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Privacy Policy




Last Updated: May 20, 2019, including all of its features and content and related websites that we own and control (“Website”), is a service made available by Insieme LLC, doing business as Gaturso LLC (together with its present and future parent, subsidiary, affiliate, and successor companies and each of their respective members, managers, officers, directors, employees, agents, and representatives, “Gaturso”, “we”, “us”, or “our”).


How This Privacy Policy Applies


Your privacy is very important to us, and in order to best protect your information, we have adopted this privacy policy (“Privacy Policy”), which applies to any and all information you submit to us in connection with your access to and/or use of the Website. This Privacy Policy describes the information we collect from you through the Website, how we use that information, and our legal basis for doing so. It also covers whether and how that information may be shared and your rights and choices regarding the information you provide to us. It also covers whether and how that information may be shared and your rights and choices regarding the information you provide to us.


By using the Website, you are accepting the practices described in this Privacy Policy (including new versions of this Privacy Policy when and as they go into effect), and our Terms and Conditions of Use (“Terms of Use”), which governs this Privacy Policy and contains all disclaimers of warranties and limitation of liabilities. Capitalized words not defined in this Privacy Policy are defined in the Terms of Use.


What Information We Collect and Receive


In order for you to use our Website, we need to collect and process certain information, which depending on how you use the Website, may include:


  • Information you provide by using the Website, such as by submitting Testimonials (as defined in the Terms of Use) and completing forms the Website, such as your name, email address, mailing address, or telephone number. We may ask for this information if you contact us;

  • Details of any requests or transactions you make through the Website. We may from time to time offer products for sale through the Website and partner with certain third-party payment processors to facilitate the transaction, in which case the payment information you submit to us will be collected and used by the payment processor in accordance with its privacy policy;

  • Information about your activity on and interaction with Gaturso, such as your Internet Protocol (IP) address, the type of device or browser you use to access the Website, and your actions on the Website;

  • Information about the ways people visit and interact with our Website in the form of web traffic analytics. You can opt out of being included in Google Analytics at {}. For more information about our use of data analytics to protect and improve our Website, see Cookies and How We Utilize Them below; and

  • Communications you send to us, such as when you request support, send us comments or questions, or report a problem to us.


We also collect and maintain aggregated, anonymized, or pseudonymized information to protect the safety and security of the Website, improve the Website, or comply with legal obligations.


You may decline to provide us with some or all of your information. However, this will limit your ability to use the Website.


Types of Cookies We Utilize


We use the following types of cookies and other technologies:


  • Security: We secure the Website with cookies that facilitate security features and allow us to detect activity that might violate our rules and Terms of Use, such as unauthorized access or activity.

  • Localization: Some cookies help us provide localized experiences, such as displaying the Website in the local language.

  • Site Features and Services: Certain cookies provide greater functionality to the Website and help us deliver our products and services.

  • Performance: We use performance cookies to help us route traffic between servers and understand how the Website is performing so we can provide users with the best experience possible.

  • Analytics and Research: Cookies and other technologies also help us to understand, improve, and research features and content on the Website, such as by using Google Analytics, which you can opt out of at {}.

  • Marketing and Online Behavioral Advertising: Cookies help us deliver targeted advertisements through web browsers and on social media platforms based on your activity on the Website and to track the performance of those ads. In some cases, our partners may use cookies to provide us with information about your interactions with their services. Those third-party cookies would be subject to such third-party service’s privacy policies. The Self-Regulatory Program for Online Behavioral Advertising program provides consumers with the ability to opt-out of having their online behavior recorded and used for advertising purposes. Visit {} to opt out of having your online behavior collected for advertising purposes.


Limiting or Blocking Cookies and Our Do Not Track Policy


Your browser may give you the ability to control cookies, which may depend on the type of cookie, and browsers can be set to reject browser cookies. However, blocking or deleting cookies may prevent you from using most of the Website.


Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. If you block cookies, certain features on the Website may not work. If you block or reject cookies, not all of the tracking described here will stop.


Note that certain options you select are browser- and device-specific.


How We Use the Information We Collect


We use the information we collect for the following purposes:


  • To protect our Website;

  • To enable us to provide you with our Website, and to improve and promote our Website and services;

  • To contact you and customize your experience on the Website; and

  • To track and analyze use of the Website and our services so that we can improve how Gaturso is performing and provide our users with the best experience possible.


European Union Users


European Union data protection law requires a “lawful basis” for collecting and retaining personal information from citizens or residents of the European Economic Area. Our lawful bases include:


  • Consent: In certain cases, you have affirmatively provided us with your consent to collect your personal data for a specific purpose, such as providing your email address when contact us or submit a Testimonial.

  • Contract: We may need your personal data to comply with our contractual obligation to deliver the Website.

  • Legal Obligations: Sometimes the law requires us to collect and use your data.

  • Legitimate Interests: This is a technical term that means we have a good and fair reason to use your data and we do so in ways which do not harm your interests and rights, such as to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom, or interests. For example, we use identity, device, and location information to prevent fraud and abuse and to keep the Website secure, may also send you promotional communications about our Website and services subject to your right to opt out, analyze how users interact with our Website so we can understand better what elements do or do not work well, which allows us to improve and develop the quality of the online experience we offer all our users.


How We Share the Information We Collect


Information that May be Publicly Accessible


If you submit a Testimonial and Gatruso chooses to display that Testimonial on the Website, other Users will be able to view such Testimonial. Do not submit Testimonials with any information, including, without limitation, personal information, that you do not want to be publicly accessible.


Information We Never Share Publicly


The following personal information is never publicly displayed or revealed to other Users:


  • Your name;

  • The date you register for any services we provide through the Website, such as our newsletter/mailing list;

  • Your email address, IP address, mailing address, or phone number;

  • Any other identity verification information or documentation;

  • Any payment information you provide; and

  • Communications you send to us.


Information We Share with Trusted Third-Party Service Providers


We may share certain information pertaining to you with certain trusted third-party service providers to help us provide, improve, promote, or protect the Website, such as when we use services to help us manage our ads on other websites. When we share data with third-party services to help us deliver the Website and our services, we require that those service providers use your information only for the purposes we have authorized and protect your personal information at least to the same standards we do. We may also share information that is aggregated and anonymized in a way that it does not directly identify you.


Information We Share to Protect Gaturso and Comply with the Law


We reserve the right to disclose information we collect from or about you when we believe that doing so is reasonably necessary to comply with the law or law enforcement, to prevent fraud or abuse, or to protect Gaturso’s legal rights, property, or the safety of Gaturso, its users, or others. You hereby authorize us, to share or disclose your personal information, including, without limitation, any content, records, or electronic communications of any kind, when we determine, in our sole discretion, that the disclosure of such information is necessary to identify, contact, or bring legal action against you if and to the extent:


  • You are or may be violating the Terms of Use or this Privacy Policy;

  • You are interfering with the rights or property of Gaturso or a third party;

  • You are violating any applicable law, rule, or regulation;

  • Necessary or required by any applicable law, rule, or regulation; and/or

  • Requested by governmental authorities in the event of any investigation, act of terrorism, or instance of local, regional, or national emergency.


In the event that Gaturso is acquired by or merged with a third-party entity, or sells all or substantially all of its assets, we reserve the right, in any of these circumstances, to transfer or assign the information and content we have collected from our users as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your personal information is treated, transferred, or used.


Links to Other Websites and Services


Our Website may include links to other websites or services whose privacy practices may differ from Gaturso’s privacy practices as described in this Privacy Policy. When you click or otherwise use a link to an external website or service, the privacy policy and data processing disclosures for that website or service govern.


Data Retention


We will retain the information we collect from or about you as long as necessary to provide you with the Website or our services, or as otherwise set forth in this Privacy Policy, and to the extent set out in this Privacy Policy and as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and protect Gaturso’s legal rights. Additionally, we may retain indefinitely any aggregated, anonymized, or pseudonymized information which we may collect and maintain.


Cross-Border Data Transfers


Gaturso is based in the United States so your information will be collected and processed in the United States, which has its own laws governing data protection and access to it, including by the government. If you reside outside of the United States, be advised that the rules that protect your personal information under United States federal, state, and local law may differ from those of your home country.


Children’s Privacy


The privacy of children is of the utmost importance, and we are committed to complying with the federal Children’s Online Privacy Protection Act (COPPA). Gaturso does not knowingly collect, use, or disclose personal information from children under the age of thirteen (13). If we ever discover that we have inadvertently collected personal information from children under the age of thirteen (13) on or through the Website, we will delete it from our records as soon as possible. If you are a parent or legal guardian of a child under the age of thirteen (13) and believe that we have collected personal information from your child, please email us at, and we will take steps to delete such personal information from our records as soon as possible.


Accessing Your Information


Users residing in certain countries, including citizens or residents of the European Economic Area, are afforded certain rights regarding their personal information. Except where an exception or exemption applies, these rights include the ability to access, correct, and request deletion of such user’s personal information. Even after you request we delete your personal information, we may retain certain information as required by law or as necessary for our legitimate business purposes.


Email Notifications


We want to communicate with you only if you want to hear from us. You may also elect to receive certain marketing email communications, in accordance with your preferences, and from which you may opt out at any time by adjusting your notification settings. We will also send you service-related announcements when and as necessary. We try to keep emails to a minimum and give you the ability to opt in to any marketing communications we send.


We maintain a strict no-spam policy. We will not use false or misleading subjects or email addresses, identify the message as an advertisement in a reasonable way, include the physical address of our business, monitor our third-party email marketing services for compliance, honor opt-out/unsubscribe requests quickly, and allow users to unsubscribe by using the link at the bottom of each email. If you are having problems unsubscribing please contact us at by forwarding the email communication and including the word “Unsubscribe” in the subject line and we will use reasonable efforts to remove you within seven (7) business days. Please note that we will not process any unsubscribe requests submitted as direct replies to any newsletter.




We take security seriously, and the security of your personal data is important to us. We follow industry-standard practices to protect the data we collect and maintain, including using Transport Layer Security (TLS) to encrypt information as it travels over the Internet. No method of transmission over the Internet or electronic storage is completely secure, so we cannot guarantee its absolute security.


Updates to this Privacy Policy


We may change the terms of this Privacy Policy at any time. Whenever we make a material change, we will post on the Website or send you an email. The effective date of the most recent version of this Privacy Policy will appear at the top of this page. New versions of this Privacy Policy will never apply retroactively.




Questions or comments about this Privacy Policy should be sent by email to

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