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Privacy Policy



Last Updated: July 30, 2020

This privacy policy (this “Policy”) describes how Freeflow & Gusto, LLC (the “Company”) collects, uses, maintains, protects, and shares your personal information when using this website, www., other Company websites, applications, and browser extensions (collectively, the “Site”). This Policy also applies to any additional ways we collect or you submit information to us, including emails, texts, or other electronic messages between you and the Company. This Policy does not apply to any of our websites that post different privacy policies.


We get information about you in a range of ways. 

Information You Give Us. We collect your 1) name, 2) date of birth, 3) postal address, 4) email address, 5) username, 6) password, 7) financial information and transactional records, if you transact business with the Company, 8) records and copies of correspondence, if you contact us, and 9) any other information you directly give us on the Site.

Information We Get From Others. We may get information about you from other sources. We may add this to information we get from the Site.

Information Automatically Collected. We automatically log information about you and your device. For example, when visiting the Site, we log your device’s operating system type, browser type, browser language, the website you visited before browsing to the Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on the Site. Unless disabled, we also automatically collect your location data while using the Site. 

Cookies. We may log information using “Cookies.” Cookies are small data files stored on your device by a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your device until you delete them) to provide you with a more personal and interactive experience on the Site.    This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.


Some content or applications, including advertisements, on the Site are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies in conjunction with other tracking technologies to collect information about you when you use the Site. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. 

We do not control these third parties’ technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. 


We use your personal information as follows:

  • We use your personal information to operate, maintain, and improve our sites, products, and services. This may include making recommendations, pushing notifications to your device, conducting research or analysis on your use of the Site, or producing website or application analytics. 
  • We use your personal information to respond to comments and questions and provide customer service.
  • We use your personal information to send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
  • We use your personal information to communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.
  • We use your personal information to link or combine user information with other personal information.
  • We use your personal information to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
  • We use your personal information to provide and deliver products and services customers request.
  • We use your personal information to enforce or exercise any rights in this Policy or any contract between you and the Company, including the Company’s Terms of Use. 


We may share personal information as follows:

  • We may share personal information with your consent. For example, you may let us share personal information with third parties for their own marketing uses. Those uses will be subject to the privacy policies of those specific third parties.
  • We may share personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding in which the personal information of our users is among the assets transferred.
  • We may share personal information for legal, protection, and safety purposes.
    • We may share information to comply with laws.
    • We may share information to respond to lawful requests and legal processes.
    • We may share information to protect the rights and property of the Company, our agents, customers, and others. This includes enforcing our agreements, policies, and terms of use.
    • We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
  • We may share information with those who need it to do work for us.

We may also share aggregated and/or anonymized data with others for their own uses without restriction.


Our marketing emails tell you how to “opt-out.” If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you.

You may send requests about personal information to our Contact Information below. You can request to change contact choices, opt-out of our sharing with others, and update your personal information.

You can typically remove and reject cookies from the Site with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how the Site works for you. 

For EU residents, we will send marketing and informational materials only to those individuals who have affirmatively indicated they want to receive marketing and informational materials by providing their contact information and/or selecting the appropriate boxes to confirm an election to receive the marketing or informational materials.

RETENTION. We retain your personal information that we receive from you as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purposes for which it was collected, provide our products and services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. 

CONTACT INFORMATION. We welcome your comments or questions about this privacy policy. You may also contact us at our address:

Freeflow & Gusto

CHANGES TO THIS PRIVACY POLICY. We may change this privacy policy. If we make any changes, we will 1) post the changes to this page, 2) post a notice that the privacy policy has been updated on the Site’s homepage, and 3) change the Last Updated date above. In the event we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting the Site and this Policy to check for any changes. Your continued use of the Site after we make changes is deemed to be acceptance of those changes.


DATA TRANSFERS. All personal information sent or collected via or by us may be stored anywhere in the world, including but not limited to, in the United States, in the cloud, our servers, the servers of our affiliates or the servers of our service providers. Your personal information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to us, you consent to the storage of your personal information in these locations. 

For EU residents subject to the GDPR, you have certain rights relating to your personal information, subject to local data protection laws. These rights may include:

  • To access your personal information held by us (right to access);
  • To rectify inaccurate personal information and, taking into account the purpose of processing the personal information, ensure it is complete (right to rectification);
  • To erase/delete your personal information, to the extent permitted by applicable data protection laws (right to erasure; right to be forgotten);
  • To restrict our processing of your personal information to the extent permitted by law (right to restriction of processing);
  • To transfer your personal information to another controller or processor, to the extent possible (right to data portability);
  • To object to any processing of your personal information carried out on the basis of our legitimate interests (right to object). Where we process your personal information for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
  • To the extent we base the collection, processing, and sharing of your personal information on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.

To exercise these rights, please submit your specific request by using the information in the “Contact Information” section above. 

Timeframe for Responding to Requests

We will respond to your request within thirty (30) days of receipt.

The period of response may be extended to forty-five (45) or sixty (60) days if more time is required. In that event, we will inform you of the reason and extension period in writing.


We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

CALIFORNIA PRIVACY RIGHTS. If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Information. To learn more about your California privacy rights, visit the California Privacy Notice (available at: Privacy Notice For California Residents).