Privacy Policy

1. Introduction

This website (https://geswo.com, https://CoGM.info, https://ChGM.info, https://SFAM.info) is operated and editorially managed by GESWO – Editorial & Consulting, Encarnación, Paraguay.

Additional brand‑related content may be published under https://drtortuga.com, which is also owned and operated by GESWO. Editorial content, publications, and methodological websites are under the responsibility of GESWO Paraguay. Payments, contracts, and international transactions related to the GESWO online store are executed via GESWO LLC, Wyoming, USA, which acts as the legal entity for invoicing, Stripe/PayPal/Shopify integrations, and global digital commerce.

We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how data may be collected, processed, and used when you visit these websites, including interactions with integrated services such as Shopify, Lulu Direct, Paymentwall, Geniuslink, and WhatsApp (Joinchat).

2. Data Collection on this Website

Browsing this website does not require registration or the submission of personal information. GESWO does not actively collect personal data from visitors unless you voluntarily submit information (e.g., via contact forms, purchases, or communication tools).

The website may contain links to external platforms (Shopify, Lulu Direct, Paymentwall, Geniuslink, Amazon, etc.). These platforms operate independently and may process personal data according to their own privacy policies. GESWO does not control or store data collected by external platforms.

3. Hosting and Security Services

This website is hosted by Hostinger International Ltd. Technical data such as IP addresses, browser information, and server logs may be processed by Hostinger for security, diagnostics, and maintenance purposes.

For performance and protection, this website also uses Cloudflare, Inc. Cloudflare may process technical data (such as IP addresses, device information, and security‑related metadata) to provide content delivery, caching, and security services.

GESWO does not actively use, analyze, or store this technical data. Any processing is subject to the privacy policies of Hostinger and Cloudflare.

4. External Sales of Consulting Products, Books, and Digital Products

Many products featuring GESWO’s methodologies, books, and digital materials are sold via external platforms. When you click on product links, you may be redirected to third‑party providers such as Shopify, Lulu Direct, Paymentwall, Amazon, or Geniuslink‑managed affiliate destinations.

Any personal data required for ordering (such as name, address, payment details, delivery information) is collected and processed exclusively by the respective platform. These platforms operate independently and process data according to their own privacy policies.

GESWO has no access to this data and assumes no responsibility for its processing, storage, or security. This includes:

  • Shopify (online store, checkout, digital product delivery)
  • Lulu Direct (print production, packaging, shipping, delivery)
  • Paymentwall (payment processing, fraud prevention, transaction validation)
  • Geniuslink (affiliate redirection, link localization)

GESWO does not store or process payment information, delivery addresses, or transaction details from these external services.

5. Sales of Consulting & Web Design Services via GESWO

When contracting consulting services (e.g., SAP Project Management, SAP Cutover Management) or web design services, personal data such as name, address, contact details, and billing information may be collected directly by GESWO. These services are governed by a separate contract, including a Statement of Work (SOW), which defines scope, deliverables, and responsibilities.

  • Local services in Paraguay are managed under GESWO – Editorial & Consulting, Encarnación, Paraguay, subject to Paraguayan law and tax regulations. For Paraguayan clients, a 10% Value Added Tax (IVA) is applied and shown separately on invoices.

  • International consulting and web design contracts are executed via GESWO LLC, Wyoming, USA, under U.S. law and jurisdiction.

Personal data is processed exclusively for the purpose of fulfilling the contract, issuing invoices, and complying with legal obligations. GESWO does not share this data with third parties, except where required by law (e.g., tax authorities). No consulting or web design data is transferred to Shopify, Lulu Direct, Paymentwall, Geniuslink, or other external platforms.

6. Server Logs and Technical Data

Like most websites, technical information (such as IP address, browser type, date, and time of access) may be automatically collected by the hosting provider for security and maintenance purposes. This data is processed by Hostinger International Ltd. and Cloudflare, Inc., which provide hosting, caching, and security services.

In addition, certain integrated services may process technical data automatically:

  • Shopify: When accessing product pages or embedded Buy Buttons, Shopify may collect technical data such as IP addresses, device information, browser type, and interaction logs for security, analytics, and fraud prevention.
  • Paymentwall: When initiating a payment, Paymentwall may process technical metadata (IP address, device fingerprint, transaction identifiers) to perform fraud checks and ensure secure payment processing.
  • Lulu Direct: When ordering print products, Lulu may process technical data related to order routing, fulfillment, and logistics.
  • Geniuslink: When clicking affiliate links, Geniuslink may process IP addresses, device information, and geolocation data to redirect users to region‑specific stores.
  • WhatsApp (Joinchat): When clicking the WhatsApp contact button, WhatsApp may process metadata such as IP address, device information, and communication logs.

This technical data is not used by GESWO to identify individuals and is deleted or anonymized after a short period by the respective service providers. Any processing is subject to the privacy policies of Hostinger, Cloudflare, Shopify, Paymentwall, Lulu Direct, Geniuslink, and WhatsApp.

7. Cookies and Consent

7.1 Consent Banner Reference

Our website uses a consent banner to manage your preferences regarding cookies and similar technologies. The banner allows you to accept, reject, or customize categories such as Functional, Statistics, and Marketing. Your selection is stored in technically necessary cookies (e.g., cmplz_*) so that your decision is not queried again each time you visit. You can change or revoke your consent at any time via the “Manage Consent” link in the footer.

7.2 Cookie Categories and Purposes

The consent banner distinguishes between the following categories:

  • Functional: Always active. Required for the operation of the website (session management, security, storing your consent decision). This category may also include essential cookies from Shopify (Buy Button), Paymentwall (payment session), and Cloudflare (security and caching).
  • Statistics: Help us understand how visitors interact with our website by collecting and analyzing information anonymously. Shopify may set analytics cookies when viewing product pages or embedded store components.
  • Marketing: Used to track visitors across websites and display personalized advertising. This includes cookies or tracking parameters from Geniuslink (affiliate redirects) and external platforms such as Amazon or other stores you may be redirected to. Marketing cookies are only active after consent.
  • Additional Note: GESWO does not set any sales‑related cookies on geswo.com; all sales cookies originate from Shopify or external platforms.

7.3 Withdrawal of Consent

You can change or revoke your consent at any time. This can be done via the consent banner or the “Manage Consent” link in the footer. Revocation only affects future data processing and does not affect the legality of processing prior to revocation.

8. Google Site Kit / Analytics

This website uses Google Site Kit, which integrates Google Analytics and other Google services. Google Analytics collects information such as IP address, device type, browser type, geographic location, and usage patterns (e.g., pages visited, time spent on the site). The data is processed by Google and may be transferred to servers outside your country of residence, including the United States.

GESWO uses this information to analyze website traffic and improve content. Users can prevent the collection of data by installing the Google Analytics Opt‑out Browser Add‑on. Further information on how Google handles user data can be found in the Google Privacy Policy.

In addition, certain integrated services may interact with Google Analytics:

  • Shopify: Product pages or Buy Buttons may trigger analytics events.
  • Paymentwall: Payment pages may include Google‑hosted scripts for fraud prevention.
  • Geniuslink: Redirects may include UTM parameters processed by Google Analytics.

GESWO does not combine Google Analytics data with personal information.

9. Google AdSense

This website may use Google AdSense, a service for integrating advertisements. Google AdSense uses cookies and similar technologies to display ads based on users’ prior visits to this or other websites. Google may also use tracking technologies to personalize advertising content.

Users can opt out of personalized advertising by adjusting their preferences in the Google Ads Settings. Further information on how Google handles user data can be found in the Google Privacy Policy.

GESWO does not have access to the personal data collected by Google AdSense. Any processing of personal information is subject to Google’s privacy practices.

If affiliate links or external stores (e.g., Amazon) are accessed, additional marketing cookies may be set by those providers.

10. Affiliate Marketing

This website contains affiliate links. When users click on these links, third‑party providers such as Amazon may place cookies or collect data to track purchases. GESWO does not have access to this data. Any processing of personal information is subject to the privacy policies of the respective third‑party providers.

Some affiliate links are managed through Geniuslink, which may process:

  • IP address
  • device information
  • geolocation
  • redirect metadata

to route users to region‑specific stores. Geniuslink does not provide GESWO with personal data; only anonymized performance statistics may be available.

Affiliate commissions do not affect the price for users. Transparency is ensured: if you make a purchase via these links, GESWO may receive a commission, but there are no additional costs for you.

11. Plugins and Third‑Party Services

This website uses WordPress plugins to ensure functionality and performance. Some of these plugins may process technical data such as IP addresses, browser information, or cookies.

  • Akismet Anti‑Spam: Checks comments for spam by transmitting data to Automattic servers.
  • WooCommerce and related extensions (CartFlows, Variation Swatches, WooPayments): Installed for technical reasons but not actively used for sales on this website. No payment data is processed through geswo.com.
  • WPForms Lite: If you use the contact form, your data (name, email, message) will be transmitted to GESWO for the purpose of responding to your inquiry. This data is not stored permanently and will not be shared with third parties.
  • Hostinger tools: May collect technical data for hosting and performance purposes.
  • Site Kit by Google: Collects usage data via Google Analytics and other Google services.
  • LiteSpeed Cache: Uses cookies to optimize website performance. These are technical cookies and do not store personal information.
  • SEO plugins (SureRank SEO, All in One SEO): May use cookies for optimization and analytics.
  • Affiliate plugins (CartFlows, WooCommerce extensions, YITH Catalog Mode): May use cookies to track referrals and sales.
  • Joinchat (WhatsApp integration): When clicking the WhatsApp button, metadata such as IP address, device information, and communication logs may be processed by WhatsApp.
  • Shopify Buy Button: Embedded product components may load scripts from Shopify, which can process technical data (IP address, device type, interaction logs).
  • Paymentwall scripts: Paymentwall may load fraud‑prevention scripts when initiating a payment.
  • Geniuslink: Affiliate redirects may process geolocation and device metadata.

GESWO does not actively use or store personal data through these plugins. Any data processing is subject to the privacy policies of the respective providers.

12. Shopify

This website integrates Shopify components, including the Shopify Buy Button and links to the GESWO online store. When interacting with Shopify elements, Shopify may process personal and technical data such as:

  • IP address
  • browser and device information
  • interaction logs
  • cart and checkout data
  • order information
  • fraud‑prevention metadata

Shopify processes this data independently according to the Shopify Privacy Policy. GESWO does not store or access Shopify checkout data, payment information, or delivery details. All transactions, including digital downloads, are handled exclusively by Shopify and its integrated payment providers.

13. Paymentwall

Paymentwall is used to process payments for products purchased through the GESWO online store. When initiating a payment, Paymentwall may process:

  • payment information
  • billing details
  • IP address
  • device fingerprint
  • fraud‑prevention data
  • transaction identifiers

Paymentwall operates independently and processes personal data according to its own privacy policy. GESWO does not receive or store payment card data, bank information, or fraud‑prevention metadata.

14. Lulu Direct

Print products purchased through the GESWO online store are produced and fulfilled by Lulu Direct. Lulu Direct may process personal data required for printing and shipping, including:

  • name
  • shipping address
  • order details
  • production and logistics information

Lulu Direct processes this data independently according to its own privacy policy. GESWO does not store or access shipping data or logistics metadata beyond what is required for order confirmation.

15. Geniuslink

Some affiliate links on this website are managed through Geniuslink. When clicking a Geniuslink URL, Geniuslink may process:

  • IP address
  • device information
  • geolocation
  • redirect metadata
  • link performance statistics

This data is used to route users to region‑specific stores (e.g., Amazon). GESWO does not receive personal data from Geniuslink; only anonymized analytics may be available.

16. WhatsApp / Joinchat

This website uses Joinchat to provide a WhatsApp contact button. When clicking the WhatsApp button, WhatsApp may process:

  • IP address
  • device information
  • communication metadata
  • phone number (if provided by the user)

Communication takes place directly via WhatsApp and is subject to WhatsApp’s privacy policy. GESWO does not store WhatsApp communication data unless you voluntarily provide information during the conversation.

17. Copyright and Content

All materials (images, videos, texts, recipes, designs, etc.) on this website are protected by copyright and are the property of GESWO. The portfolio may be downloaded, copied, and shared for non‑commercial purposes. Modification of the content or commercial use without the express permission of GESWO is prohibited.

Copyright laws of third parties are respected as long as the contents on this website do not originate from GESWO. Contributions of third parties are indicated as such. If you notice any violations of copyright law, please inform us. Such content will be removed immediately.

No personal data is embedded in downloadable content. Digital products (PDFs, templates, methodological materials) do not contain hidden tracking or personal identifiers.

18. Dr. Tortuga

Dr. Tortuga™ is a brand owned by GESWO. The DrTortuga.com website and related content do not process personal data directly. Any purchases, downloads, or interactions involving Dr. Tortuga products are handled through external platforms such as Shopify, Lulu Direct, or Paymentwall, which process data according to their respective privacy policies.

19. Your Rights

If you believe that personal data has been processed in connection with GESWO, you may contact us at [email protected]. Users have the following rights regarding their personal data:

  • Right of Access: Request information about the personal data stored about you, its origin, recipients, and the purpose of storage.
  • Right to Rectification and Erasure: Request correction of inaccurate data or deletion of your personal data, provided that no legal obligations require its retention.
  • Right to Withdraw Consent: If data processing is based on your consent, you may withdraw this consent at any time with effect for the future.
  • Right to Lodge a Complaint: Users may lodge a complaint with a competent data protection authority if they believe their rights have been violated.

Requests will be handled in accordance with applicable Paraguayan law. For users within the European Union, the General Data Protection Regulation (GDPR) applies. Requests will be answered within a reasonable timeframe (typically 30 days).

20. Data Privacy Contact

For all privacy‑related inquiries, please contact: [email protected]

21. Jurisdiction and Applicable Law

This website is operated under the laws of Paraguay. The place of jurisdiction for editorial content and publications is Encarnación, Paraguay.
For international contracts and payment transactions, jurisdiction is Sheridan, Wyoming, USA.
For users in the European Union, GDPR applies to the processing of personal data where relevant.

Last updated: August 22, 2026