrypted backups for a limited rolling period before being overwritten or purged.

We may retain limited information where necessary to comply with law, resolve disputes, enforce our Terms, prevent fraud, protect the Services, or maintain security.

9. Sharing of personal data

We may share personal data with:

cloud hosting, storage, database, and compute providers;
analytics, diagnostics, and crash-reporting providers;
authentication and account-service providers;
customer support providers;
contractors or reviewers helping us provide approved review, labeling, support, or quality workflows;
payment and subscription providers;
professional advisers such as lawyers, auditors, and insurers; and
regulators, courts, law enforcement, or other third parties where required by law or necessary to protect rights, safety, or security.

We do not sell raw audio recordings as data commodities.

10. International transfers

Your data may be processed in countries other than your own. Where required by law, we use appropriate safeguards for international transfers, such as adequacy decisions, contractual safeguards, or other approved mechanisms. The European Commission identifies adequacy decisions, SCCs, and BCRs as recognized GDPR transfer mechanisms.

11. Children and child-related data

Gugu is intended for adult parents and caregivers, not for direct use by children.

Under COPPA, an audio file containing a child’s voice is treated as personal information, and child-directed services or services with actual knowledge of collecting such information have additional obligations.

If we learn that data was provided without appropriate authorization, we may suspend the account and delete the affected data where appropriate.

12. Consumer health and inferred-data notice

Some outputs generated by Gugu may relate to a baby’s likely condition, behavior, or needs. Some U.S. state privacy laws define health-related or inferred health-related data broadly, including data that is inferred or derived by algorithms or machine learning.

Where applicable, we will provide any additional notices or rights required by those laws.

13. Security

We use administrative, technical, and organizational measures designed to protect personal data, including access controls, encryption in transit, restricted permissions, logging, and vendor controls. No method of transmission or storage is completely secure.

14. Your rights and choices

Depending on where you live, you may have rights to:

access your personal data;
correct inaccurate data;
delete personal data;
export certain data;
object to or restrict certain processing;
withdraw consent at any time for optional processing;
manage saved recordings and history; and
lodge a complaint with a supervisory authority.

Privacy notices should explain user rights and provide the relevant contact route.

You can exercise rights by contacting us at [privacy@guguworks.com].

15. Consent choices

You can manage available privacy and data-use settings in the app.

Help improve Gugu

Help improve Gugu controls whether uploaded recordings may be stored and used to improve Gugu’s models and services. When enabled, this may include automated model improvement and review of selected recordings or related results by trained personnel or service providers.

Unless otherwise stated in the app or required by local law, Help improve Gugu may be enabled by default. You can disable it in the app settings.

If disabled, Gugu still uploads audio for analysis, but raw recordings should not be kept after the result is generated or used for model improvement or ordinary trained review, except for short-lived technical processing, security, debugging, retries, legal compliance, or protection of the Services.

Local-law requirements

Where applicable law requires consent for a particular processing activity, Gugu will request that consent separately. You may withdraw consent where required by law, and disabling a setting will apply prospectively unless otherwise required by law.

For users in regions where affirmative consent is required for model-improvement storage or trained review, Gugu may present additional choices or disable certain default settings.

16. Deletion

You may request deletion of your account and associated data. When you do:

live account data will be deleted or de-identified within a reasonable period, subject to legal and security exceptions;
saved recordings and history tied to the account will be deleted or scheduled for deletion;
raw recordings stored under Help improve Gugu will be deleted, de-identified, or removed from active model-improvement datasets where reasonably feasible and legally required;
certain limited data may be retained for compliance, fraud prevention, dispute resolution, backup integrity, security, or protection of the Services.

Deletion from backups may take longer because backups are overwritten or purged on a rolling schedule.

17. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. If changes are material, we will provide notice as required by law.

18. Contact

For privacy questions or requests, contact:

Privacy Team