Privacy is part of stewardship.

1. Who We Are

Guruu International Inc. operates Legacy Guruuz and is responsible for the privacy practices described in this Policy.

For purposes of this Privacy Policy:

“Company” means Guruu International Inc.

“Website” means LegacyGuruuz.com and related public-facing Legacy Guruuz pages.

“Product Environment” means App.LegacyGuruuz.com and related authenticated Member, Steward, Contributor, onboarding, and Legacy-building environments.

“Legacy Guruuz,” “we,” “us,” and “our” refer, as context requires, to the Legacy Guruuz service line, Company, Website, Product Environment, communications, software, services, and related experiences.

“Member” means an individual enrolled in or otherwise authorized to use a Legacy Guruuz Member experience.

“Contributor” means an individual authorized to contribute stories, photographs, recordings, writings, reflections, memories, or other materials associated with a Legacy.

“Legacy Content” means material entrusted to Legacy Guruuz for preservation, organization, storytelling, continuity, mentorship, remembrance, or authorized Legacy development.

“Private Legacy Content” means Legacy Content whose access remains restricted according to Member permissions, service settings, applicable rights, and governing agreements.

“Steward” means a person designated through the applicable Legacy Guruuz process to carry defined responsibilities concerning a Member's Legacy according to the Member's instructions and governing terms.

Where applicable privacy law uses terms such as controller, business, or comparable designations for the organization determining how and why personal information is processed, Guruu International Inc. acts in that capacity for the processing described in this Policy unless another relationship is expressly identified.

2. Scope of This Policy

The Policy applies to personal information and Legacy Content collected or processed through LegacyGuruuz.com; App.LegacyGuruuz.com; Founding 100 enrollment and onboarding; Living Legacy intake, preservation, and development; interactions with Haliʻa; Stewardship; Contributor participation; photographs, video, voice recordings, writings, documents, stories, memorabilia, and other submitted Legacy materials; email, support, telephone, SMS, and related communications; payment and transaction processes; and future Legacy Guruuz services where this Policy is incorporated or referenced.

Additional governing documents may apply to particular activities, including the Terms of Service, Member Consent & Legacy Authorization, Content Standards, Stewardship & Continuity Agreement, Contributor permissions, Founding Member disclosures, Voice & Likeness Consent, rights-holder agreements, and feature-specific notices.

A more specific consent, agreement, or privacy notice may supplement this Policy for the particular subject it governs.

3. Legacy Privacy Principles

Our privacy architecture follows several enduring principles.

Member Direction. Members remain central to decisions concerning their Living Legacy, approved materials, permissions, sharing, access, correction, and Stewardship.

Purposeful Preservation. Personal information is collected and processed for defined purposes connected to Legacy preservation, organization, continuity, storytelling, mentorship, service administration, security, and authorized Legacy development.

Permission. Collection, contribution, access, sharing, preservation, processing, and future use operate through appropriate permissions, authority, agreements, service design, and applicable law.

Provenance. Where relevant, we preserve information about where Legacy material came from, who contributed it, whose perspective it represents, and what permissions govern it.

Relational Privacy. A person's Legacy naturally includes other people. Their information, rights, dignity, and permissions remain part of responsible stewardship.

Source Integrity. Original source material remains distinguishable, where relevant to trust and meaning, from summaries, organization, interpretation, generated language, and other system-created records.

Stewardship. Long-term continuity operates through responsibility, Member direction, governed authority, and thoughtful future care.

Safety. Legacy materials may pass through safety, rights, authenticity, and trust controls before becoming active within the Legacy experience.

4. Information We Collect

The information collected depends on how you interact with Legacy Guruuz.

A. Account and Contact Information

Account and relationship information may include name, email address, telephone number, mailing address where applicable, authentication information, date of birth, birthplace, family or relationship information, Steward information, communication preferences, onboarding information, membership status, and service configuration.

B. Legacy Content

A Living Legacy may contain audio recordings, biographical information, correspondence, documents, family history, photographs, stories, memories, journals, letters, written reflections, beliefs, worldview, humor, personal expressions, life lessons, values, relationships, significant places, traditions, teachings, video, voice, memorabilia, descriptions of meaningful objects, and other materials selected for preservation.

Because human lives are complex, voluntarily provided Legacy Content may contain information that applicable law considers sensitive or specially protected. Depending on the Member's choices, that can include information relating to health, disability, family relationships, religious or philosophical beliefs, race or ethnicity, sexual orientation, identity, financial circumstances, trauma, loss, political views, or other highly personal experiences.

Certain biometric or identity-linked information may also arise if a Member later chooses a separately authorized voice, likeness, verification, or digital-replica capability.

C. Contributor Information

When another person contributes to a Legacy, we may collect their name, contact information, relationship to the Member or person being remembered, contributed stories and memories, photographs, recordings, writings, attribution information, permissions, consent records, and communications concerning the contribution.

D. Steward Information

Stewardship may require information sufficient to designate, invite, verify, communicate with, authenticate, and administer a Steward.

Relevant records may include identity information, contact details, relationship information, designation records, acceptance records, Stewardship Instructions, verification information, and documentation connected to a qualifying continuity event.

E. Website, Device, and Usage Information

Use of the Website or Product Environment may generate technical information such as IP address, browser type, device type, operating system, pages viewed, referring source, session activity, approximate location derived from IP address, cookie or similar technology information, interaction data, security information, and site or application performance information.

F. Communications

We may maintain information associated with inquiries, onboarding, Member support, scheduling, email, SMS, telephone communications, consent discussions, contribution coordination, Stewardship, privacy requests, security matters, and other service communications.

G. Transaction Information

Third-party payment providers may process information associated with Founding Enrollment and other purchases.

We seek to minimize direct possession of complete payment-card or financial-account credentials while maintaining transaction information reasonably necessary for enrollment, refunds, accounting, fraud prevention, customer support, contractual administration, and legal compliance.

H. Service-Generated Information

Legacy Guruuz may create service-generated information needed to organize, administer, protect, and provide the Member’s authorized Legacy experience.

This may include summaries, organizational records, permission records, service questions, Member preferences, attribution information, and safety or support records.

Information created from identifiable Legacy Content remains governed as part of the applicable Member or Legacy environment.

5. Sources of Information

Information may come directly from a Member, Contributor, Steward, authorized representative, rights-holder, or person communicating with us.

Other information may arise through use of the Website or Product Environment, authorized integrations and service providers, payment providers, security systems, communications, or service-generated processing.

A Remembered Legacy involving a deceased person may also draw from authorized family materials, estates, organizations, archives, licensed sources, published materials, public records, or other sources permitted by applicable rights and governance.

Source origin remains important. Where provenance affects trust, permissions, attribution, or authority, we seek to preserve that distinction.

6. How We Use Information

Information may be used to create and administer accounts; provide the Living Time Capsule; preserve and organize Legacy Content; support conversations with Haliʻa; support storytelling and guided reflection; maintain continuity across interactions; use relevant approved materials; preserve attribution and context; administer permissions; administer Stewardship; communicate with Members, Contributors, Stewards, and authorized participants; process enrollment and payments; respond to support and privacy requests; protect content safety; secure accounts and systems; prevent fraud and misuse; maintain service reliability; improve Website and Product Environment performance; maintain records; enforce rights and governing agreements; comply with law; and support future authorized Legacy Guruuz experiences where applicable permissions and rights are in place.

Processing remains tied to an identified Legacy Guruuz purpose, applicable authority, and the governing relationship.

7. Legal Bases for Processing Where Applicable

Privacy laws in some jurisdictions require an identified legal basis for processing personal information.

Where the European Economic Area, United Kingdom, Switzerland, or another comparable legal framework applies, processing may rely on one or more lawful bases depending on the activity.

Contractual necessity may support processing required to provide an enrolled Member's Legacy Guruuz services.

Consent may support processing where an individual makes an informed, voluntary choice, including certain permissions, communications, sensitive information, or separately authorized identity-linked capabilities.

Legitimate interests may support appropriate activities such as maintaining service security, preventing fraud, protecting rights, administering ordinary business operations, supporting Members, improving service reliability, and protecting the integrity of Legacy Guruuz, provided those interests are not overridden by applicable individual rights.

Legal obligations may require processing or retention for taxation, accounting, lawful requests, safety reporting, regulatory requirements, rights administration, or other obligations.

Other lawful bases may apply where permitted by governing law.

Where information qualifies as a special category of personal data or receives heightened protection under applicable law, we will rely on an additional legally recognized condition where required, which may include explicit consent or another applicable basis.

8. AI, Haliʻa, and the Legacy Experience

Legacy Guruuz uses artificial intelligence and related technologies to provide guided Legacy experiences.

Authorized information may be processed to support conversation, storytelling, transcription, organization, continuity, Member-directed preservation, service quality, reliability, safety, and other authorized Legacy Guruuz functions.

Haliʻa may use information entrusted to the Member’s Legacy environment to support conversations within applicable permissions.

AI-assisted output may include summaries, questions, interpretations, or generated language and may contain errors.

Members and authorized contributors may clarify or correct information within their applicable authority.

9. General-Purpose AI Model Training

Private Legacy Content is not used to train general-purpose artificial intelligence models for unrelated users without separate express authorization.

Authorized AI, cloud, infrastructure, transcription, retrieval, security, and related service providers may process information as reasonably necessary to provide Legacy Guruuz functionality under applicable agreements, safeguards, configurations, and privacy requirements.

A future use of Private Legacy Content for materially different general-purpose model training would require the corresponding separate express authorization.

10. Legacy Content Safety Review

Submitted images, video, audio, artwork, documents, and other media may be reviewed for safety, rights, authenticity, security, or legal compliance before becoming available for active Legacy Guruuz use.

Review may involve automated tools and, where reasonably necessary, limited authorized human review.

Possible outcomes may include approval, a request for additional information or permission, restriction, removal, or another action required by the Content Standards, governing agreements, or law.

Human review remains limited to authorized personnel and the information reasonably necessary to evaluate the applicable concern.

Material involving suspected child sexual exploitation, nonconsensual intimate imagery, unlawful sexual content, credible threats, or other serious concerns may require separate preservation, restriction, reporting, escalation, or cooperation procedures under applicable law.

Further requirements appear in the Content Standards and Terms of Service.

11. Voice, Image, Likeness, and Identity-Linked Processing

Voice carries identity, emotional meaning, cadence, humor, and recognizable human presence.

Members may provide audio, photographs, and video for ordinary functions such as storage, playback, transcription, organization, retrieval, preservation, safety review, and conversational continuity.

Ordinary submission of those materials does not by itself authorize creation of a cloned voice, synthetic voice, biometric voice model, voiceprint used for identity modeling, digital replica, photorealistic synthetic likeness, or comparable materially expanded identity capability.

Those uses require applicable authority and separate heightened authorization.

Identity verification, rights-holder verification, licensing, estate authority, privacy rights, publicity rights, biometric law, or other legal requirements may also apply depending on the capability and jurisdiction.

12. Living Legacy

A Living Legacy is created while the individual whose Legacy is being preserved is alive and participating directly.

Members may choose to preserve stories, wisdom, values, voice, worldview, humor, teachings, judgment, relationships, memories, reflections, and approved source materials.

Continuing participation allows Members to add context, correct information, update permissions, manage sharing, change Stewardship choices, and request eligible removal according to available functionality, governing agreements, and law.

13. Remembered Legacy and Deceased Individuals

Legacy Guruuz may preserve and organize materials concerning a deceased person through authorized family, estate, organizational, archival, published, licensed, public, or other approved sources.

Privacy law may treat deceased individuals differently from living individuals. Our stewardship standards nevertheless continue to consider attribution, cultural context, dignity, estate and rights-holder authority, family and relational sensitivity, image and likeness rights, licensing, provenance, reputation, source authenticity, and voice rights.

Materials concerning a deceased person often contain information about living people.

Personal information concerning living individuals remains subject to applicable privacy rights and protections.

14. Information About Other People

A Legacy naturally contains relationships.

Members and Contributors may share memories, stories, photographs, correspondence, recordings, or other materials involving family members, friends, colleagues, and other people.

Providing material about another person requires an appropriate basis for the contribution and respect for applicable privacy, intellectual-property, confidentiality, image, likeness, voice, contractual, and other rights.

Knowing something about another person does not create unlimited authority to authorize every future use of that person's information or identity.

We may request additional permission, documentation, attribution, clarification, restriction, or removal when another person's rights materially affect a proposed Legacy use.

15. Member-Directed Sharing

Private Legacy Content remains governed by Member permissions, service configuration, applicable rights, and governing agreements.

Members may be able to authorize selected access for family members, Contributors, Stewards, invited participants, or other approved audiences.

A change in audience may require a corresponding Member action, permission, notice, or control.

Information intentionally shared with another person can be copied, stored, discussed, photographed, recorded, or redistributed by that recipient outside Legacy Guruuz and beyond our direct control.

Preservation, private access, family sharing, public publication, marketing use, and Legacy Guruu embodiment remain distinct permission contexts.

16. How We Disclose Information

Information may be disclosed in defined circumstances to service providers supporting hosting, AI processing, cloud infrastructure, storage, authentication, communications, transcription, security, analytics, payment processing, or other operational functions; authorized Company personnel, contractors, or advisors with a legitimate business need; authorized Stewards; authorized Contributors or family participants where permissions allow; estates, rights-holders, licensors, or representatives where appropriate; professional advisors such as attorneys, accountants, insurers, or auditors; government authorities or other parties where valid legal process or applicable law requires disclosure; or parties involved in a merger, financing, acquisition, reorganization, sale of assets, or comparable corporate transaction subject to applicable safeguards.

We may also disclose information when reasonably necessary to protect people, privacy, rights, safety, security, fraud prevention, intellectual property, Company systems, or service integrity.

Access and disclosure are intended to remain proportionate to the purpose being served.

17. Service Providers and Processors

Operating Legacy Guruuz may require specialized service providers.

Depending on the function, providers may support artificial intelligence, cloud infrastructure, hosting, storage, authentication, cybersecurity, transcription, communications, payments, analytics, video, email, support, and related operations.

We seek to select and govern providers in a manner appropriate to the nature and sensitivity of information they process.

Where applicable law treats a provider as a processor, service provider, contractor, subprocessor, or comparable regulated role, corresponding contractual and data-protection requirements will apply.

Provider relationships may change as technology and service architecture evolve.

18. Sale, Advertising, and Commercial Data Use

Private Legacy Content is a trust-bearing asset.

We do not sell Private Legacy Content.

We do not share Private Legacy Content for cross-context behavioral advertising.

The public Website may use ordinary analytics, attribution, measurement, communications, or campaign technologies consistent with applicable notice and choice requirements.

Where a particular technology creates a regulated sale, sharing, targeted-advertising, profiling, or comparable opt-out right under applicable law, we will provide the corresponding choice mechanism.

Legally recognized browser-based opt-out signals, including Global Privacy Control where applicable, will be honored as required by governing law.

19. Cookies, Analytics, and Similar Technologies

The Website and Product Environment may use cookies, pixels, local storage, analytics tools, and similar technologies to maintain essential functionality, remember preferences, authenticate sessions, understand traffic and usage, improve performance, measure engagement, understand campaign effectiveness, support security, and reduce fraud.

Essential technologies may operate where necessary to provide requested functionality or maintain security.

Where applicable law requires consent before non-essential cookies or similar technologies are placed or accessed, those technologies will be governed through the corresponding consent or preference mechanism.

Browser, device, and Website controls may provide additional choices.

20. Email, SMS, and Other Communications

Communications may concern enrollment, onboarding, account activity, Member support, scheduling, Stewardship, Contributor invitations, service updates, Legacy-building reminders, transactions, privacy, security, and other operational matters.

Promotional communications will use applicable consent and preference mechanisms.

Marketing preferences may generally be managed through available unsubscribe instructions.

Operational, account, security, privacy, payment, and transactional communications may continue where reasonably necessary to administer an active relationship or satisfy legal obligations.

SMS and comparable communications will follow applicable consent requirements where used.

21. Payments and Transaction Information

Payments may be processed through third-party payment providers operating under their own terms, security practices, and privacy notices.

We seek to minimize direct storage of complete payment credentials.

Transaction records may be retained where reasonably necessary for enrollment, refunds, accounting, taxation, fraud prevention, customer support, contractual administration, dispute resolution, and legal compliance.

22. Retention, Cancellation, Refunds, and Deletion

Personal information and Legacy Content are retained according to their purpose, Member relationship, permissions, service requirements, rights obligations, security needs, and applicable law.

Retention may support ongoing Legacy preservation, continuity, Stewardship, provenance, permission history, rights administration, account administration, security, fraud prevention, financial records, dispute resolution, legal compliance, or evidence of Member direction.

Members may request deletion, export, release, correction, or other eligible action according to available functionality, governing agreements, and applicable law.

Founding 100 Refund Period

When a qualifying Founding Member exercises the 30-Day Money-Back Guarantee, the Member's Legacy Content and associated Member account materials will be deleted according to the Terms of Service and applicable deletion procedures.

Limited transaction, accounting, tax, security, rights-administration, fraud-prevention, dispute, legal-compliance, or deletion-verification records may remain where retention is reasonably necessary or required.

Protected backup systems may require a reasonable period before deleted information cycles out of backup storage.

Copies retained solely for legal, security, transaction, rights, or backup purposes do not remain available as active Legacy Content.

Cancellation After the Refund Period

Where governing Legacy Guruuz terms provide for release or export of Member materials following cancellation, we will administer that process according to the applicable terms, technical capabilities, permissions, rights, retention obligations, and law.

23. Security and Incident Response

We use administrative, technical, and organizational safeguards designed to protect personal information, accounts, Legacy Content, and Company systems.

Measures may include access controls, authentication, role-based permissions, protected infrastructure, secure transmission where appropriate, operational access discipline, monitoring, backup and recovery practices, provider controls, internal governance, and content-safety measures.

Digital systems carry inherent risk, and no online service can guarantee absolute security.

Processes are maintained to identify, investigate, contain, document, remediate, and respond to suspected security incidents.

Where applicable law requires notification following a qualifying incident, required notices and corresponding response measures will be provided.

Members and participants can strengthen security by protecting authentication credentials and promptly reporting suspected unauthorized access.

24. Children and Minors

Direct authenticated participation in the initial Legacy Guruuz service is intended for adults.

Members, Contributors, Stewards, and other independently authenticated participants must be at least 18 unless we expressly introduce a separately governed age-appropriate experience.

Family stories, photographs, recordings, and Legacy materials may naturally include children when lawfully provided by an authorized adult.

No independent child Member or Contributor experience is presently offered.

Any future service designed for direct use by minors will require age-aware privacy architecture, parental or guardian authorization where applicable, appropriate notices, consent mechanisms, safety controls, and legal review before deployment.

Content involving minors also receives heightened safety, dignity, permission, and exploitation protections.

25. Privacy Rights and Choices

Depending on location and applicable law, individuals may have rights concerning their personal information.

Those rights may include access; information about collection, processing, and disclosure; correction; deletion; portability; withdrawal of consent where consent provides the applicable basis; objection or restriction; rights concerning certain sensitive information; opt-out rights involving covered sale, sharing, targeted advertising, or profiling; appeal rights; and protection from discriminatory treatment for exercising applicable privacy rights.

Rights vary by jurisdiction and are subject to legal exceptions.

Requests may be submitted to:

Privacy@LegacyGuruuz.com

Additional privacy-request mechanisms may be offered through the Website or Product Environment.

Identity, authority, relationship to a Legacy, Steward status, Contributor status, or rights-holder authority may require verification before a request is fulfilled.

A request involving information connected to multiple people may require careful consideration of each person's rights, provenance, permissions, and interests.

26. California Privacy Rights

California residents may have rights under the California Consumer Privacy Act, as amended, where that law applies to Guruu International Inc. or the relevant processing activity.

Depending on applicability, rights may include knowing categories and specific pieces of personal information collected; learning how information is used and disclosed; requesting access, correction, or deletion; receiving eligible information in a portable form; opting out of covered sale or sharing; limiting certain uses or disclosures of sensitive personal information where the right applies; and exercising rights without unlawful discriminatory treatment.

Categories of information processed through Legacy Guruuz may include identifiers, customer and account records, commercial and transaction information, internet or network activity, approximate geolocation, audio and visual information, communications, family and relationship information, submitted Legacy Content, sensitive personal information voluntarily provided, and inferences or organizational information created through service interactions.

Private Legacy Content is not sold and is not shared for cross-context behavioral advertising.

Where California law requires an additional disclosure, opt-out mechanism, sensitive-information control, or other choice based on a specific technology or processing activity, we will provide the corresponding mechanism.

27. European, United Kingdom, and Swiss Privacy Rights

Where the General Data Protection Regulation, United Kingdom GDPR, Swiss data-protection law, or comparable protections apply, individuals may have rights including access, correction, erasure, portability, restriction of processing, objection to certain processing, and withdrawal of consent where consent provides the legal basis.

Consent may generally be withdrawn prospectively without affecting processing lawfully completed before withdrawal.

Individuals may also have the right to lodge a complaint with an applicable data-protection or supervisory authority.

Certain rights depend upon the legal basis, nature of the information, purpose of processing, and available legal exceptions.

Where applicable law creates additional rights concerning automated decision-making, profiling, sensitive information, or direct marketing, corresponding rights and disclosures will be provided as required.

28. International Processing and Data Transfers

Guruu International Inc. operates from the United States.

Information may be processed in the United States and in other locations where authorized service providers operate.

When personal information protected by European, United Kingdom, Swiss, or other international data-transfer requirements is transferred to another jurisdiction, we will use an applicable transfer mechanism or safeguard where required.

Depending on the circumstances, safeguards may include approved contractual provisions, legally recognized transfer frameworks, adequacy determinations, supplementary protections, consent where legally appropriate, or another authorized transfer mechanism.

Jurisdiction-specific privacy notices or protections may supplement this Policy as Legacy Guruuz expands internationally.

29. Verification, Authorized Agents, and Appeals

Privacy rights often require verification so that information is not released, altered, or deleted at the request of an unauthorized person.

Verification measures will be proportionate to the request, sensitivity of the information, and applicable legal requirements.

Authorized agents may submit requests where governing law permits.

We may require evidence of the agent's authority and, where allowed, may also verify the identity of the individual whose rights are being exercised.

Where applicable law provides a right to appeal a privacy-request decision, instructions for submitting an appeal will be provided with the response.

30. Aggregated and Deidentified Information

We may create aggregated or deidentified information for purposes such as service analysis, security, operational planning, reliability, product improvement, and understanding how Legacy Guruuz is used.

Where information is maintained as legally recognized deidentified information, we will not attempt to reidentify it except where permitted for security, testing, compliance, or another purpose allowed by applicable law.

Deidentified information is not treated as Private Legacy Content when it can no longer reasonably be linked to an identified Member, Contributor, Steward, Legacy, or individual.

31. Third-Party Services and Links

The Website and Product Environment may interact with services supporting payment processing, video, communications, cloud infrastructure, hosting, authentication, analytics, social platforms, security, or other operations.

When an individual interacts directly with a third-party service, that provider's terms and privacy practices may apply.

Embedded media and external links may also involve technology operated by the applicable provider.

We evaluate provider relationships according to the role they perform and the sensitivity of information involved, while recognizing that independently controlled third parties govern their own services.

32. Changes to This Privacy Policy

Privacy practices will evolve as Legacy Guruuz, technology, law, and the services surrounding a Legacy develop.

The Version, Effective Date, and Last Updated date identify the current published Policy.

Material changes may also be communicated through the Website, Product Environment, email, or another appropriate channel.

Where governing law requires renewed notice, consent, acknowledgment, or choice for a material change, the corresponding mechanism will be provided before the affected processing occurs where required.

33. Contact Us

Privacy questions, requests, or concerns may be directed to:

Legacy Guruuz
Guruu International Inc.

Privacy: Privacy@LegacyGuruuz.com

Legal: Legal@LegacyGuruuz.com

Website: LegacyGuruuz.com

Member Environment: App.LegacyGuruuz.com

Corporate Website: GuruuInternational.com

© 2026 Guruu International Inc. All rights reserved.