Privacy Policy

GYGLER PRIVACY POLICY

Last Updated: July 1, 2026

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW GYGLER, LLC (“GYGLER,” “WE,” “OUR,” OR “US”) COLLECTS, STORES, USES, SHARES, AND OTHERWISE PROCESSES DATA IN CONNECTION WITH YOUR ACCESS TO AND USE OF OUR WEBSITE, MOBILE APPLICATION, AND RELATED SERVICES (COLLECTIVELY, THE “PLATFORM”). THE INFORMATION COLLECTED INCLUDES, WITHOUT LIMITATION, PERSONAL INFORMATION. BY ACCESSING OR USING THE PLATFORM, OR BY ACCEPTING THE APPLICABLE TERMS OF SERVICE PURSUANT TO WHICH THIS PRIVACY POLICY IS PROVIDED, YOU ACCEPT THIS PRIVACY POLICY. THIS PRIVACY POLICY IS HEREBY INCORPORATED INTO AND MADE A PART OF THE APPLICABLE TERMS OF SERVICE BY THIS REFERENCE.

WHEN ACCESSING AND/OR USING THE PLATFORM, YOU MAY ALSO BE SUBJECT TO PRIVACY POLICIES OF THIRD PARTIES. PLEASE READ SUCH THIRD-PARTY PRIVACY POLICIES CAREFULLY. YOU ACKNOWLEDGE AND AGREE THAT GYGLER DOES NOT CONTROL SUCH PRIVACY POLICIES AND HAS NO RESPONSIBILITY OR LIABILITY FOR THE ACTIONS OR OMISSIONS OF SUCH THIRD PARTIES.

Capitalized terms used, but not defined, in this Privacy Policy have the meanings ascribed to such terms in the applicable Terms of Service.

If you have any questions regarding our Privacy Policy, please contact us at:

Gygler, LLC
Attn: Privacy Officer
6996 Piazza Grande Ave.
Suite 301
Orlando, Florida 32835
Email: privacy@gygler.com

How We Collect Your Information

Information Collected Automatically

To provide functionality for and improve the Platform, we use cookies, web beacons, pixels (including Meta Pixel), analytics tools (such as Google Analytics), and similar tracking technologies to automatically collect certain information, including Personal Information. Information we automatically collect includes, without limitation, internet protocol (IP) addresses, internet browser type, characteristics of your device and software, domain names of your internet service provider, your precise or approximate geographic location as determined by the device you are using, a record of your usage of the Platform, and the time of your usage. For more information on our collection and use of such collected information, please view our Cookie Policy.

Information Provided Directly By You

You actively provide information to Gygler in various ways, including when you:

• Register for an account;
• Create or update a profile;
• Apply for or accept work opportunities;
• Submit documentation or verification materials;
• Communicate with us or other users through the Platform.

Sensitive Personal Information

To verify identity, facilitate background checks, and enable payments, we may collect sensitive Personal Information, including:

• Government-issued identification numbers (e.g., driver’s license, SSN);
• Tax documentation (e.g., W-9 forms);
• Financial account information necessary for payment processing;
• Precise geolocation data during active Gigs; and
• Biometric identifiers or biometric information (as described below).

Such information is collected and processed only to the extent reasonably necessary to provide the Platform and fulfill legal and operational requirements, and is stored using appropriate administrative, technical, and physical safeguards, including encryption and restricted access controls.

Geolocation Information

We may collect precise geolocation data through the Platform for operational purposes, including verifying attendance, timekeeping, and platform integrity during active work engagements. Location data collection may occur during a defined period surrounding scheduled Gigs. However, we do not use your location data for continuous tracking outside of defined operational windows and it is not disclosed to other users except as necessary to confirm attendance. You acknowledge that such collection is a condition of use of certain Platform features.

Biometric Information

In certain circumstances, Gygler may collect and use biometric identifiers or biometric information (e.g., facial geometry templates or voiceprints) for identity verification, fraud prevention, and secure access to the Platform. Gygler does not sell, lease, trade, or otherwise profit from biometric identifiers or biometric information. Such data is used solely for authentication, security, and fraud prevention purposes and is retained only as long as necessary to fulfill those purposes, subject to applicable law. Our collection, use, retention, and destruction of biometric data is governed by our Biometric Information Policy and Consent, which is incorporated herein by this reference. Where required by applicable law, we will obtain appropriate consent prior to collection.

Background Check Information

With your authorization, we may receive background check results from third-party screening providers. Such information is used solely for eligibility determinations, compliance, and platform safety purposes.

Review and Modification of Personal Information

You can request to review or modify the Personal Information previously provided to or collected via the Platform. You acknowledge that we will use reasonable efforts to delete your information when requested, but that some residual information may remain because of backup files and deletion logs.

Types of Personal Information Collected

Gygler may collect, and may have collected within the last twelve (12) months, the following categories of Personal Information from users of the Platform:

How We Use Your Data

Generally
We use your data to:
Provide, operate, and maintain the Platform;

Facilitate connections between Clients and Gyglers;

Process payments and transactions;
Verify identity and eligibility;
Enhance functionality and user experience;
Monitor compliance with our Terms of Service;

Protect against fraud, abuse, or unauthorized activity;

Conduct analytics and product development; and

Communicate with you regarding Platform-related matters.

Processing

We may process your data for one or more of the following reasons:

Legitimate business interests;
Performance of contractual obligations;
Compliance with legal obligations;
Protection of vital interests; and/or
Your consent, where applicable.

Marketing and Communications

From time to time your Personal Information, such as your name and email address, may be used to contact you with promotional materials, marketing or other information that may be of interest to you based on your preferences. You further agree that:

BY ACCESSING OR USING THE PLATFORM OR ACCEPTING OUR TERMS OF SERVICE, YOU HEREBY PROVIDE GYGLER AND OUR PLATFORM PROVIDERS, EXPRESS CONSENT TO CONTACT YOU ON YOUR TELEPHONE, INCLUDING, BUT NOT LIMITED TO, CALLS, LEAVING VOICE MESSAGES, AND SENDING TEXT MESSAGES, AND TO SEND EMAILS, WITH NOTIFICATIONS, INFORMATION, AND OFFERS RELATED TO GYGLER AND/OR THE PLATFORM, INCLUDING, BUT NOT LIMITED TO, NOTIFICATIONS PERTAINING TO REQUESTS, COMMUNITY FORUMS, AND NEWSLETTERS, AND ADVERTISING, MARKETING, AND/OR PROMOTIONAL INFORMATION AND OFFERS. BY SUBMITTING A REQUEST OR INQUIRY FOR THIRD PARTY WEBSITE OR OTHERWISE INTERACTING WITH ANY THIRD PARTY THROUGH THE PLATFORM, YOU HEREBY PROVIDE GYGLER, AND THE APPLICABLE THIRD PARTY, EXPRESS CONSENT TO CONTACT YOU BY TELEPHONE, INCLUDING, BUT NOT LIMITED TO, CALLS, LEAVING VOICE MESSAGES, AND SENDING TEXT MESSAGES, AND TO SEND YOU EMAILS, WITH NOTIFICATIONS, INFORMATION, AND OFFERS RELATED TO GYGLER, THE PLATFORM, YOUR ACCESS TO AND USE OF THE PLATFORM, OUR PRODUCTS AND OTHER SERVICES (IF APPLICABLE), THE THIRD PARTY, AND THE THIRD PARTY PRODUCTS AND SERVICES. YOU ARE ALSO EXPRESSLY AGREEING TO RECEIVE FUTURE CALLS, VOICE MAILS, TEXT MESSAGES, AND EMAILS THAT DELIVER ADVERTISING AND TELEMARKETING MESSAGES THAT ARE GENERATED THROUGH AN AUTOMATIC TELEPHONE DIALING SYSTEM OR AUTO-DIALER, AND ARE CONSENTING TO RECEIVING MESSAGES THAT COME VIA AN ARTIFICIAL OR PRE-RECORDED VOICE MESSAGE OR THAT COME IN THE FORM OF A MASS TEXT MESSAGE MAILER. THE TERMS OF THIS PROVISION ARE NOT A CONDITION OF YOUR USE OF THE PLATFORM. THIS PERMISSION CONSTITUTES PRIOR EXPRESS WRITTEN CONSENT UNDER THE TELEPHONE CONSUMER PROTECTION ACT. THIS CONSENT APPLIES EVEN IF YOU ARE CHARGED FOR THE CALL UNDER A PHONE PLAN. YOU ACKNOWLEDGE AND AGREE THAT MESSAGE AND DATA RATES (FOR EXAMPLE, FROM YOUR NETWORK PROVIDER) MAY APPLY. YOU ARE RESPONSIBLE FOR ANY CHARGES THAT MAY BE BILLED BY THE COMMUNICATIONS CARRIERS.

You may be contacted by the email address you provide to us, subject to your right to opt-in and opt-out, as such rights may be available to you. You can withdraw your consent to receive any direct marketing communication from us by contacting marketing@gygler.com or following the unsubscribe instructions in our email communications.

Non-Personal Information

We may collect and create de-identified and aggregated information and other non-Personal Information, which is not related to an identified or identifiable natural person (“Non-Personal Information”). You agree that Gygler owns, without restriction, all Non-Personal Information and that you have no rights in or to any Non-Personal Information. Because Non-Personal Information cannot be used to personally identify you, you agree Gygler may use such information for any lawful purpose, including for analytics, research and development and other product and service improvement purposes.

Information Sharing and Disclosure

Generally

We do not sell, share, or otherwise transfer your data to third parties, except for sharing your data with Clients, hosting partners, other trusted third parties who assist us in operating and providing the Platform, or otherwise conducting our business as set forth in this Privacy Policy and/or applicable Terms of Service. We may also share your data when we believe sharing is necessary to comply with applicable law, enforce our policies (including, without limitation and as applicable, our Terms of Service and Cookie Policy), or protect our or others' rights, property, or safety.

Clients

We may share your data with Clients to match you with Gigs and matters related to those Gigs, such as background checks and screenings, your location and applicable biometrics, and paying you for Gigs. Clients are bound to maintain your data they receive from Gygler in accordance with this Privacy Policy.

Third-Party Service Providers

We may share your data with third-party service providers or other trusted third-party companies and individuals to provide, analyze, and improve the Platform, perform database management, analyze use of the Platform, perform analytics and produce statistics on the Platform, and/or deliver other requested products and services and features to you. We may also share certain Personal Information with third-party background check and screening providers. These third-party service providers may include, but are not limited to, payment processors, internet service providers, cloud computing providers, and third-party background check and screening providers. These third-party service providers are contractually bound to only process the limited amounts of your data that we provide them to perform specific tasks at our direction. These third-party providers are bound to maintain your data they receive from Gygler in accordance with this Privacy Policy. You agree we may share your data with third party service providers as necessary for providing you with the Platform.

Business Transfers

From time to time, Gygler may buy or sell assets or businesses. In the event of a corporate sale, merger, reorganization, dissolution, or similar event, your data may be part of the transferred assets. You acknowledge and agree that any assignee or other successor to Gygler (or Gygler’s assets) will continue to have the right to use your data and other information in accordance with the terms of this Privacy Policy and applicable Terms of Service. If the privacy policy of any such assignee or successor will apply to your data, we will notify you before your data is transferred and becomes subject to a different privacy policy.

Legal Requirements

As we may determine in our sole discretion, we may disclose your data if required to do so by applicable law, including, without limitation, responding to a subpoena or request from law enforcement, court, or government agency, or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect or defend our rights, interests or property or that of third parties, (iii) prevent, investigate, or identify possible wrongdoing in connection with the Platform, (iv) act in urgent circumstances to protect the personal safety of customers, users, or the public, or (v) protect against legal liability. Unless restricted by applicable law, we will inform you of such a disclosure or request for disclosure before sharing your data for this purpose.

Your Rights Regarding Your Data

Depending on your place of residency, you may have certain rights related to your Personal Information, including:

Right to Know

You may have the right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which it is collected, the business or commercial purposes for collecting, selling, or sharing it, and the categories of third parties to whom we disclose it.

Right to Access and Data Portability

Consistent with applicable law and subject to certain exceptions, you may have the right to request, in a portable and (if technically feasible) readily usable form, the Personal Information that we have collected about you as well as more information about our data practices.

Right to Correct Inaccurate Information

Consistent with applicable law, you may have the right to request that we correct inaccuracies in your Personal Information that we collected from you and retained, subject to certain exceptions.

Right to Delete

Consistent with applicable law, you may have the right to request that we delete Personal Information that we collected from you and retained, subject to certain exceptions.

Right to Opt-Out

Consistent with applicable law, you may at any time exercise the right to opt out of the sale of your data. Please note that if you opt-out of certain types of sales, we will be unable to provide you with the Platform, related products and other services that rely on such sales.

Right to Opt-Out from Personalized Advertising

We do not sell Personal Information. However, we do process Personal Information for purposes of displaying advertisements that are selected based on users’ online activities over time and across different sites, services, and devices. Consistent with applicable law, you may have the right to opt-out of having your Personal Information shared for purposes of targeted advertising.

However, due to the inherent necessity of your data for the operation of the Platform, you understand and agree that the erasure of, or withdrawal of your consent for us to process, your data may mean some features of the Platform may not function properly or may not be available to you and that any such deficiency in the Platform caused by such exercise of your privacy rights is not a result of discriminatory treatment for the exercise of your applicable privacy rights.

To exercise your applicable rights, please contact us at:

Gygler, LLC
Attn: Privacy Officer
6996 Piazza Grande Ave.
Suite 301
Orlando, Florida 32835
Email: privacy@gygler.com

We may verify the identity of any person who requests to exercise any of the above listed rights by, as applicable, matching information provided by such person with information already maintained by us or requesting additional information from such person for the sole purpose of identity verification. You may designate an authorized agent to make a request to exercise your applicable privacy rights on your behalf, in which case we will verify your identity and the identity of your authorized agent in one of the manners described above. You understand and agree that Gygler, at its sole discretion, may decline to comply with, or require further identity verification of, any request for which Gygler cannot adequately verify the identity of the person submitting the request.

If we deny your verifiable request to exercise your applicable privacy rights on your behalf, you have the right to appeal our decision. To initiate an appeal, please submit a written request to us within thirty (30) days of receiving our denial notice. We will review your appeal and respond within thirty (30) days of receipt of your appeal. If your appeal is denied, we will provide an explanation for the denial and inform you of any further rights you may have.

If you have a concern about our privacy practices, please contact us using the contact information set forth above, and we will take reasonable steps to address your concern.

IMPORTANT: The exact scope of these rights varies by state. There are also several exceptions where we may not have an obligation to fulfill your request.

Data Transfers – International Users

If you provide Personal Information to us, it may be transferred to and processed on computers in the U.S. and other countries. Do not provide your Personal Information to us if you do not want this information to be transferred outside of your country, or if the laws in your country restrict these types of transfers.

Third-Party Links

At our discretion, the Platform may include links to other websites not operated or controlled by us. These third-party websites are subject to separate and independent privacy policies. We have no responsibility or liability for the content and activities of these linked websites. Inclusion of these links to third-party websites through the Platform does not imply that we endorse or have reviewed the third-party websites. Nonetheless, we seek to protect the integrity of the Platform and welcome any feedback about these third-party websites.

CAN-SPAM Act

We are committed to being compliant with the Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003 (“CAN-SPAM Act”). All emails you receive from us or through the Platform are intended to fully comply with the CAN-SPAM Act. You may unsubscribe from receiving future emails from us at any time by contacting us at privacy@gygler.com and we will promptly remove you from all correspondence for the Platform. You understand and agree that being removed from all correspondence for the Platform may mean some features of the Platform may not function properly or may not be available to you, and you may not be able to use the Platform.

Storage and Security

Subject to this Privacy Policy, and unless you otherwise provide us with specific instructions that we accept, we will only store your data for as long as is necessary to provide you with access to and use of the Platform, fulfill our Terms of Service, or as otherwise required by law. Gygler has implemented and we routinely update and maintain appropriate administrative, physical and technical security measures to help protect your data from unauthorized access. Some of the safeguards we use to protect your data are firewalls and data encryption, information access controls, controlled access to our facilities and 24/7 monitoring of our systems databases. You acknowledge that your access to and use of the Platform is voluntary and undertaken with full knowledge and awareness that such activities necessarily entail risks, including security breaches, unavailability, loss or corruption of data, and other inherent risks associated with computer software, communications via the Internet, electronic communications and processing. You should take particular care in deciding what information you send or otherwise make available to us, and you should always back up your data or content you send or otherwise make available to us. Except as otherwise required by applicable law, Gygler shall not be liable for the storage or loss of any of your data or content. If you believe your credentials for accessing and using the Platform have been compromised, please contact us immediately at privacy@gygler.com.

Children Under the Age of 16

We do not specifically or knowingly provide or market the Platform to children under the age of 16 or collect, store, use, share, or otherwise process Personal Information of children under the age of 16.

Unsolicited Information

This Privacy Policy shall not apply to any unsolicited information you provide to us. This includes, but is not limited to, information shared to us via the App, any ideas for new products or services, or modifications to existing products or services, claim or demand letters, Digital Millennium Copyright Act notices, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, distribute and exploit such Unsolicited Information without limitation or attribution. However, if any of your Personal Information is included in any Unsolicited Information, then we will only process that Personal Information in compliance with this Privacy Policy and applicable law.

Changes to Our Privacy Policy

We reserve the right to change the terms of this Privacy Policy at any time by posting those changes to this Privacy Policy, so that you are always aware of our processes related to collection, use and disclosure of your Personal Information. For significant changes, we will notify you by posting a prominent notice on our Platform indicating when the Privacy Policy was most recently updated. Please consult this portion of the Platform regularly for important changes to the Privacy Policy as they occur.