Privacy Policy

This Privacy Policy is effective as of April 4, 2022.

The purpose of this Privacy Policy is to inform you on how GURU collects, uses and discloses your personal data to provide you with our products and services. It also contains information on some privacy rights that you can exercise.

The terms “we”, “us”, and “our” used in the Privacy Policy refer, collectively, to GURU Organic Energy Corp., GURU Beverage Inc., GURU Beverage Co. and its affiliates, subsidiaries, divisions, successors and assigns and their respective employees, mandataries and agents (collectively, “GURU”).

GURU produces and distributes organic energy drinks crafted with plant-based ingredients (our “Products & Services”). In 1999, GURU launched the world’s first Natural Energy Drink to provide our community (our “Customers”) with a clean source of energy to sustain their demanding lifestyle. GURU’s mission now is to inspire our community to become the best version of themselves and spend more time outside reconnecting with nature.

GURU does not knowingly collect any personal data from children under the age of 16. If you think that your child provided us personal data, we encourage you to contact us immediately and we will do our best to promptly remove such information from our records.

1. WHEN DOES THIS PRIVACY POLICY APPLY?

This Privacy Policy applies when you visit guruenergy.com, investors.guruenergy.com, guru.energy, and all of its subdomains (the “websites”) and/or when you submit your personal data for an employment (the “Careers”) and/or when you subscribe to, use or access our customer services (the “Customer Service”), when you participate in our Affiliate program or any of our online and onsite marketing and promotional activites. Furthermore, it applies when you create an account, you make an online purchase, or when you interact with us through e-mail, our social media pages or through any other form of communication.

We adhere to the Digital Advertising Alliance (“DAA”) and the Digital Advertising Alliance of Canada’s (“DAAC”) interest-based advertising principles, and as such, we will provide you with enhanced notice, transparency and control of our digital marketing practices. Please click here for more information on our interest-based advertising practices.

If you have any questions or concerns regarding how we collect and process your personal data or regarding your privacy, please do not hesitate to contact us:

[email protected]

7236 Waverly, suite 602

Montréal, (Québec) H2R 0C2

1.888.810.4878

2. WHEN DOES THIS PRIVACY POLICY NOT APPLY?

If you click a link that leads you from our websites to a third-party website, application or service, this Privacy Policy does not apply to the collection and processing of personal data by such external services. Indeed, this Privacy Policy does not extend to websites, mobile applications or other services of third parties. We are therefore not liable for their privacy policies, procedures and practices, and we encourage you to review their privacy policies before using these external services.

3. WHAT IS PERSONAL DATA?

Personal Data means any information that relates to an identified or identifiable natural person. Personal data can include online identifiers, such as your name, telephone number, address, e-mail and purchase information, including your credit card number and the history of your purchases.

Personal data also includes information collected about you through cookies and tracking technologies such as beacons and web pixels (together, the “cookies”). Cookies are small blocks of data which are installed on a browser or a device during a session or for a longer period of time, and which remembers preferences or information about you. Click here to learn more about how we use cookies.

Different jurisdictions may have different legal definition(s) of what constitutes personal data. We use a large definition for this Privacy Policy so that we can provide you with as much information as possible, but it is possible that the personal data covered in this Privacy Policy is not protected by your local laws.

4. WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU AND FOR WHAT PURPOSES?

We collect your personal data to deliver our products & services, for example to allow you to purchase our products, create an account and receive discounts, to respond to your inquiries, to send you communications about GURU, to facilitate your participation as an Affiliate and to conduct interest-based marketing and other online and onsite promotional activities.

We might collect your personal data directly from you, automatically through our use of cookies, and in some cases, from third parties. Please read the following section for more details on our practices.

Account Registration Data
Examples: name, e-mail address, password, telephone number

If you choose to create an account on our websites to access our online products & services, we collect the information that you share with us, such as your name, email, telephone number and password, to create this account and manage your purchases. Creating an account with us will also allow you to automate your purchase orders and receive exclusive discounts. We might also send you emails reminding you to complete an unfinished order when items have been added to the shopping cart and the order has not been completed yet.

Purchase Data
Examples: purchased items, credit card information, home/delivery address, transaction history, shipping information, telephone number, tracking order number, subscription program information, date and time of purchase, IP address

We collect “purchase data” about you when you make an online purchase through our website. You can create an account with us to automate your purchase orders or select the “quick buy” option each time you purchase a product. To complete your purchase, we collect and process your credit card information, your delivery address, your order tracking number and subscription program information, if applicable. We also collect and process information about your purchase history. We collect and process Purchase Data to deliver our Products and Services to you. We use a third-party service provider that is PCI DSS compliant, and therefore meets high payment card industry standards to process your credit card information. As such, GURU does not store your credit card information, we only store the four last digits.

Affiliates Data
Examples: Name, email and/or telephone number, country where you are located, promotional information, company information, username, password, currency of choice, Indirect Tax Registration number, account contact information, banking information and social media networks

If you chose to participate in our “Affiliate” program, you will have the opportunity to promote the GURU brand and products across your online social networks in exchange for discounts on our products and for revenues. Revenues are calculated according to your level of influence and lead generation across your social media networks. You will also have access to various promotions, special offers, early access to new product launches, events.

To deliver our Affiliate’s program, we have partnered with Impact, an online platform that supports our referral and partnership efforts. Accordingly, Impact provides a performance partnership program management tool which enables GURU to track events such as impressions, clicks, and conversions. Impact also provides payment processing services on behalf of GURU regarding all payouts made to our Affiliates based on the tracking of actions and lead generation results. We encourage you to review Impact’s Privacy Policy before choosing to participate in our Affiliates program.

As an Affiliate of GURU, we may contact you to discuss potential Affiliate opportunities. You may also be added to our Affiliate Alerts Email List. You may unsubscribe at any time directly in the emails or by contacting us at [email protected]. You may also opt-out of Impact’s promotional email lists by contacting them at [email protected] or by following the unsubscribe link or instructions provided in any emails sent by Impact.

Usage and Technical Log Data
Examples: IP address, browser type, Internet Service Provider, date and time of visit, referring/exit pages and number of clicks

When you visit our websites, we monitor usage and technical log data such as your internet protocol (IP) address, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. Mostly, this data is collected and processed in an aggregate manner and is not linked to any information that is personally identifiable. Exceptionally, when you make a purchase of any GURU products, your order information will contain your IP address as well as the date and time of your purchase.

We monitor log files to analyze trends, administer the websites, fix bugs, prevent suspicious activity, track users' movements and gather demographic information.

Communication Data
Examples: name, email address, message content, supporting documentation and attachments, zip/postal code, location and other pertinent information

If you inquire about our Services by e-mail, through social media or otherwise, if you interact with us through any media or if you request support from us, we will process the personal data required to respond to your inquiries, including any attachments and content you include. We process such personal data based on your implied consent. We use a service provider to help GURU manage its support requests.

We might, in some circumstances, communicate with you as a registered account owner, an Affiliate or a customer, to share important corporate information that is relevant to you.

If you engage with us on social media, we will collect and process the personal data which you make available to us based on your implied consent. On social media, we will have access to your publicly available information when you interact with us and we will use this information to respond to your questions and comments and to send targeted advertising through the social media which was used during the engagement. You can withdraw your consent from receiving our targeted advertising through your preferences and privacy settings on such social media sites.

When you engage with our content through the social media on our websites, the social media site may use your personal data for other purposes, please consult their privacy policies below:

LinkedIn
Facebook
Instagram
Youtube
tiktok
Snapchat
Employment Data
Examples: name, email and mobile number, your resume, areas of interest, certifications, memberships, experience and education

If you submit your personal data for an employment opportunity, we will collect the personal data you shared with us, such as your name, email and mobile number, your resume, areas of interest, certifications, memberships, experience and education. We collect this information to respond to your inquiries or to follow up with you regarding such employment opportunities. We collect this information based on your consent.

We work with third party employment service providers to promote our job opportunities. We are therefore not liable for their privacy policies, procedures and practices, and we encourage you to review their privacy policies before submitting your personal data for an employment opportunity.

Marketing Data
Examples: Name, Email, marketing and product preferences, transaction history, cookies, browsing habits, pictures, videos.

With your consent, we will use your e-mail address to provide you with commercial electronic messages (CEMs), promotional content and our newsletters. We send these commercial electronic messages in accordance with the Canadian Anti-Spam Law (CASL).

You can unsubscribe to our promotional content by clicking the “unsubscribe” link in our emails or by contacting us at [email protected].

GURU sponsors sporting and other types of events as part of its marketing and promotional activities. These sponsorship opportunities allow us to promote GURU at onsite events. With your consent, we might take pictures of you while you are participating in our promotional activities and these pictures may be publicly available. If you visit our website and download your picture, we will track you with our use of cookies and conduct interest-based marketing. Please read sections 5 and 6 here to know more about how we use cookies and what is interest-based advertising. Please click here to know more about how to manage your cookie preferences.

GURU also de-identifies the personal data we collect about you to gain access to analytical and business insights, in an aggregated format, on trends, preferences, patterns of purchase, business processes. These business insights allow GURU to predict business results and anticipate product preferences and customer demand while it inspires us to innovate and create new products we believe will cater to our customers’ preferences. We use Google’s Data Warehouse BigQuery as a service provider to provide GURU with this business intelligence.

Third Party Transaction Data
Examples: name, email, telephone number, shipping and billing addresses, credit card information

We employ third party service providers such as Amazon, Instacart and others to sell our products on our behalf. Accordingly, Amazon, Instacart and other third parties use your personal data to receive and handle orders, deliver products and services, process payments, and communicate with you about orders, products and services. We encourage you to review our third parties’ Privacy Policies before sharing your personal data and placing an order. Third parties will share some of your personal data with GURU, such as your name, email and shipping address.

5. WHAT TYPES OF “COOKIES” DO WE USE AND HOW?

Cookies are data files installed on your device (a computer tablet or mobile for instance) to fulfil several purposes. In this Privacy Policy, when we use the term “cookies”, we also mean similar tracking technologies such as tracking pixels (or pixels tags), web beacons and browser fingerprinting.

Cookies can be installed by us, in which case, they are called “first-party cookies”. They can also be installed by third parties, such as Google Analytics and Amazon Advertising, referred to as “third-party cookies” and result in the sharing of your personal data, such as your IP address, with these third parties.

We use essential, preference, analytical and marketing cookies to better understand how you interact with our websites, to improve and personalize your experience while visiting our websites, to provide GURU with some aggregated statistical data about how you use and browse our websites and to allow third parties to conduct interest-based advertising. More specifically:

Essential cookies

We use “essential” cookies to ensure the functionality of our websites, namely by enabling basic activities like navigating our online pages and accessing the secure areas of our websites.

Preference cookies

We use “preference” cookies to recognize you each time you return to our websites, remember your preferences. For example, we create a persistent cookie that includes some basic information about you, like your most recent searches or your language preferences.

Analytical Cookies

Analytical cookies are used to generate aggregated statistical data about traffic and visitor behaviour on our websites. GURU uses Google Analytics to view key metrics such as how many visitors view the websites, peak hours of traffic, duration and frequency of visits, pages visited, and keyword searches. Google Analytics is Google’s analytical tool that helps us to understand how Visitors engage with our websites. Data collected also includes your IP address, geographic location, browser information, device identifiers, what websites you visited before and after your visit.

Advertising Cookies

We use first-party and third-party advertising cookies.

First, we track what videos from YouTube you have seen and to store your video player preferences using You Tube embedded videos.

We also use Amazon Advertising, Google’s DoubleClick and Google Ads to register user actions and target content on the website based on ad clicks on a different website. Amazon Advertising is also used to track visitors across multiple websites.

Advertising cookies allow us to present you with relevant advertisements based on your preferences and interests, limit the number of times you see an ad, help measure the effectiveness of a campaign, content and/or email driven traffic in order to re-evaluate content offerings, map customer buying journeys and provide a more personalized experience.

6. WHAT IS INTERESTED-BASED ADVERTISING, AND DO WE CONDUCT ANY?

Interest-based advertising (also known as targeted or behavioural advertising) means that your preferences and interests are collected through cookies or otherwise, and then used to serve you advertising and marketing materials that are relevant to you (based on those preferences and interests).

Without interest-based advertising, you would still be getting ads when browsing the Internet. However, these ads would not be personalized based on your preferences and interests; they would be less relevant to you, and less effective for us. For instance, we use Amazon Advertising, Google Ads, Google’s DoubleClick, Facebook and SnapChat to provide you with ads based on your browsing history and search requests. We also use YouTube to provide you with personalized ads based on your viewing content. Click here to learn how to manage your cookie preferences.

We adhere to the Digital Advertising Alliance (“DAA”) and the Digital Advertising Alliance of Canada’s (“DAAC”), interest-based advertising principles by providing you with enhanced notice, transparency and control of our digital marketing practices, as stated at https://youradchoices.com & https://youradchoices.ca

7. HOW DO I MANAGE MY COOKIE PREFERENCES?

You can manage your cookie preferences through your browser using the instructions provided below by clicking on the browser that you are using. However, by blocking some cookies that enable the functions of the Services, parts of the Services may not be available.

Google Chrome
Firefox
Safari
Microsoft Edge
Opera
Brave
You can also install the Google Analytics opt-out browser add-on, which prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page.

8. DO WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES?

We work with a number of service providers that are assisting us in the delivery of our products and services and to conduct our marketing and promotional activities.

Here are the various types of service providers with whom we share your personal data:

Providers of data aggregation and analytics software services that enable us to effectively monitor and optimize the delivery of our services and provide useful reporting features to brand partners and their users (Google Analytics);
Third party ecommerce marketing solutions (such as Amazon Advertising, Google Ads, DoubleClick, Bazaarvoice, Goloot, Impact);
Providers of e-mail management and distribution tools, as well as customer relationship management software (such as Freshdesk, Klaviyo);
Providers of IT services and online cloud storage services (such as Google Cloud);
Providers of business intelligence and data warehousing services (such as BigQuery);
Sales and product delivery service providers (such as Amazon, Amazon Logistics, Walmart and Instacart).
Also, we may disclose your personal data to third parties as outlined in this Privacy Policy, or if required by law. We may use and disclose your information when we believe such use or disclosure is permitted, necessary or appropriate: (a) under applicable law; (b) to comply with the legal process; (c) to respond to requests from public and government authorities; (d) to enforce or apply our policies and agreements; (e) to protect our rights, operations or property; (f) to collect amounts owed to us; (g) to allow us to pursue available remedies or limit the damages that we may sustain; (h) to protect the safety of our stakeholders; (i) to address, prevent or stop fraud or other activity that we consider to be illegal or unethical; or (j) to address an emergency involving danger of death or serious harm.

9. HOW DO WE PROTECT YOUR PERSONAL DATA?

GURU protects your personal data with reasonable physical, organizational and technological security measures. For example, your personal data can only be accessed on a need-to-know basis for specific purposes; we use contractual agreements and confidentiality agreements with our service providers and our staff is trained on the importance of safeguarding privacy.

Keep in mind these safeguards may not be completely secure from loss or theft, or unauthorized access, use, or disclosure. Please ensure you take appropriate steps to protect your personal data and keep your credentials and passwords confidential.

10. WHERE DO WE STORE YOUR PERSONAL DATA?

We may rely on service providers who are located in the United States who assist us with the delivery of our products and services, in which case your personal data may be stored in or accessed from the United States. In that case, your personal data will be subject to United States laws and may be subject to disclosure to United States governments, courts or law enforcement or regulatory agencies, pursuant to those laws.

Subject to those laws, GURU uses reasonable measures to protect your personal data as it would be protected in Canada. For more information about our policies and practices regarding processing of personal data outside of Canada, please send us an email at [email protected].

11. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

We keep your personal data for as long as it is necessary to provide you with our products and services, or as required by law, whichever is longer.

When visiting our websites, we use both persistent and session cookies. Session cookies are deleted once you close your browser, whereas persistent cookies remain active on your device for some time. For instance, Google Analytics and Amazon Advertising cookies remain installed on your device for two (2) years.

12. WHAT ARE YOUR PERSONAL DATA RIGHTS?

You have rights when it comes to your personal data. These rights generally include the right to access and correct your personal data, as well as the right to withdraw your consent. Keep in mind that depending on the province, state or country you live in, these rights may be different.

If you have questions regarding how GURU processes your personal data or you are looking to exercise your personal data rights, please reach out to us:

[email protected]

7236 Waverly, suite 602

Montréal, (Québec) H2R 0C2

1.888.810.4878

Once we receive your request, we will get back to you within 30 days. It’s possible that we cannot comply with your request, for instance, if it’s not applicable under the law. If we can’t process your request, we will provide you with explanations. For security reasons, we may ask you to provide a proof of identity with your request. We will not use such personal data for any other purposes.

We will try to respond to your request free of charge. In some instances, and if the law permits, we may request that you pay a reasonable fee, for example to receive a transcript or a copy of your personal data. If we need to charge you a fee, we will let you know before we answer your request.

Need more info on your personal data rights? The Office of the Privacy Commissioner of Canada (OPC) has published advice to inform you on how to exercise your privacy rights when personal data is held by a business.

If you are a resident of Quebec, you can read about your privacy rights on the Commission d’accès à l’information du Québec (Commission) website here.

If you’re not satisfied with how we process your request, please reach out to us! If you are still not satisfied, you can report your concerns to the OPC by filling out this form, and to the Commission by filling out this form.

13. MAY I WITHDRAW MY CONSENT?

Yes, whenever we process your personal data based on your consent, you can withdraw that consent at any time by contacting us, or by using the functionalities that we make available to you within your online account. Please note that if you withdraw your consent, we may not be able to provide you will all of our products and services.

14. CAN YOU CHANGE THIS PRIVACY POLICY?

Yes, we may need to modify this Privacy Policy to reflect new processing activities, adapt to new laws and regulations or reflect technological changes or corporate changes, such as a result of a merger and acquisition.

You can view the date of the latest update at the top of this page, and you can always reach out to us should you have any questions!