Privacy Policy

Last updated: 04/25/2023

Guide, Inc. (“us”, “we”, “our,” or “Guide”) operates the www.aspirations.co website (the “Website”) and the Aspirations mobile application and related services (collectively, the “Services”).

This page informs you of our policies regarding the collection, use and disclosure of Personal Information when you use the Services.

BY VISITING OR USING THE SERVICES, YOU EXPRESSLY CONSENT TO THE PROCESSING OF YOUR PERSONAL INFORMATION ACCORDING TO THIS PRIVACY POLICY.  IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, YOUR CHOICE IS TO NOT USE THE SERVICES.  YOUR PERSONAL INFORMATION MAY BE PROCESSED IN THE COUNTRY WHERE IT WAS COLLECTED AS WELL AS OTHER COUNTRIES (INCLUDING THE UNITED STATES) WHERE LAWS REGARDING PROCESSING OF PERSONAL INFORMATION MAY BE LESS STRINGENT THAN THE LAWS IN YOUR COUNTRY.  BY UPLOADING PERSONAL INFORMATION TO THE SERVICES You warrant that you have the right to transfer such information outside your country and into the United States.

Children’s Privacy

People under 18 years of age are not permitted to use the Services for any purpose and Guide does not collect information from or about anyone under the age of 18.  If we learn we have collected or received personal information from or about a person under 18, we will delete that information. If you believe we might have any information from a person under 18, please contact us at info@aspirations.co.

The Information We Collect

If you contact us or register to join a mailing list, you may voluntarily provide certain information that can be used to contact or identify you, such as your email address, name, phone number, postal address and other information related to your question or preferences.  We collect this information for the purpose of providing the Services, identifying and communicating with you, responding to your requests/inquiries and improving the Services.  You may opt-out of receiving marketing communications from us by following the unsubscribe link or instructions provided in any email.

3rd Party Users:  If you are using the Services through your business or institution (“Institution”), we may collect your: name, company email, personal email, status in the organization, preferred learning category. Information will be fully available to Institution to be used by them to the same extent as if you provided the information directly to the Institution.

When using the Services, you may choose to provide information on publicly accessible portions of the Services or share information with other registered users through private messages.  Please be aware that any information you publicly post on the Services may be viewable by Guide members or the general public.  We recommend you use caution when publicly posting or sharing private information on the Services and that you do not post personal information or other information you are not comfortable sharing with the general public.    

If you’re using the Services on your mobile device, you may also choose to provide us with location data.

Financial Information: If you use the Services to purchase a subscription, host your products, pay for a listing or make any other purchase, Guide uses Paypal and WooCommerce, a secure payment provider, to process your payments.  Your payment information is subject to the privacy policy and terms of use of Paypal and WooCommerce.  We recommend you review these policies before uploading any credit card information.  Guide does not have access to your credit card information and does not store this information on our servers.

Access and Log Data

Like most website operators, Guide collects non-personally-identifying information of the sort that web browsers, mobile applications and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request when visitors use the Services. Guide’s purpose in collecting non-personally identifying information is to better understand how Guide’s visitors use the Services. From time to time, Guide may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its Services.  Guide also collects potentially personally-identifying information like Internet Protocol (IP) addresses and may collect statistics about the behavior of visitors to the Services. For instance, Guide may monitor the Services to help identify spam.  We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

In addition to log data, we may also collect information about the device you’re using to access the Services, including the type of device, the operating system, device settings, device identifiers and crash data. Whether we collect some or all of this information often depends on what type of device you’re using and its settings.  To learn more about the information your device makes available to us, please review the policies of your device manufacturer or software provider.

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

Cookies

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and transferred to your device. We use cookies to collect information in order to improve our services for you.  You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help feature on most browsers provides information on how to accept cookies, disable cookies or to notify you when receiving a new cookie.

If you do not accept cookies, you may not be able to use some features of the Services and we recommend that you leave them turned on.

How We Use Your Information

We use the information we collect to provide you full access and functionality of the Services.  Accordingly, your information may be used for the following purposes: (i) to provide and improve our services, features and content; (ii) to administer your use of our services and accounts; (iii) to enable users to enjoy and easily navigate the Services; (iv) to better understand your needs and interests; (v) to fulfill requests or to respond to questions or comments you may make; (vi) to personalize your experience; (vii) to provide you with announcements, notifications and advertisements related to your interests and use of the Services and other communications such as electronic newsletters, promotional e-mails or similar messaging; (viii) to provide service announcements; (ix) to protect against users seeking to hack into the Services; (x) to assess the level of general interest in the Services and (xi) for any other purpose with your consent.

How We Disclose Your Information

3rd Party Users

As provided above, we will provide your Institution with access to your Information.

Public Posting

You may choose to post a question or comment on our message boards.  Please be aware that any information or images you post will be publicly available.  Please do not post any information that could be used to identify you or your location on the public portions of the Services. 

Other Disclosures

We may disclose non-personally identifiable aggregated information about our users without restriction.

Except as otherwise provided in this policy, we disclose the potentially personally-identifying information you disclose to Guide only to those of our employees, contractors and affiliated organizations that (i) need to know that information in order to process it on our behalf or to provide the Services, and (ii) that have agreed not to disclose it to others. Some of those employees, contractors and affiliated organizations may be located outside of your home country and by using the Services, you consent to the transfer of such information to them.

Other than to its employees, contractors and affiliated organizations or as described above, we disclose personally-identifying only when required to do so by law, or when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Guide, third parties or the public at large.  If you send us a request (for example via chat, a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users.

In addition, in some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the business assets that is transferred. Moreover, if Guide or substantially all of its assets were acquired, or in the unlikely event that Guide goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur and that any acquirer of Guide may continue to use your personal and non-personal information only as set forth in this policy. Otherwise, we will not rent or sell potentially personally-identifying and personally-identifying information to anyone.

We may also disclose your personally-identifying information if you expressly consent to the disclosure. 

Security

Guide is committed to protecting your personal information. We regularly test our facilities and use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use or disclosure.

We Do Not Sell Your Personal Information

Guide does not, to the best of our knowledge, sell or rent personal information that we have collected or retain about you to any other third-party for any purpose. Accordingly, we do not offer individuals the ability to “opt-out” of the selling or renting of personal information because we do not engage in those practices.

Our Data Retention Criteria

The period during which we store your personal information varies depending on the purpose for the processing. For example, we store personal information needed to provide you with products and services, or to facilitate transactions you have requested, for so long as you are a customer of Guide. We store your personal information for marketing purposes until you have opted-out of receiving further direct marketing communications in accordance with applicable law. In all other cases, we store your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Statement, following which time it is either anonymized (where permitted by applicable law), deleted or destroyed.

Links to Other Sites

The Services may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Your Rights and Responsibilities

You are permitted, and hereby agree, to only provide personal information to Guide if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation.

You may have certain rights under applicable data protection law with respect to personal information about you that is collected through the Sites or when you contact or otherwise engage with us. To exercise any of these data privacy rights, please contact us, or have your authorized agent contact us, in accordance with the “Contact Us” section listed below. In the event you submit, or your authorized agent submits on your behalf, a data request, you (and your authorized agent) hereby acknowledge and agree, under penalty of perjury, that you are (or the authorized agent of) the consumer whose personal information is the subject of the request. We will respond to any data requests within the timeframes required by law, and we may charge a fee to facilitate your request where permitted by law.

Marketing. You have the right to opt-out of receiving electronic direct marketing communications from us.  All electronic direct marketing communications that you may receive from us, such as e-mail messages, will give you an option of not receiving such communications from us in the future.

California Privacy Rights.  California Civil Code Section § 1798.83 permits users of the Sites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Pursuant to the California Consumer Privacy Act of 2018, as amended (“CCPA”), California residents may have certain data privacy rights, such as the right to be notified about what personal information categories are collected about you, and our intended use and purpose for collecting your personal information. You have the right to request access to your personal information and, to the extent feasible, request that it be transmitted in certain forms and formats.  You may have the right to request that we (and any applicable service provider) delete your personal information. You have the right not to be subject to discrimination for asserting your rights under the CCPA.  If you make, or an authorized agent on your behalf makes, any request related to your personal information, Guide will ascertain your identity to the degree of certainty required under the CCPA before addressing your request.  Guide may require you to match at least three pieces of personal information we have previously collected from you before granting you access or otherwise responding to your request. 

Do Not Track. Some web browsers may transmit “do-not-track” signals to the Sites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.

European Union (EU) Privacy Disclaimer

Guide processes personal information in accordance with the legal bases set forth in the EU General Data Protection Regulation (GDPR) or EU Member State law. For example, our processing of Personal Data on individuals (as described above) is justified based on statutory provisions that (1) processing is based on the consent; (2) processing is necessary for Guide’s  legitimate interests as set out herein; (3) processing is necessary for the performance of a contract to which you are a party; and, (4) Guide is required to comply with a legal or statutory obligation in the EU or a Member State. If you are in the EU or afforded protection under the GDPR, you may have certain rights with respect to the Personal Data. To the extent permitted by applicable data protection laws, you may access the Personal Data we hold about you; request that inaccurate, outdated, or no longer necessary information be corrected, erased, or restricted; and, request that we provide your Personal Data in a format that allows you to transfer it to another service provider. You also may withdraw your consent at any time where we are relying on your consent for the processing of your Personal Data. You may object to our processing of your Personal Data where that processing is based on our legitimate interest. You have the right to lodge a complaint with your competent data protection authority.  Guide transfers personal data outside the EU in accordance with standard contractual clauses adopted by the European Commission, or other approved safeguards (e.g., Privacy Shield, consent). If you wish to exercise any of these rights, please contact us in accordance with the instructions provided below.

Nevada Privacy Disclaimer

Pursuant to Nevada law, a Nevada “consumer” (as the term is defined therein), may, at any time, submit a verified request through a designated request address to an “operator” directing the operator not to make any sale of his or her personal information that the operator has collected or will collect about the consumer. For clarity purposes, Guide does not sell or exchange your personal information for monetary consideration to a third party for the third party to license or sell the information to additional persons or parties.

Changes to This Privacy Policy

We may occasionally update this Privacy Statement. When we do, we will revise the “last updated” date at the top of the Privacy Statement and take such additional steps as may be required by law.

Contact Us

If you have questions regarding this Privacy Statement, our handling of your personal information, or would like to request more information or exercise a data right, please contact us via email at info@aspirations.co or at:

        ATTN: Guide, Inc.

        28184 Knapps Lot St

        Easton, MD 21601