GoGira Privacy Policy

We (and/or trusted partners acting on our behalf) automatically collect certain information when you visit, use, or navigate the Services. This does not reveal your specific identity (like your full name) but may include:

• Device & Usage Data: IP address; device identifiers; browser and device characteristics; operating system; language preferences; referring URLs; device name; Internet service provider or mobile carrier; system configuration; pages/screens viewed; navigation paths; time spent; access times; error logs/crash data; diagnostic and performance data.
• Location Information: We may collect or process general location information, such as ZIP code, county, city, state, region, or country, including location information you provide directly or approximate location inferred from IP address or similar technical signals. General location is used to provide core matching features, including relevant higher-education, career, scholarship, school, service, and event recommendations.

With your permission, we may also collect precise geolocation from your device, such as GPS-based location, to provide optional nearby opportunities, events, schools, services, or location-based recommendations. Precise geolocation is optional, requires your opt-in permission, and may be turned off at any time through your GoGira settings or device settings. We do not use precise geolocation for hidden tracking, continuous monitoring, unrelated advertising, data brokerage, or cross-context behavioral advertising.

• Preferences & Engagement: Interactions with our emails, text messages, push notifications, and in-app messages.
• Support Telemetry: Dates of contact; chat transcripts; call logs (including phone numbers you use to contact support).
• Cookies/Similar Tech: Cookies, pixels, tags, and local storage used for session integrity, security, preferences, analytics, and (for adults off-platform) marketing attribution. See Cookies and Other Tracking Technologies.

Do Not Track: Some browsers send DNT signals; we currently do not respond to DNT.

To provide relevant Services and keep records current, we may obtain information about you from:

• Public databases and data providers
• Joint marketing/affiliate partners
• Social media platforms (if you interact via your social account)

Examples: mailing addresses; job titles; email addresses; phone numbers; intent/behavior data; IP addresses; social handles and URLs; and public profile information, subject to your social platform settings.

For minors, we do not buy, license, append, or otherwise use third-party marketing profiles, brokered audience segments, intent data, or similar commercial data for advertising, profiling, or targeted outreach purposes.

You may provide information when you register, create a profile, use features, fill forms, upload content, communicate with us, or otherwise use the Services. Below are the main user roles and the personal information we may collect.

Partner & Higher-Ed Content. Inside GoGira, colleges/universities (“Higher-Ed”) and career, financial-aid, counseling, internship, employer, tutoring, and related service organizations (“Partners”) may publish information, opportunities, events, and other content so students can discover, evaluate, match with, and connect to them. This content may be promotional in nature, but within GoGira it functions as first-party matching and connection content, not third-party advertising delivered through external ad networks or cross-context behavioral advertising.

Profile. Your “Profile” means the information you choose to include in GoGira (for example: first name/initial, education history and grades, test information, extracurriculars/interests, references/recommendations, uploads, contact preferences, resumes, portfolio, and approximate location). Your “Profile” means the information you choose to include in GoGira, for example: first name/initial, education history and grades, test information, extracurriculars/interests, references/recommendations, uploads, contact preferences, resumes, portfolio, and general location. General location may include ZIP code, county, city, state, or similar non-precise location information used for matching.

GoGira does not include precise real-time geolocation in your profile by default. Precise geolocation is collected only if you enable the optional real-time geolocation feature and is used only to support nearby opportunities, events, services, or location-based recommendations, unless you separately choose to share location information through a specific GoGira feature or workflow.

Profile Sharing. Students may choose to share their profile with higher-ed institutions and/or partners through GoGira for discovery, matching, and connection purposes. If a student shares their profile, approved higher-ed institutions and/or partners may view the information the student has provided within GoGira as part of that shared profile.

Profile sharing is not the same as contact sharing. Sharing a profile does not automatically share the student's direct contact information and does not by itself authorize off-platform contact by phone, text, email, or other channels.

Connections. If a student chooses to connect with a specific higher-ed institution or partner through GoGira, that specific recipient may also view the student's direct contact information and applicable communication preferences as made available through the relevant GoGira feature or workflow.

Messaging and User-Directed Sharing. Students may also choose to share contact information or other information through messages or other interactions at their own discretion. Information a student voluntarily shares in messages or other user-directed interactions is shared by the student.

Compliance note (U.S. states). Because some state laws define “sale” or “sharing” broadly, allowing profile information to be made visible to higher-ed institutions or partners before a connection may in some circumstances be treated as a sale/share. We therefore provide Do Not Sell/Share controls and honor Global Privacy Control (GPC) where required. For ages 13-15, where required, we obtain opt-in before enabling any activity a state might treat as a sale/share. Users under 13 may not use GoGira.

We do not run third-party ad networks inside GoGira. Information posted by Higher-Ed and Partners in GoGira functions as first-party matching and connection content within GoGira, not third-party ad-network advertising.

Off-platform campaigns to students and parents. We may run awareness campaigns on third-party services (e.g., search engines or social media) to explain GoGira and our Services.

• Students ages 13-17. We may show contextual or age-gated ads to teens using the platform's native tools (e.g., “13-17”). We do not: (i) upload or use student lists; (ii) build lookalike audiences from minors' data; (iii) retarget minors from pixels or cookies; or (iv) otherwise use minors' personal information from GoGira to select, target, or measure ads. Where a law restricts targeted advertising to minors (e.g., certain U.S. states), we do not run such targeted ads to those audiences and honor teen opt-out rights.
• Measurement & tracking. If we use off-platform measurement, we limit it to aggregate reporting. We avoid cross-context behavioral tracking tied to minors and honor legally required signals and controls (including Do Not Sell/Share and Global Privacy Control where applicable).
• No use of minors' in-app data for ads. We do not use student profile content or other minors' personal information collected in GoGira to create advertising audiences or to run off-platform campaigns.

We may share personal information with companies that provide services to GoGira, such as hosting, storage, communications delivery, customer support, payment processing, content delivery, security, fraud prevention, moderation support, analytics, and similar operational services. These service providers process information only on GoGira's behalf and only for the purpose of providing services to GoGira. They may not use personal information collected through GoGira for their own independent advertising, marketing, profiling, sale, model training, product improvement, or other unrelated purposes.

For clarity, GoGira does not make students' racial or ethnic demographic information available to higher-ed admissions users for admissions-review purposes through GoGira.

GoGira is designed to help students discover, evaluate, match with, and connect to higher-ed institutions and related partners, including scholarship, financial-aid, counseling, internship, employer, tutoring, and similar opportunity providers. We may share information with these recipients only as permitted by the student's choices, actions, and use of the Services, including when:

• a student chooses to share their profile with higher-ed institutions and/or partners through GoGira;
• a student chooses to connect, message, apply, request information, RSVP, submit a form, share media, or otherwise engage with a higher-ed institution or partner;
• a student invites, designates, or authorizes a reference, counselor, parent/guardian, or similar participant;
• a school, institution, or program authorizes or directs the sharing in connection with an education-related workflow; or
• sharing is otherwise necessary to provide a feature the student requested.

These recipients may use information made available through GoGira only for the specific educational, recruiting, advising, scholarship, internship, employment, counseling, tutoring, financial-aid, or other service purpose for which the information was shared through GoGira.

Unless separately authorized by the student, school, or applicable law, these recipients may not:

• sell personal information received through GoGira;
• use such information for cross-context behavioral advertising;
• create unrelated marketing audiences or unrelated commercial profiles;
• use student-level GoGira data for independent data brokerage or enrichment purposes;
• redisclose student-level information except as reasonably necessary for the specific purpose for which it was shared, to their own service providers acting on their behalf, or as required by law; or
• use private student content, including direct messages, reference content, essays, portfolio materials, or Fast-Track References, for generalized AI or machine-learning training, public marketing, or unrelated commercial purposes without additional explicit permission where required.

Recipients are independently responsible for ensuring they have any required consent under applicable law for specific communication methods (such as SMS/text or automated communications) and for honoring opt-out requests.

General location may be included in profile, matching, or workflow information made available to higher-ed institutions, partners, or other authorized recipients when a student chooses to share a profile, connect, submit information, request information, RSVP, apply, message, or otherwise engage through a GoGira feature or workflow.

Precise geolocation is not shared with higher-ed institutions, partners, or other users by default. We share precise geolocation only if the Service clearly indicates that location will be shared and the user separately chooses to share it through a specific feature or workflow, or where required by law or necessary for safety or security.

If a student chooses to share their profile, approved higher-ed institutions and/or partners may view the information the student has provided within GoGira as part of that shared profile before a connection occurs. A student's direct contact information is not shared unless and until the student connects with a specific higher-ed institution or partner through GoGira. When a student makes that connection, that specific recipient may also view the student's direct contact information and applicable communication preferences as made available through the relevant GoGira feature or workflow.

Where permitted by law and consistent with this Policy, higher-ed institutions and partners may use information about shared profiles, matches, or non-matches to evaluate fit, understand interest, improve their use of GoGira, and manage their own student-facing workflows. However, unless the student separately authorizes continued engagement or disclosure, recipients may not retain or repurpose student-level non-connected or non-matched information beyond the period reasonably necessary for the applicable matching, review, outreach, or service workflow. Deidentified or aggregated reporting may be used for internal analysis, performance measurement, planning, and service improvement.

If a student invites or authorizes a reference, evaluator, counselor, coach, employer, mentor, or similar person to submit information about the student, we may share that content with the student, designated recipients, and other participants in the relevant workflow as described at the time of submission or sharing. Reference content, evaluative materials, and Fast-Track References may be used only to assess, support, or verify the student for the purpose for which the reference or evaluation was requested, submitted, or shared. They may not be sold, publicly posted, or used for unrelated marketing, profiling, or commercial purposes.

If a student adds a parent or guardian or otherwise authorizes family access through available GoGira features, we may share the information necessary to provide those features, subject to the student's settings, the feature design, and applicable law.

We may disclose information to courts, law enforcement, regulators, child-safety organizations, or other governmental or authorized parties if we believe doing so is necessary to:

• comply with law, regulation, legal process, or enforceable governmental request;
• protect the rights, safety, integrity, or property of GoGira, our users, or others;
• detect, investigate, or prevent fraud, abuse, security incidents, or unlawful activity; or
• respond to emergencies or child-safety concerns.

We may share or transfer information in connection with an actual or proposed merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar corporate transaction, subject to customary confidentiality and legal protections.

Communication preferences may include email, SMS/text messaging, in-app messaging, push notifications, and physical mail, as selected or consented to by the user through GoGira.

We do not share your mobile number or SMS opt-in/consent with third parties for their own independent marketing by default. We may share mobile information with communications service providers and other service providers as necessary to deliver GoGira messaging features, authenticate accounts, prevent fraud, support safety, and comply with law.

If a student chooses to connect with, or separately share contact information with, a specific higher-ed institution, partner, counselor, employer, scholarship provider, or other authorized recipient through GoGira, GoGira may make the student's contact information and applicable communication preferences available to that specific recipient for the relevant connection, outreach, or workflow.

Any consent a user provides to receive messages from GoGira does not, by itself, constitute consent to receive marketing, promotional, autodialed, or prerecorded calls or text messages from a higher-ed institution, partner, or other recipient. Those recipients are responsible for obtaining any consent required by applicable law for their own calls or texts and for honoring opt-out requests.

GoGira may allow users to interact with or navigate to third-party websites, applications, forms, or services. Once a user leaves GoGira or submits information directly to a third party, that third party's privacy policy and terms apply to its collection and use of information. Post-connection or post-click processing by a higher-ed institution, partner, or other recipient may be governed by that recipient's own privacy notice.

• We disclosed Categories A, B, C, D, F, G (approximate only), I, J, K, and applicable L to service providers and, where applicable, to higher-ed institutions, partners, and other authorized recipients for the business purposes described in this Policy.
• However, GoGira does not make students' racial or ethnic demographic information available to higher-ed admissions users for admissions-review purposes through GoGira. Where applicable and permitted by law, certain demographic information may be made available to other authorized departments, programs, or recipients, such as financial aid, internships, scholarships, reporting, compliance, or similar workflows, only for the specific purpose for which the information was provided, requested, or lawfully processed.
• We do not run third-party ad networks inside GoGira and do not conduct cross-context behavioral advertising in product.

You may request access, deletion, correction, or a portable copy of your data, and opt out of sale/sharing where applicable. We will verify requests as required by law and respond within statutory timelines. You may use an authorized agent subject to verification. We do not discriminate for exercising rights.

If we offer a financial incentive tied to personal information, we will disclose required terms (including a good-faith estimate of data value and calculation method). You may withdraw at any time.

These states provide similar rights (access, correction, deletion, portability, opt-out of targeted ads/sale/profiling). We provide opt-outs and an appeals process within required timelines.

We apply data minimization and do not engage in targeted advertising to minors.

• Controller: Shyres SCR Inc. (GoGira).
• Legal Bases: Consent; contract; legitimate interests; legal obligation; vital interests.
• Transfers: We use SCCs and other safeguards where required.
• Your Rights: Access, rectification, erasure, restriction, objection, portability, and withdrawal of consent where applicable. You may lodge a complaint with your local DPA.

We rely on express or implied consent as required; you may withdraw consent (subject to legal/contractual limits). Complaint rights to the OPC or provincial authorities remain available.

We comply with applicable national privacy principles. You may request access/correction and lodge complaints with the relevant regulator.