Guspora^™

This Privacy Policy describes how Guspora LLC, which operates the Guspora™ platform ("Company," "we," "us," or "our"), collects, uses, stores, and protects personal information in connection with the Guspora™ platform ("Platform").

1. Scope

This Privacy Policy applies to all users of the Guspora™ Platform including:

• Service Providers (Inspectors/Technicians)
• Customers (Property Owners/Managers)
• Authorities Having Jurisdiction (AHJs)
• Insurers
• Users of the Guspora™ mobile application (com.guspora.app)
• Purchasers and users of Guspora Track™ hardware devices

2. Information We Collect

2.1 Information You Provide

• Account registration information (name, email, phone, company)
• Service company profile (business address, license numbers, certifications)
• Customer and property records
• Inspection data, reports, photos, videos, and audio notes
• Equipment inventories and service histories
• Billing and payment information
• Communications with support

2.2 Information Collected Automatically

• Device information (browser, OS, device identifiers)
• Usage data (pages viewed, features used, session duration)
• IP address and approximate location
• Authentication logs and access timestamps
• AI Agent configuration settings, approval events, and Agent Action Ledger records

2.3 Mobile Application Data

The Guspora™ Android application (com.guspora.app) requests the following device permissions and collects data accordingly:

• Camera: Photos and videos captured during inspections. Used for inspection documentation, barcode scanning, and evidence capture. Photos and videos include embedded metadata (GPS, timestamp, device ID).
• Fine Location (GPS): Precise location data collected during active inspection workflows (check-in/check-out). Used for evidence geolocation and technician dispatch context where enabled. Location is NOT collected when the app is in the background or when the technician is not actively checked into a job.
• Microphone: Audio recordings captured during inspections for voice notes and AI-assisted inspection reporting features. Audio is transmitted transiently to OpenAI's Whisper API for transcription. Guspora does not authorize OpenAI to use customer audio for model training; OpenAI's own retention of API request data is governed by its API terms in effect at the time of the request.
• Storage: Read/write access to device storage for offline data caching (SQLite), photo/document access, and file uploads.

2.3A Guspora Collect App Data

The Guspora Collect app (com.guspora.collect on Google Play and the App Store) collects the following. None of it is sold, none of it is used for advertising, and the app has no ads.

• Account: your name, email address, and the fact that you confirmed you are 13 or older. If you sign in with Google or Apple, we receive your name, email address, and a sign-in identifier from them, never your password.
• Camera and photos: the card photos you take or choose. They are sent to Guspora to identify and price the card and are stored with your collection. The app asks for camera access only when you scan.
• Your collection and activity: the cards you save, prices you set, listings, trades, offers, messages with other collectors and shops, price alerts, saved searches, and searches.
• Purchases: Collect Pro and Shop Pro bought in the app are processed by Google Play or Apple. We receive the purchase record (product, dates, status, and an order identifier), never your card number. Marketplace payments are processed by Stripe.
• Location (Android, card shops only): Tap to Pay and some Bluetooth label printers on older Android versions require location permission. The app asks for it only when a shop starts Tap to Pay or connects a printer. Location is used by Stripe to confirm the payment is allowed where it happens; Guspora does not store it.
• Card payments in a shop (Android): when a shop takes a card with Tap to Pay, the card is read by Stripe's payment software and sent only to Stripe. Guspora never sees or stores the card number.
• Microphone (Android, optional): voice intake uses your phone's own speech recognizer to turn spoken card names into text. Only the text reaches Guspora; Guspora does not record or store audio.
• Nearby devices (optional): Bluetooth and local network access find and connect to label printers. Nothing about other devices is sent to Guspora.
• Notifications: if you allow notifications, a push token for your device so we can send the alerts you turn on.
• Diagnostics: on Android, Google's on-device text and barcode readers (ML Kit) send Google basic diagnostics (device model, OS version, app version, and performance and error codes). When app performance monitoring is turned on, crash and freeze reports go to Datadog. These are not linked to your name or used to track you.

All of this travels over encrypted connections (HTTPS). Sign-in tokens are kept in the phone's secure storage. You can delete your account and its data in the app (Profile, then Account, then Delete account) or at guspora.com/account/delete.

2.4 Guspora Track™ Data

If you purchase and activate Guspora Track™ GPS/BLE tracking devices, we collect:

• Continuous GPS location data from tracked vehicles/assets
• Device battery status and connectivity information
• Movement history, speed, and route data
• Geofence entry/exit events

This data is collected continuously while the tracking device is active and powered. Guspora Track™ location data is stored for 90 days, then archived for an additional 12 months before deletion. You may request deletion of tracking data at any time. Guspora Track™ data is only visible to the account holder who registered the device.

2.6 SMS Data

When you opt in to SMS notifications, we collect your phone number, consent status, consent method (web form, verbal, or text keyword), timestamp of consent, and IP address at the time of consent. This information is used exclusively for delivering service-related messages in accordance with our SMS Terms & Conditions.

2.7 Information We Do NOT Collect

• Social Security numbers
• Full credit card numbers (handled by Stripe)
• Biometric data (fingerprints, facial recognition)
• Data from children under 13 (accounts are for people 13 and older)
• Background location data when not actively checked into a job (inspection GPS)

3. Three-Party Data Sharing Framework

The Guspora™ Platform facilitates data sharing between three key parties: Authorities Having Jurisdiction (AHJs), Customers, and Service Providers (SPs). Each party has different visibility into platform data:

4. Credential Data Collection

For service providers, we collect and verify professional credentials including state license numbers and types, license issue and expiration dates, NICET certification levels, manufacturer certifications, and insurance and bonding information.

Verification sources include Kentucky DHBC, other state licensing databases, NICET verification system, and manufacturer certification databases. Credential status is publicly visible to customers and AHJs.

5. Evidence and Audit Data

All inspection evidence includes embedded metadata (GPS, timestamp, device ID, technician ID, inspection reference). Files are hashed using SHA-256 at upload. All access to evidence is logged.

AI Agent activity is recorded in the Agent Action Ledger, including action category, risk class, actor or approving user, tenant scope, target record, approval status, timestamps, and related metadata. These records support auditability, dispute resolution, security investigations, and verification of whether an Agent operated in Default Configuration or Modified Configuration.

6. Third-Party Service Providers (Subprocessors)

All third-party providers are bound by data processing agreements. Guspora does not authorize AI providers (OpenAI, Anthropic) to use customer data for model training. Provider-side retention of API request data is governed by each provider's API terms in effect at the time of the request; current OpenAI and Anthropic API defaults retain request data for a short operational window for abuse monitoring and do not use API content for model training without explicit opt-in.

For the complete list, see /legal/subprocessors.

6A. SMS / Phone Numbers

• Phone numbers are shared with Twilio for SMS delivery.
• Used for customer care SMS (scheduling, updates, invoices, support).
• Service providers may deliver SMS through the Platform on behalf of their business.
• Message frequency varies. Msg & data rates may apply.
• Reply STOP to opt out. Reply HELP for help.
• Consent to receive SMS is not a condition of purchase.

See /legal/sms.

7. Data Retention

Data export available for 30 days after termination. Active data deleted within 45 days. Legal retention periods may extend beyond termination.

8. Audit Trail Permanence

Deficiency lifecycle data is maintained permanently including identification, status changes, approval records, evidence hashes, and credential verification. Audit trail data may persist after account deletion to maintain compliance record integrity.

Agent Action Ledger records may also persist after account termination where needed to preserve legal, security, financial, regulatory, communication-consent, or dispute-resolution evidence.

9. GPS and Location Data

• Inspection GPS: Collected only when technicians are actively checked in. Not collected in background.
• Guspora Track™: Continuous collection while device is active. Separate from inspection GPS.
• Retention: Inspection location: 90 days then anonymized. Track™ data per Section 7.

10. Recording Practices

Inspection recordings stored with AES-256 encryption. AI processing via OpenAI Whisper (transcription) and Anthropic Claude (reports) with no data retention by AI providers. Support calls recorded with notice; standard 12 months, emergency 7 years.

10A. Guspora Collect Giveaways

When you enter a Guspora Collect giveaway, we keep your entry: your name, email address, how you entered, and when you confirmed the entry. The free entry form (no account or purchase needed) also asks for your state and date of birth, which we use to check eligibility and to stop one person from entering twice. Each entry has a random receipt number so a published drawing can be checked. A winner's name is shown publicly only if the winner chooses to be shown.

If you win and claim a prize, we keep the shipping name, address, and phone number you give us to send it. For a prize worth $600 or more, we ask you by email for an IRS Form W-9 before the prize ships, and the prize is reported on an IRS Form 1099-MISC.

Deletion. If you delete your Guspora account, your name, email address, date of birth, state, and shipping address are removed from your entries and claims. Only the random receipt number is kept, so a published drawing can still be checked. Entries you never confirmed are deleted. If you claimed a prize worth $600 or more, the name and address on that claim are kept for 7 years after the claim for tax records, then removed. For a smaller prize that has not been delivered yet, they are kept until it is delivered (at most 90 days). If you entered without an account, email support@guspora.com to have your entry removed the same way.

10B. Community Profiles, Messages, and Reports

If you use the Guspora Collect community, we keep your profile (bio and showcase), the collectors and shops you follow, block, or mute, and your direct messages. A direct message can be read only by the people in the conversation; for a conversation with a shop, that means the shop's members. Links to other sites are removed from messages, strong profanity is masked, and a message with a phone number, an email address, or a payment app carries a warning to keep payments on Guspora.

You can report a message, a conversation, a profile, or a shop. We keep the report and a copy of what was reported (for a message, that message and the ten before it). Guspora reviews the report and that copy, not your inbox, and may remove a message (it then shows as "Message removed") or suspend an account.

Deletion. Deleting your account deletes your profile, follows, blocks, mutes, your conversations and their messages, and the reports you filed. Reports other people filed about you are kept with what was reported for up to 7 years to keep the community safe, and are never shown to anyone but Guspora.

10C. Guspora Protection Claims

When a protected order has a claim, we keep the claim and every step and decision on it, the messages between the buyer, the seller, and Guspora, the photos either side adds (for example, a photo of the card that arrived or of an item that was returned), and the order's tracking and delivery details. When a protected item is listed, we also keep a record of the listing as buyers saw it: its title, condition, disclosed defects, price, any serial or certificate number, and the seller's photos.

Claim messages and photos cannot be edited or removed, because they may be needed to settle a dispute: if a buyer disputes the charge with their bank, Guspora sends the tracking, the delivery confirmation, the listing record, and the claim messages to Stripe as evidence. These records are kept with the order's records; deleting your account does not delete them.

10D. Pre-Grade Photos

When you request a pre-grade, the photos you upload are kept with your pre-grade as its evidence, together with the report. Pre-grade photos are measured on computers Guspora runs itself; they are not sent to an outside AI service for measuring. The copies made for measuring are deleted as soon as the measurement is done.

10E. YouTube, Google, and TikTok API Services

Guspora uses YouTube API Services to publish Guspora's own videos to Guspora's YouTube channel and to read, answer, and moderate public comments on those videos. If you comment on a Guspora video on YouTube, you are also using YouTube and agree to the YouTube Terms of Service. Google's handling of your information is described in the Google Privacy Policy.

Through YouTube API Services, Guspora accesses the public text of comments on its own videos, the commenter's public display name and channel ID, and the video and comment IDs. Guspora uses this only to reply to questions, hold obvious spam for review, and send comments that need a person (for example refunds, legal matters, or press) to Guspora's owner. Guspora does not sell this information, does not use it for advertising, and does not share it with anyone else. Comment text and names are removed from Guspora's comment log within 30 days.

The only Google account Guspora connects is the one that manages Guspora's channel. Its access tokens are kept encrypted in Guspora's secret store and are never shown in a browser. Access can be revoked at any time in Google's security settings at myaccount.google.com/permissions; once it is revoked, Guspora can no longer reach YouTube, and the stored tokens are deleted.

Guspora also connects its own TikTok account through TikTok's Login Kit and Content Posting API (Upload to inbox) to send Guspora's videos to the owner's TikTok inbox as drafts. The owner opens each draft in TikTok, edits the caption, chooses privacy, music, and disclosures, and decides whether to post it; Guspora does not publish for the owner. Guspora stores only that account's access tokens, its TikTok ID, and its display name. Guspora does not collect data about TikTok viewers or commenters through TikTok's APIs. Access can be revoked at any time in TikTok's app permissions settings; once it is revoked, Guspora can no longer reach the account, and the stored tokens are deleted.

11. Your Rights

12. California Privacy Rights (CCPA/CPRA)

Right to Know, Right to Delete, Right to Opt-Out of Sale (we do not sell data), Right to Non-Discrimination. Contact support@guspora.com. Response within 45 days.

13. European Privacy Rights (GDPR)

Legal bases: contract performance, legitimate interest, legal obligation, consent. Data stored in AWS US-East-1. Standard Contractual Clauses for EEA transfers.

14. Cookies and Tracking

Essential cookies only (session, security, preference). No advertising cookies, third-party tracking, or behavioral advertising. Third-party analytics on public marketing pages are listed in Section 6.

14.1 Guspora's Own Visit Counts (No Cookies)

On guspora.com, including Guspora Collect, our servers count page visits so we can see how many people visit, which pages they land on, and where they came from (for example a search engine, a Facebook or Instagram post, an email from us, or a link tag such as utm_source). This counting uses no cookies and no local storage. A small script on the page confirms that a person actually had the page open: after the page has been visible for a few seconds, or you tap, scroll, or type, it tells our servers the page address, how long the page was visible, and the referring source and campaign tag. It also reports taps on the Get the app install links and the first time you click into a sign-up field. It sets no identifier and reads nothing else from your browser.

• To count a visitor once per day, we combine your IP address and browser user agent with a random value that changes every day and keep only a one-way, shortened hash of the result. We never store your IP address or user agent for this purpose, and each day's random value is deleted within two days, so the hash cannot be linked back to you or to your visits on other days.
• We store only daily totals: visits, page views by page, the referring source and campaign tag, Android app downloads, and sign-up and checkout counts.
• If your browser sends Do Not Track or Global Privacy Control, your visits are not counted at all. Automated traffic, crawlers, and our own staff and test traffic are not counted as visitors; we keep only a total of how many page requests were filtered out.
• These counts are used only by Guspora to understand interest in our products. They are never sold or shared, and they are not used for advertising.

15. Security

TLS 1.2+ in transit, AES-256 at rest, AWS SOC 2 infrastructure, regular security audits, MFA support, role-based access controls, SHA-256 evidence hashing.

16. Children's Privacy

Guspora accounts are for people 13 and older. When an account is created, we ask you to confirm that you are 13 or older and keep the date of that confirmation with the account. We do not knowingly collect personal information from children under 13. If we learn that an account belongs to a child under 13, we close it and delete its personal information. A parent or guardian who believes a child under 13 has an account can email support@guspora.com.

17. Changes to This Policy

Material changes communicated via email 30 days before taking effect.