Last Modified: June 1, 2018
The purpose of this Policy is to inform you about our privacy practices and to ensure that you understand the purposes for which We collect and process your personal data. The following is a brief summary of the manner and purposes for which We process your personal data.
We may update this Policy from time to time, and the updated version of this Policy will be effective upon posting on the Services. Please check this page to review the most up-to-date version of this Policy.
4## . RESPONSIBILITY FOR DATA PROCESSING Cheeze is the entity which is responsible for the processing of personal data that We collect from you when you use the Services such as [INSERT]. If you have any questions or concerns about Cheeze’s use of your personal data, please contact us at firstname.lastname@example.org.
5. COUNTRY OF PROCESSING
We operate the Services from the United States of America (USA) and our data collection and processing activities take place predominantly in the USA. Accordingly, data collected from users when using our Services is collected in the USA. We store and otherwise process data (including personal data) through third party cloud service providers and other IT service providers which may be located or which may operate in other countries, including countries which do not guarantee the same level of protection to privacy as the USA.
6. HOW WE COLLECT AND USE YOUR PERSONAL DATA
- Information That You Provide Directly or Authorize Someone Else to Give Us. We may ask you to provide certain information including, but not limited to your name, email address, and any other information You choose to provide to Us. For example, We may collect information from You when You register for and/or use the Service, contact or interact with Us, fill out a form, apply for employment, respond to a survey, and voluntarily provide Us with Your comments and/or questions and other content in connection with using the Service. When You submit a “Contact Cheeze” form, We may collect Your name, phone number, email address and any other information You choose to provide to Us. In addition, if another user allows us to collect information from their device phonebook—and you’re one of that user’s contacts—we may combine the information we collect from that user’s phonebook with other information we have collected about you. We also collection your personal data if You provide Us with information about You in connection with setting up, using or managing Your account.
- Information We Collect from Other Sources. We may collect information about You from third party sources including without limitation social media companies and marketing and business partners. The Service may provide connections with Facebook, Twitter, YouTube and LinkedIn. If You connect with Facebook through the Service, We receive Your public profile (which includes Your Facebook User ID, Your profile photo, Your public information, Your friends’ User IDs), Your language, Your country, and whether You are in an age group, for instance, under 18, between 18-20, or 21 and over. We can also access, store, and update the information You share through Facebook. If You connect with Twitter through the Service, We receive Your Twitter identity (which includes Your Twitter avatar and user name and Your followers’ user names). We can also access, store, and update the information You share through Twitter. We may receive information about You from digital marketing companies with which We work to help Us deliver relevant marketing to You and recognize You across browsers and devices.
- Cookies. When you use the Service, We sometimes send one or more cookies (small text files containing a string of alphanumeric characters) to your computer that uniquely identify your browser and enhance your navigation on the Service. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take), and allow us or our third-party analytics tools We use to track your usage of the Services. There are at least two different types of cookies: persistent and session cookies. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent use of the Service. Persistent cookies can be removed by following your Web browser's directions for removal of cookies. A session cookie is temporary and disappears after you close your browser. You can reset your Web browser to refuse all cookies or to notify you when a cookie is being sent. However, some features of the Service may not function properly if cookies are disabled.
- Log File. Log file information is automatically reported by your browser each time you access a Web page. When you access or use the Service, our servers may automatically record certain log file information, including but not limited to your Web request, Internet Protocol address, browser type, referring/exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, and pages viewed.
- Device Identifiers. When you access or use the Service using a mobile device, We may access, collect, monitor and/or remotely store one or more "device identifiers," such as a universally unique identifier. Device identifiers are small data files or similar data structures stored on or associated with your device that uniquely identify your device. A device identifier may consist of data stored in connection with the device hardware, operating system or other software, or data sent to the device by us. A device identifier may convey information to us about how you browse and use the Service. A device identifier may remain persistently on your device to enhance your navigation on the Service. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.
- Advertising Identifiers. Advertising identifiers are unique strings associated with your mobile device that are provided by the operating system. Certain advertising identifiers may be modified or disabled by users in the operating system's settings.
- Location Data. When you access or use the Service using a mobile device, We may access, collect, monitor and/or remotely store "location data," which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your device. Location data may convey to us information about how you browse and use the Service. Some features of the Service, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled.
- Commercial Communications. To the extent permitted under applicable law, We may use the information We collect or receive to communicate directly with you in relation to the Services or related services We offer. Subject, where necessary, to obtaining your consent to receiving such communications, We may use the information to communicate with you in relation to other services that We and our affiliates offer. We may also use the information to send you service-related notices (e.g., account verification, technical and security notices).
- Use of Certain Service-Type information. We may use information from cookies, log files, device identifiers, location data, clear GIFs and other tools to: (i) remember information so that you will not have to re-enter it during your visit or the next time you use the Service; (ii) provide custom, personalized content or information to you or others; (iii) monitor the use of the Service; (iv) monitor aggregate metrics, such as total number of visitors, traffic and demographic patterns; (v) diagnose or fix technology problems; (vi) provide advertising to your browser or device; and (vii) conduct research or surveys.
- Use of information with Your Consent. We may use your personal data for any other purpose for which you specifically provide Us with your consent.
7. THE PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA
The purposes for which We collect and store your personal data are the following:
- Personal data that We receive from you enables Us to deliver the Services to you and to enable you to use them efficiently;
- Insofar as permitted under applicable law, to communicate with you in relation to our Services and other services that We or our affiliates offer;
- Where you sign up for the Services through an account with a third party content or platform provider, to report to that third party and to communicate with it in relation to your activities on the platform or in relation to the content;
- To personalize, test, monitor, improve and upgrade the Services;
- To send periodic emails or SMS messages (the email address and phone number You provide may be used to send You information and updates pertaining to Your account, in addition to receiving occasional Company news, updates, related product or service information, etc., but if at any time You would like to unsubscribe from receiving future emails, We will include detailed unsubscribe instructions at the bottom of each email);
- To meet our legal obligations and the regulatory requirements to which We may be subject, for loss prevention purposes and to protect and enforce our rights and meet our obligations to third parties; and
- For our internal business purposes, such as compiling and analyzing usage information for general operational, statistical and business purposes.
8. Third Party Service Providers and Business Partners; other cheeze users; GENERAL PUBLIC AT LARGE
- Third Party Service Providers and Business Partners.
- Other Cheeze Users.
We may share the following information with other users of the Service:
- information about You, such as Your username, name and photos;
- information about how You have interacted with the Service, the names of other Cheeze users with whom You are connected and/or friends with, and other information that will help Cheeze users understand Your connections with others using the Service; and
- additional information You have consented for us to share.
- All Cheeze Users, Our Business Partners and the General Public At Large.
We may share the following information with all Cheeze users as well as with our business partners and the general public at large:
- public information like Your name, username and profile pictures; and
- any photos or other content that You submit to Cheeze that contributes to content submitted from various Cheeze users throughout the community (including on a crowd-sourced basis), collected and categorized to capture an event or place from various perspectives that could appear anywhere including various portions of the Service or even other third-party services or platforms including streamed on the Internet, broadcast or rebroadcast including in real time on extra-large screen jumbo trons while you are at concerts or sports events.
9. YOUR RESPONSIBILITIES
It is important that the personal data We hold about you is accurate and current. If you provided us with any details of personal data, please keep us informed if such details change.
10. LEGAL BASIS FOR PROCESSING YOUR DATA
We rely on the following lawful basis for the processing of your personal data:
- Our legitimate interests in (among other things) delivering the Services, conducting commercial research, improving and maintaining the Services, personalising and tailoring content made available to you through the Service, protecting the security or integrity of our databases, protecting our business or reputation, taking precautions against legal liability, dealing with our assets in the event of a business change (see further below), protecting and defending our legal rights or property, or for resolving disputes, investigating and attending to inquiries or complaints with respect to your use of the Services;
- Where relevant, your express consent. If you give your consent for accessing your mobile data to take measurements, you can withdraw it through the personal settings on the Company app);
- Where relevant, the fulfilment of our contractual obligations to you under our terms and conditions of service; and
- Where relevant, for compliance with legal obligations to which we are subject.
11. HOW WE SHARE YOUR INFORMATION
- Service Providers. We may share your personal data with third-party service providers that perform services on our behalf in connection with the Service, such as cloud service providers that we may use or third party analytical service providers. Where your information is shared with such third parties, We ensure that the third party service provider will deal with your information only on our behalf and on our written instructions and solely for Our benefit (and not for its own benefit).
- Business Change. If We become involved in a merger, consolidation, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution or other transaction, or if the ownership of all or substantially all of our business otherwise changes, We may share or transfer databases containing personal data of users including your personal data to a successor party or parties in connection with such transaction or change in ownership or legal structure.
- Sharing information. We may share certain service-type information, including information obtained through tools such as cookies, log files, device identifiers, location data and clear GIFs (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with our third-party service providers who may use such information for the purposes described in the section titled "How We Collect and Use Your Personal Data."
- Aggregated data. As mentioned above, We may also aggregate or otherwise strip information of all personally identifying characteristics and may share that Anonymized and Aggregated Data with third parties or publish it. This Anonymized and Aggregated Data does not personally identify you and helps us to measure the success of the Service and its features and to improve your experience. We reserve the right to make use of any such Anonymized and Aggregated Data in our sole discretion.
12. HOW WE PROTECT YOUR INFORMATION
We take measures to protect personal data you provide through the Service against loss, theft, and unauthorized access, use, disclosure or modification. These include physical, technological and administrative measures. However, We cannot ensure or warrant the security of any information you transmit to us or guarantee that information on the Service may not be accessed, disclosed, altered or destroyed. Email sent to or from the Service may not be secure. You should use caution whenever submitting information online and take special care in deciding what information you send to us via email. We cannot guarantee that transmissions of your personal data will be fully secure and that third parties will never be able to defeat our security measures or the security measures of our partners. WE ASSUME NO LIABILITY FOR DISCLOSURE OF YOUR INFORMATION DUE TO TRANSMISSION ERRORS, THIRD-PARTY ACCESS OR CAUSES BEYOND OUR CONTROL.
13. YOUR CHOICES ABOUT YOUR INFORMATION
- Controlling Your Settings. You can limit your browser or mobile device from providing certain information by adjusting the settings in the browser, operating system or device. Please consult the documentation for the applicable browser, operating system or device for the controls available to you. You can also stop receiving promotional emails from us by following the unsubscribe instructions in those emails.
- Changing Your Information. To change Your information, please contact Us at email@example.com.
- Closing Your Account. You may close Your account by contacting Us at firstname.lastname@example.org. If the email account or mobile number associated with Your email address is not active, We may close Your account without notice. If your account is not used for more than 12 months we may close your account.
- Email Communications. You can make changes regarding opting out of or otherwise receiving email communications from Us by contacting Us at email@example.com.
- Do Not Track. At this time, We do not recognize "do not track" signals sent from Web browsers. In some cases, your browser may offer a “Do Not Track” option, which allows you to signal to operators of Websites, mobile applications, and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and/or across different Websites and mobile applications and services. Disabling tracking mechanisms may disable certain features of the Service. To disable tracking, please consult the documentation for you browser, operating system or mobile device. For some devices, it may not be possible to disable tracking mechanisms. You may also disable tracking by certain third-party services by opting out:
- Opt-Outs Available from Our Partners. Some of our partners allow users to opt-out of their collection of information. See “Do Not Track” section above for details.
14. HOW LONG WE KEEP YOUR INFORMATION
We will only retain your personal data for as long as necessary to fulfill the purposes We collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, We consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which We process your personal data and whether We can achieve those purposes through other means, and the applicable legal requirements. Insofar as the data is collected to enable Us to recognise you as a user of the Services and to improve the Services provided to you, We will dispose of the data within a reasonable time after you cease to be a registered user of the Services.
15. CHILDREN'S PRIVACY
The Service is not directed to children and/or persons under the age of majority in their respective jurisdictions and is intended for use by adults and/or persons at or over the age of majority only. We do not knowingly collect personal data from individuals under sixteen (16) years of age. If you are under the age of sixteen (16), please do not submit any information through the Service and do not provide your consent for the use of your data unless your parent or guardian has approved.
16. EU PRIVACY RIGHTS
Users based in the European Union have the following legal rights in respect of their information:
- The right to require Company to confirm whether or not their information is being processed, the purpose of any such processing, the recipients of any information that has been disclosed, the period for which their information is to be stored and whether any automated decision-making processes are used in relation to their information;
- The right to require Company to rectify inaccurate information without undue delay;
- Where Company has relied on the ‘consent’ basis for processing that information (see paragraph 9(b) above), the right to withdraw their consent at any time. This right to withdraw consent does not affect the lawfulness of processing based on consent before its withdrawal;
- The right to request the erasure of their information. You can make a request for erasure where:
- the information is no longer necessary in relation to the purpose for which it was collected;
- where the processing of the information is based on the user’s consent (and the other circumstances described in the ‘Legal Basis for Processing Your information’ and ‘How We May Share Your information’ sections above no longer apply), if the user withdraws his or her consent; or
- where the personal data is processed by Company solely on the basis of our ‘legitimate interest’ referred to in paragraph 9(a) (and the other legal basis set out in paragraph do not apply), if the user objects to the processing of his or her personal data and there are no overriding legitimate grounds for the processing (such as, for example, where the processing of the data is required to meet statutory obligations or for the defence of legal claims).
- The right to require Company to restrict its processing of a user’s personal data in certain circumstances, such as where the accuracy of that data is disputed or an objection has been raised. In such circumstances, Company will only process that information with the express consent of the user, or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest;
- Where data is processed based on user’s consent or to fulfil a contractual obligation, the user has the right to receive his or her personal data from Company in a structured, commonly used and machine-readable format;
- The right to object to the processing of personal data where:
- Company relies solely on the ‘legitimate interest’ basis for processing that data, in which case we will be legally required to stop processing the user’s information unless we have compelling legitimate grounds for the processing which override the user’s privacy rights and interests; or
- the information is used for direct marketing purposes, in which case we will immediately stop processing the user’s information for such purposes;
- Users have the right to lodge a complaint with the data protection supervisory authority of the EU member state where the user resides.
17. THIRD-PARTY SITES AND SERVICES
18. CALIFORNIA PRIVACY RIGHTS
Under California Civil Code Section 1798.83, if you are a California resident and your business relationship with us is primarily for personal, family or household purposes, you may request certain data regarding our disclosure, if any, of information to third parties for the third parties' direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org with "Request for California Privacy Information" in the subject line. You may make such a request up to once per calendar year. If applicable, We will provide to you via email a list of the categories of information disclosed to third parties for their direct marketing purposes during the immediately-preceding calendar year, along with the third parties' names and addresses. Please note that not all personal data sharing is covered by the requirements of California Civil Code Section 1798.83.
19. QUESTIONS/CONTACTING US
305 Lytton Avenue
Palo Alto, California USA 94301.