Privacy Policy

Effective date: 18 April 2026. This policy describes how Gutly (“we”, “us”) handles information when you use the Gutly mobile application (the “App”).

The App is listed on the Apple App Store and Google Play using developer accounts registered in the United Kingdom. Privacy rules where you live may also apply, as explained in this policy.

1. What Gutly is (and is not)

Gutly is a decision-support tool. It does not make decisions for you, does not replace human judgment, and only provides structured recommendations and perspectives based on information you choose to enter. Outputs are informational, not authoritative, and not binding on you or anyone else.

2. Data we collect

Depending on how you use the App, we may process the categories below. You are not required to provide direct personal identifiers (such as your legal name or government ID) for core functionality.

This may include:

• User inputs you submit in the App, such as dilemmas, questions, decision context, constraints, and similar text you type or select while using features.
• Preferences and configuration, such as response style, length, driver selections, feedback where offered, and other in-app settings that personalize your experience.
• Usage data relating to how the App is used, such as feature interactions, timestamps, diagnostics needed to operate the service, and similar technical or product analytics limited to what is necessary to run and improve the App.
• Account or device identifiers that our infrastructure uses to provide optional cloud features (for example, an authentication or app-account identifier managed by our service provider), where those features are enabled.

3. Sensitive personal data

The App does not require you to provide special categories of personal data (for example, health data, biometric data used for identification, or precise location) for core functionality. If you voluntarily include sensitive information in free-text fields, you choose to provide it; we treat it as part of your inputs and process it only as described in this policy.

4. No sale of personal data

We do not sell your personal information. We do not disclose your information to third parties for their independent marketing purposes.

5. Purposes and legal bases

We process information as necessary to provide and maintain the App, personalize responses based on your inputs and preferences, secure the service, troubleshoot issues, comply with law, and understand aggregate or product-level usage so we can improve experience and reliability. Where required by law, we rely on appropriate bases such as performance of a contract, legitimate interests that are not overridden by your rights, or consent where we specifically ask for it.

6. Sync user data (optional cloud backup)

If you use “Sync my data” or similar features, we store a copy of certain local App data—such as preferences and usage-related or history data as implemented in the product—in cloud storage associated with your account or device identity handled by our backend.

Sync is optional. Synced data is used to restore your experience across devices where supported, maintain backups you request, and improve the App’s functionality and reliability. It is not used to sell advertising profiles.

7. AI processing

When you request AI-generated content, your inputs may be sent to our systems and/or model providers we use to generate responses. AI outputs are generated dynamically and may be incomplete, incorrect, or unsuitable for your situation. Do not rely on outputs as professional advice. See the Terms of Service for full disclaimers.

8. Storage and security

We implement appropriate technical and organizational measures designed to protect information against unauthorized access, loss, or misuse. Data is processed using Google Firebase and related Google Cloud infrastructure (or successor services we may use), which provide industry-standard security controls. No method of transmission or storage is completely secure; we cannot guarantee absolute security.

9. International transfers

Our service providers may process data in countries other than your own. Where transfers require safeguards, we use mechanisms appropriate under applicable law (such as standard contractual clauses or equivalent protections).

10. Retention

We retain information only as long as needed for the purposes described in this policy, unless a longer period is required or permitted by law. Local data on your device remains under your control until you delete it or uninstall the App. Cloud-synced data is retained while your account or sync relationship exists and for a reasonable period afterward to allow recovery, security, and legal compliance, after which we delete or de-identify it where feasible.

11. Your rights (LGPD, UK GDPR, and similar laws)

Brazil’s Lei Geral de Proteção de Dados (LGPD) applies where Brazilian law governs your relationship with us. If you are in the United Kingdom, the UK GDPR and the Data Protection Act 2018 provide comparable protections. Depending on where you live and the law that applies, you may have rights to:

• Access: obtain confirmation of processing and a copy of your personal data where applicable;
• Correction: request correction of incomplete, inaccurate, or outdated data;
• Deletion: request deletion of personal data subject to legal exceptions;
• Portability, objection, restriction, and withdrawal of consent where relevant under applicable law.

You may exercise rights by contacting us at the email below. You may also lodge a complaint with your local supervisory authority. In the United Kingdom, the supervisory authority is the Information Commissioner’s Office (ICO); see ico.org.uk.

12. Children

The App is not directed at children under the age required by applicable law for valid consent to data processing in their jurisdiction. Do not use the App if you do not meet that age requirement.

13. Changes to this policy

We may update this Privacy Policy from time to time. We will post the updated version in the App and revise the effective date. If changes are material, we will provide additional notice where required by law.

14. Contact

Questions or requests about privacy: hello@gutly.tech