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

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1. Who we are

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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

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2. Who Gugu is for

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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.

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3. Categories of data we collect

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

a. App identifiers and privacy preferences

 

When you use the Gugu app, we may process:

 

• a pseudonymous privacy subject or app-instance identifier;

• privacy-choice and consent metadata;

• app version, build, locale and policy-region information;

• purchase and entitlement identifiers or status associated with the app or platform.

 

These identifiers are pseudonymous. We do not treat them as anonymous where they can reasonably be associated with an app installation, transaction, recording, or other retained data.

 

If you contact us, submit a website form, or otherwise communicate with us, we may also receive information you choose to provide, such as your name, email address and message.

 

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. Purchase and entitlement data

 

Where you make an in-app purchase through Apple App Store, Google Play, RevenueCat, or another supported platform, we may receive limited transaction, purchase-status, entitlement, product and platform information needed to provide and restore the purchased feature.

 

Gugu does not receive your full payment-card or bank-account information where payment is handled directly by the applicable app-store or payment provider.

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4. How we collect data

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We collect data directly from you when you submit audio, provide feedback, change privacy settings, make or restore a supported purchase, contact support, or submit information through our website.

 

We also collect data:

 

• automatically from your device and app usage;

• from platform providers such as Apple and Google when needed for purchase, entitlement, or app-delivery functionality; and

• from service providers acting on our behalf.

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5. Why we use data

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We use personal data to:

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a. Provide the core service

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

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b. Maintain and secure the service

We use data to operate privacy controls, prevent abuse, detect fraud, monitor reliability, debug technical issues, and protect the Services.

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c. Maintain privacy preferences and supported entitlements

 

We process pseudonymous app or privacy identifiers, privacy-choice metadata, and purchase or entitlement information to apply privacy preferences and provide supported purchased features.

 

d. Improve product performance

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

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e. Model evaluation and improvement

 

Gugu may retain reduced acoustic representations derived from submitted recordings, together with related results, labels, confidence values, feedback and technical metadata, to evaluate, calibrate, test, train and improve Gugu’s baby-sound models and related systems.

 

Your Recording Privacy choice controls whether Gugu may retain the original audio recording after analysis. Choosing to delete the original recording does not by itself prevent retention or model-improvement use of eligible reduced acoustic representations and related results or feedback.

 

Reduced acoustic representations are not treated as anonymous merely because they do not contain the original waveform.

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f. Optional human review

 

Automated model evaluation and improvement do not by themselves authorize a person to listen to your recording.

 

Human review is a separate optional process. Where human review is offered and operationally enabled, Gugu requires the applicable separate in-app authorization before an eligible recording may be made available to trained personnel or contracted reviewers for labeling, quality assurance or model improvement.

 

Choosing to keep the original audio does not, by itself, authorize ordinary human review.

 

g. Legal and compliance purposes

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

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6. Audio processing and Recording Privacy

 

Gugu processes audio on its servers. When you submit a recording for analysis, the original audio file is sent from your device to Gugu’s servers or infrastructure providers. The server processes the recording, derives technical acoustic representations, runs Gugu’s analysis models, and returns a result to the app.

 

This means that the original audio leaves your device whenever you use the analysis feature.

 

Gugu currently offers two Recording Privacy choices:

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Keep original audio

 

The original recording may be retained after analysis in accordance with the applicable retention policy. Eligible reduced acoustic representations, results, labels, feedback and related metadata may also be retained and used for model evaluation and improvement.

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Delete original audio after analysis

 

The original recording is scheduled for deletion after the analysis and the applicable technical processing, retry and cleanup period.

 

Deleting the original recording does not mean that all information derived from the recording is deleted. Eligible reduced acoustic representations, results, labels, feedback and related metadata may still be retained and used for model evaluation and improvement.

 

Neither choice authorizes ordinary human listening. Human review, if offered, is governed by a separate authorization as described above.

 

You can review or change available Recording Privacy choices in the app. The effect of a change on previously retained data is governed by the applicable data-lifecycle rules and any deletion request you make.

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7. Legal bases and regional requirements

 

The legal basis for processing personal data depends on the processing purpose, the type of data involved, and the law that applies where the Services are offered.

 

Depending on the circumstances, processing may be based on providing the service you request, legitimate interests, consent where required, compliance with legal obligations, or another basis permitted by applicable law.

 

Where local law requires a specific notice, consent, authorization, right, or processing condition for a particular activity, Gugu will apply the requirements that govern that activity and market.

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8. Retention

 

We retain personal data only for as long as reasonably necessary for the applicable processing purpose.

 

Different retention periods may apply to:

 

• original audio retained under Keep original audio;

• original audio awaiting deletion after analysis;

• reduced acoustic representations;

• model results, labels and feedback;

• failed, abandoned or incomplete processing jobs;

• operational, security and diagnostic records; and

• backups.

 

Retention periods are determined according to the purpose of the data, technical and operational requirements, applicable privacy choices, security requirements, and legal obligations.

 

Where a user requests deletion, applicable data is deleted or scheduled for deletion subject to verified technical capability and limited legal, security, fraud-prevention, dispute-resolution or backup exceptions.

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9. Sharing of personal data

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We may share personal data with:

• cloud hosting, storage, database, and compute providers;

• analytics, diagnostics, and crash-reporting providers;

• customer support providers;

• authorized contractors or service providers involved in human review, labeling or quality workflows, but only where the relevant recording is separately eligible for that process;

• 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. We do not disclose baby-audio recordings to advertising networks for advertising purposes.

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10. International transfers

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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.

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11. Children and child-related data

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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 child-related information was submitted without authority required by applicable law, we may restrict further processing and delete the affected information where appropriate.

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12. Consumer health and inferred-data notice

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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.

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13. Security

 

We use administrative, technical and organizational safeguards designed to protect personal data, including access controls, restricted permissions, logging and security measures appropriate to the relevant processing environment.

 

No security measure can eliminate all risk.

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14. Your rights and choices

 

Depending on where you live, you may have rights concerning personal data, including rights to access, correct or delete data, obtain certain data, object to or restrict certain processing, or withdraw consent where processing is based on consent.

 

You may also request deletion of data associated with your Gugu privacy subject or app use even though the Gugu app does not currently require a user-facing Gugu account.

 

Requests can be sent to privacy@guguworks.com.

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15. Recording Privacy choices

 

Gugu’s Recording Privacy controls determine whether the original recording may be retained after analysis.

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Keep original audio

 

Gugu may retain the original recording as well as eligible reduced acoustic representations and related model-improvement data.

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Delete original audio after analysis

 

Gugu schedules for deletion the original recording after the applicable analysis and technical cleanup period, but eligible reduced acoustic representations, results, labels, feedback and related metadata may still be retained and used for model evaluation and improvement.

 

The current Recording Privacy controls do not provide an ongoing mode in which an analysis is performed while all recording-level derived model-improvement information is necessarily excluded from retention.

 

Human review is separate from these choices and requires its own applicable authorization where offered.

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16. Data deletion requests

 

Gugu does not currently require a user-facing Gugu account for core app use.

 

You may nevertheless request deletion of personal data associated with your use of Gugu by contacting privacy@guguworks.com.

 

Subject to applicable technical capability and legal or security exceptions, a deletion request may cover data such as:

 

• retained original recordings;

• retained reduced acoustic representations;

• related model-improvement metadata;

• feedback and annotations;

• pseudonymous app or privacy identifiers; and

• other data that can reasonably be matched to the requesting user or app privacy subject.

 

Certain limited information may be retained where necessary for legal compliance, security, fraud prevention, dispute resolution or documented backup integrity.

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17. Changes to this Privacy Policy

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

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18. Contact

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For privacy questions or requests, contact:

Privacy Team

Guguworks LLC
1209 Mountain Rd PL NE Ste N

87110, Albuquerque

NM, United States
privacy@guguworks.com