Privacy Policy

This Privacy Policy explains how Platoon LLC dba Gunly (“Gunly”, “we”, “us”, or “our”) collects, uses, discloses, and protects information when Merchants use the Gunly Platform, including hosted websites, ecommerce tools, managed WordPress and WooCommerce infrastructure, integrations, data feeds, and related services.

By accessing or using the Platform, you agree to the practices described in this Privacy Policy.

1. COMPANY INFORMATION

Platoon LLC dba Gunly
5448 Apex Peakway, Suite 133
Apex, NC 27502
Email: support@gunly.com

Gunly provides a managed ecommerce platform for licensed firearms businesses and related merchants. This Privacy Policy applies to all data collected through the Gunly Platform.

2. INFORMATION WE COLLECT

Gunly collects information directly from Merchants, information automatically through use of the Platform, and information processed on behalf of Merchants to operate their ecommerce websites.

2.1 Merchant Information

Gunly collects the following information from Merchants:

• Name
• Email address
• Phone number
• Business address
• FFL information (if applicable)
• Billing and payment information (excluding full card numbers)
• Login credentials
• IP address, device identifiers, browser type, and usage data

2.2 End Customer Information (Processed on Behalf of Merchants)

Gunly processes but does not independently control the following End Customer information:

• Customer names
• Customer email addresses
• Customer shipping addresses
• Customer phone numbers
• Order details and purchase history
• Customer account profiles (if enabled by Merchant)

Gunly does not collect or store:

• Age or date of birth
• Government-issued identification documents
• 4473 forms or related ATF compliance documents
• Digital signatures or biometric data

2.3 Payment Information

Gunly does not process or store full payment card data. All cardholder data is processed by:

• Authorize.net, or
• Merchant-selected payment processors

Gunly may receive limited metadata (such as last four digits, card type, billing address) depending on processor configurations.

2.4 Technical and Analytics Information

Gunly automatically collects:

• IP address and device data
• Browser type and operating system
• Platform usage information
• Error logs
• Cookies and tracking identifiers
• Behavioral analytics collected through:
  • Google Analytics
  • Google Ads pixel
  • Microsoft Clarity
  • Meta pixel
  • HubSpot

Gunly does not use Hotjar.

3. HOW WE USE INFORMATION

Gunly uses collected information strictly for business and operational purposes, including:

3.1 Platform Operation and Service Delivery

• Providing and maintaining the Platform
• Account setup, authentication, and security
• Processing setup services, configuration, and onboarding
• Enabling third-party integrations and data feeds
• Hosting Merchant websites

3.2 Communications

• Sending service announcements, updates, notices, and billing alerts
• Responding to Merchant inquiries or support requests
• Providing onboarding or troubleshooting assistance

3.3 Security and Compliance

• Monitoring for security threats, fraud, or abuse
• Protecting against unauthorized access or malicious activity
• Enforcing Terms of Service and acceptable use requirements

3.4 Analytics and Improvements

• Improving Platform performance and reliability
• Evaluating usage trends and feature adoption
• Enhancing user experience and service quality

Gunly does not sell personal information.

4. COOKIES AND TRACKING TECHNOLOGIES

Gunly uses cookies and similar technologies for:

• Account authentication
• Session management
• Analytics and performance monitoring
• Advertising and retargeting (Google Ads, Meta pixel)
• Security and fraud prevention

Merchants may also install their own tracking tools on their storefronts. Gunly is not responsible for Merchant-chosen tracking technologies.

5. HOW WE SHARE INFORMATION

Gunly shares information only with trusted service providers and only as necessary to operate the Platform.

5.1 Service Providers

Gunly shares limited data with:

• DigitalOcean (hosting and infrastructure)
• SendGrid (email delivery)
• Twilio (SMS delivery)
• HubSpot (CRM and support ticketing)
• FFL Cockpit (distributor data feed provider)
• Cloudflare (provides content delivery, DNS, caching, reverse proxying, SSL termination, DDoS protection, Web Application Firewall services, traffic routing, and performance optimization. Cloudflare processes IP addresses, device information, request headers, and other technical data as part of securing and delivering the Platform.)
• Third-party integrations selected by Merchants

Service providers are contractually obligated to protect data and use it only for service delivery.

5.2 Legal Compliance and Safety

Gunly may disclose information if required by:

• Law enforcement
• Subpoena or court order
• ATF or regulatory inquiry directed at the Merchant
• To protect Gunly’s rights, security, and operations

Gunly does not voluntarily provide data to regulators about Merchants unless legally compelled.

5.3 Business Transfers

If Gunly is involved in a merger, acquisition, financing, or sale of assets, information may be transferred as part of the transaction.

6. DATA RETENTION

Gunly retains Merchant account data and Client Assets for 30 days after account termination. After 30 days:

• Merchant data may be permanently deleted
• Client Assets may be removed from servers
• Backups containing Merchant data will be overwritten during normal cycles

Gunly may retain limited records for legal, accounting, or fraud prevention purposes.

7. DATA SECURITY

Gunly uses commercially reasonable measures to protect information, including:

• Access controls and authentication systems
• Encrypted transmission of data
• Secure hosting environments
• Malware and intrusion monitoring
• Firewalls and network protections

No method of transmission or storage is completely secure. Gunly does not guarantee protection from all cyberattacks, unauthorized access, or security incidents.

8. CHILDREN AND AGE RESTRICTIONS

The Platform is intended only for Merchants 21 years of age or older. Gunly does not knowingly collect information from minors.

9. MERCHANT RIGHTS

9.1 Right to Request Deletion

Merchants may request deletion of their Gunly account and associated data by contacting support@gunly.com. Deletions occur after identity verification and are subject to retention obligations described in Section 6.

9.2 No Right to Access or Portability

Gunly does not provide copies of account data, logs, or internal records except as required by law.

9.3 No Right to Restrict Processing

Gunly does not offer data processing restrictions. Use of the Platform requires information processing as described in this Privacy Policy.

10. INTERNATIONAL DATA TRANSFERS

Gunly may process and store information on servers located in the United States or in other countries. By using the Platform, Merchants consent to the transfer of information to locations outside their jurisdiction.

11. STATE-SPECIFIC PRIVACY RIGHTS (NON-GDPR)

Gunly complies with applicable U.S. state privacy laws, including the California Consumer Privacy Act (CCPA/CPRA), the Virginia Consumer Data Protection Act, and similar frameworks.

Merchants operating in these states may have additional rights under state law, but these rights apply primarily to End Customers. Merchants are responsible for providing required privacy notices to their own End Customers.

Gunly does not operate as a marketplace facilitator and does not direct consumer sales.

12. CHANGES TO THIS PRIVACY POLICY

Gunly may update this Privacy Policy at any time. Continued use of the Platform after changes are posted constitutes acceptance of the updated Policy.

13. CONTACT INFORMATION

For privacy inquiries, data deletion requests, or questions about this Policy, contact:

Platoon LLC dba Gunly
5448 Apex Peakway, Suite 133
Apex, NC 27502
Email: support@gunly.com