1. Introduction
This Privacy Policy pertains to the data handling practices of Cheerbay Technology Limited ("Cheerbay," "us," "we," or "our") and is hereby incorporated into and subject to our Terms of Service. Users are encouraged to review this document to understand our approach to handling data. By accessing or using our Cheerbay mobile application ("App"), visiting our website, or utilizing any services available or related thereto (collectively referred to herein as the "Services"), users agree to abide by the terms outlined in this Privacy Policy. If you do not consent to the terms set forth in this document, we kindly request that you refrain from using the Service.
During your interaction with the Site or App, data may be collected from you as delineated below. Upon registration and utilization of your account with us, data will be collected to facilitate the provision of our Services. The types of data collected vary depending on the manner in which our App and Services are utilized.
2. Information we collect
Upon your visitation and utilization of our Site or App, installation of the App onto your device, or registration for an account with Cheerbay, it is necessary for us to gather certain personally identifiable information about you to facilitate the provision of our Services. Additional specifics regarding this matter are outlined below.
2.1 Registration and Account Data
Upon installation of the Service on your device and/or registration for an account with Cheerbay, we may collect both personally and non-personally identifiable information about you. This comprises two types of Registration and Account Data:
Information you provide (mandatory): You will be required to furnish your gender, name or alias, date of birth. This information is crucial to enable us to provide you with connection and friend features within our Service.
Information you provide (optional): You may opt to provide additional personally identifiable information such as photos or videos of yourself, a self-description, and details about your interests, along with your mobile phone number or email address. The provision of such data is entirely voluntary. Should you choose to register and log in using your Facebook, Apple, or Google account, we may also gather additional information made accessible to us. For instance, if you register with Cheerbay via your Facebook account (e.g., Facebook Connect), we may collect and store your Facebook ID and corresponding token on our servers for automatic login and profile information. With your explicit consent, we may access and collect specific information available on Facebook (e.g., first and last names, email address, profile picture, birthdays). This data will be stored on our servers and utilized to facilitate your utilization of the Service, such as synchronizing your Cheerbay account across different devices.
We may also use your contact information to market to you, in compliance with the laws of your country – for example, to inform you of new offerings or updates regarding changes to our Services, and to aid others in locating your account if your settings allow. You can manage the notifications you receive from us via your email and mobile notification settings. Additionally, you can unsubscribe from a notification by following the instructions contained within the notification or here.
In addition to the video calling features, you can utilize our personal text messaging service within the App as part of the Services. When you communicate with others via text messages, we will store and process your communications and associated information. This includes scanning for malicious content, detecting abuse and prohibited images, and addressing reported issues. Information about whom you have communicated with and when (excluding the content of those communications) will also be used to enhance our understanding of Service usage, safeguard the platform's safety and integrity, and assess communication patterns.
2.2 Location Information
'Location Data' pertains to information such as your current location, derived from your GPS (GPS coordinates), Wi-Fi (approximate city location), or IP address (country location), which may be disclosed to us, other users, or both. We require Location Data to securely and reliably set up and maintain your account, provide our Services to you, and uphold the integrity and security of our Services. Your current location is crucial for the effective operation of our Services, ensuring correct and anticipated connections are established.
Consequently, we may collect, use, and store additional information about your location - such as your precise current position or previously visited locations while using our Services - to operate or personalize our services, including providing more relevant connections.
2.3 Log Data
We receive information when you interact with our services, referred to as "Log Data." This encompasses a range of activities, including viewing content on our websites, signing into our services, interacting with email notifications, or using your account to authenticate to a third-party service. Log Data may include your IP address, browser type, operating system, configuration information from the Cheerbay app or desktop browser, referral sources, pages visited, location, mobile carrier, device information (including device and application IDs), search terms, and cookie information. We also receive Log Data when you click on, view, or interact with links or connections on our Services, along with general information about your communications on Cheerbay. This includes details about users you have communicated with, communication dates and durations, and installation of other applications through our Services. Log Data is utilized to operate our Services, ensure their secure and reliable performance, protect account security, gauge service popularity, and facilitate connections on Cheerbay. Additionally, this data aids in improving our Services and enhancing our marketing effectiveness. Metadata related to items made available through Cheerbay, such as connection dates or locations, may also be utilized.
Log Data is retained for a period of up to 30 days.
2.4 Other Third Parties and Affiliates
We may receive information about you from third parties, including partners who assist in evaluating content safety and quality on our platform, our corporate affiliates, and services linked to your account.
The information received from third parties is utilized to operate our Services. For integrations officially supported by us, you may revoke permission from your application settings at any time; for other integrations, please refer to the respective service's settings.
You may furnish us with payment information, including your credit or debit card number, expiration date, CVV code, and billing address, to make purchases offered as part of our services. If you initiate a payment or transfer funds using our features or Services, we may receive transaction information, such as the timing of the transaction.
2.5 Personalizing Based On Your Inferred Identity
Upon logging into Cheerbay on a browser or device, we will associate that browser or device with your account for purposes like authentication, security, and personalization. Subject to your settings, we may also associate your account with browsers or devices other than those used to log into Cheerbay (or associate your logged-out device or browser with other browsers or devices). Other information provided to Cheerbay, such as an email address, will be associated with your account. Subject to your settings, this information may be utilized to infer additional details about your identity. For example, we may associate your account with hashes of email addresses that share common components with the provided email address. This is done to operate and personalize our Services. For instance, logging in through Facebook enables us to connect with your age profile there, ensuring compliance with our App usage standards.
2.6 During Usage of the App
Device Information: Cheerbay may collect and store details about the device(s) you use to install and access the App, such as device model, unique identifier, IP address, device capabilities, and page view statistics.
Your Activity: Information about your and others' App usage and activity, including matches, text messaging, music choices, and geographic usage, may be collected and stored by Cheerbay. Your device permissions are required for accessing and copying your photos for use as profile pictures or shared media files within the App. Access to your camera/microphone may also be required to record video/audio, including music files, to facilitate App and Site usage. Additionally, video and images may be captured to ensure content safety on our platform.
Content You Shared: Your profile, interests, text messages, photos, screenshots, videos, music choices, and other communications shared within the App may be stored on our servers. Sharing such information may render it publicly accessible, depending on your actions or those of other users with whom you've shared the information. Cheerbay shall not be held liable for the use or misuse of shared information.
Content You Created: User-generated content, such as photos, screenshots, comments, interests, and other materials, may be collected and stored by Cheerbay.
Transaction Information: Payment information is required to complete transactions, which may include credit card details, transaction dates, merchants' names, and transaction amounts. Cheerbay may process or store payment information, along with other transaction-related details.
Error-Reporting Information: Error reports are collected if the App crashes or malfunctions, to investigate errors and enhance App stability. These reports contain information like device type, version, identifier, error timing, and affected feature. Personally identifiable information is not included or is only incidental.
2.7 When You Visit Our Site
We may employ online tracking technologies, such as cookies, pixel tags, and web beacons, to automatically gather information about your visits to our Site, including browsing history, duration of stay, and frequency of visits. Location information provided by your device during interactions with our Site, along with device details (e.g., device ID, operating system, browser type/version), may also be collected. You have the right to disable any online tracking technologies. These technologies aid in secure login, data analytics for service development, and creation of new services. For further details on data usage, refer to the Cookie Policy section below.
2.8 Age
The Service is not intended for children or individuals under eighteen (18) years of age, and we do not knowingly collect personally identifiable information from such individuals. However, age information may be collected to ensure compliance with our App usage standards. If inadvertent collection of personally identifiable information from individuals under eighteen (18) years of age occurs, it will be promptly deleted from our records. Individuals under eighteen (18) years of age are advised against using the Service.
3. Your Personal Profile
You retain full access, control, and editing rights to the information you furnish for your user profile on the App (referred to as your "Profile") at all times. This encompasses details such as your profile pictures and videos, name, interests, personal bio, spoken languages, and birthday, all of which may be shared with your Cheerbay contacts. It is advised that you exercise caution in sharing only the information you wish to be included in your Profile. Your Profile will be visible to other users of the App who are connected to you. Furthermore, your Profile may be discoverable by other App users, for instance, through the App's contact listings, which may reveal your proximity to other users.
You have the option to "block" any Cheerbay user in your App contact list, thereby preventing them from accessing your Profile at any time. Additionally, Cheerbay may automatically populate certain information in your Profile, such as your name, Facebook profile picture, date of birth, email, gender, and Facebook ID, if you have logged into the App using your Facebook account. You are able to delete and update your Profile information within the App, as outlined in Section 13 and our Safety Centre.
4. Purpose and use of personal information
We adhere to the principle of data minimization when collecting and utilizing your data, ensuring that your data will be used solely in accordance with the specified purposes outlined below. Our processing of your data is solely for the purpose of providing the Service and other related business activities, including but not limited to:
4.1 Service Provision
- Facilitating connections between you and other users within the App.
- Allowing you to share your Profile with other users on the App.
- Providing video and audio call functionalities within the App.
- Enabling you to send images and videos through the App.
- Displaying the names of individuals you communicate with and displaying your name to individuals you communicate with on the App.
- Providing certain features of the App such as Premium Services (as outlined in our Terms of Service), playing games, and sharing/playing music during video calls.- Enabling you to contact us.
- Connecting with third parties for payment processing.
- Conducting analytics to offer better and more relevant connections, additional offers, and updates to our Services.
4.2 Account Administration
- Creating and updating your account.
- Delivering administrative notices, alerts, and communications relevant to your App usage.
- Facilitating networking opportunities and providing location or interest information regarding other App users.- Developing, testing, and improving our Services through surveys, research, statistics, analytics, and user habits/behaviors analysis.
- Handling payments for transactions conducted through the Service via third-party providers.
- Sending marketing communications, notifications (including details about our Membership Loyalty Programme), and communicating about our Services, policies, and terms.
- Responding to user inquiries.
4.3 Safety, Integrity, and Security Promotion
For audit, compliance, controls, security, and risk management purposes, we verify accounts and activities, combat harmful conduct, detect and prevent bad experiences and illegal behavior, maintain the integrity of our Services, and promote safety and security. This includes investigating suspicious activity or violations of our Terms of Service and policies, and enabling users to report issues.
4.4 Business Management
- Establishing, exercising, and/or defending our legal rights.
- Complying with legal, regulatory, and reporting requirements to regulatory bodies.
- Ensuring user safety through content moderation.
- Involvement in corporate transactions such as purchases or sales of business units, acquisitions, mergers, asset sales, or similar events.
- Fulfilling contractual obligations with us and third parties.
4.5 Information Across Our ServicesWe aggregate information about you and your activities on Cheerbay with our other Apps and Services to provide a comprehensive engagement experience and ensure a tailored and consistent user experience across our Services.
5. Legal Basis for processing your data
During your usage of our Service, there exist various legal grounds for the processing of your data. These legal grounds necessitate the processing of your data based on one or more of the following principles:
- Contractual Obligation: We process your data as required to fulfill our contractual obligations outlined in the Terms of Service agreement with you.
- Legitimate Interests: Processing may occur based on legitimate interests pursued by us or a third party, including but not limited to fraud prevention, network and information security, and internal administrative purposes. This processing is conducted unless such interests are overridden by your own interests or fundamental rights and freedoms that necessitate the protection of personal information.- Consent: We may process your personal information for specific purposes, provided you have given us consent to do so. These purposes may include the provision of our Service and fulfillment of other requests made by you.
- Legal Compliance: Processing may be necessary to comply with legal obligations or requirements imposed by law.
- Public Interest and Vital Interests: Processing may also be necessary in the public interest or to safeguard your vital interests or those of others.
6. Sharing Information with Third-Party Partners
We hereby disclose information and content to our affiliates, vendors, and service providers, who contribute to the operation of our business by rendering technical infrastructure services, analyzing user interactions with our Services, delivering customer support, ensuring security, facilitating financial transactions, enabling music sharing, or conducting surveys. Your information may be shared or transferred to other users, our affiliates within our Group, or Third-Party Partners for the aforementioned purposes essential for the provision of our Services to you. The disclosed information may include, but is not limited to:
- Your publicly visible information and Profile, encompassing your ID, name, gender, geographic location, photographs, date of birth, interests, and in-App music playlists;
- All information voluntarily shared by you with other users, or information disclosed by other users about you;
- Our parent company, subsidiaries, affiliates, and/or branch offices , which contribute to the operation of the App or Site Services, as well as the integration of your information with our other applications facilitating the delivery and performance of the Services;
- Any agents or contractors acting on our behalf, including IT companies supporting our website and other business systems, back-office service providers, payment processors, data management and analytics service providers, and data cleansing service providers. Additionally, subject to your consent, we may engage direct marketing companies and mailing houses to assist in managing our electronic and postal communications;
- Relevant third parties, such as telecommunications operators, third-party collection agencies, credit reference agencies, security agencies (including identification verification service providers), credit providers, banks, financial institutions (including payment processors);
- Professional advisors, including legal advisors and auditors;
- Regulatory authorities, law enforcement agencies, courts, and other governmental agencies; and
- Any actual or proposed assignees or transferees of any part of our business or operations.
7. Parties with whom you may choose to share your User Content
By voluntarily disclosing or posting any information or content on the App, including your User Content, you acknowledge that such content becomes publicly available. Once you have shared or made your User Content public, it may be viewed and redistributed by others, and there may be no means to prevent its dissemination once it is made public.
Even in the event that you delete any User Content (e.g., screenshots) that you have created or posted on the App, copies of such User Content may remain accessible through cached or archived pages of the App or may have been copied or saved by other users or third parties (e.g., through the use of social media platforms such as Facebook).
Any personally identifiable information that you: (i) share in text messages, photos, videos, or other means within or through the App with other users; or (ii) submit via live messaging on the App, may be viewed and utilized by others. Cheerbay shall not be held responsible for any use or misuse of such information that you share or submit.
8. Direct Marketing
If you have chosen to receive direct marketing content from us through notifications, you acknowledge and agree that we may utilize your personally identifiable information to:
- Transmit direct marketing communications to you, such as information pertaining to Token offerings, related to the latest news, events, updates, offers, contests, and promotions concerning our Service; or
- Assess your preferences, online activities, and transactional history to derive insights, enabling us to tailor the updates, promotions, offers, and services we present to you through our Site, our App, and our direct marketing communications, including social media or other communication channels, such as email.
Before furnishing you with direct marketing communications, we will invariably seek your explicit consent. You reserve the right to opt out of receiving such direct marketing communications from us at any time. For further details, please refer to the section on Your Data Protection Rights below.
9. Data Access and Removal
You retain full control over the information you opt to disclose to us via the App (except for data we deem mandatory for your usage). You can manage this by adjusting your settings within the App or your mobile device. Alternatively, you have the option to completely uninstall the App from your device.
At any time, you have the liberty to request the removal of your data. If you request the deletion of your account, we will endeavor, to the extent commercially feasible, to eliminate your data from our servers, barring any legal or regulatory obligations mandating the retention of certain personally identifiable information. Please be aware that deleting your personally identifiable data from our database may result in the inability to continue providing you with our services.
To initiate the deletion of your data, kindly navigate within the App to the Settings section of your profile, proceed to "Account Settings", select the "Delete Account" option, and then confirm the deletion.
Furthermore, you reserve the right to request the erasure of your data by submitting an email to the following address: contact@cheerbay.info
10. Outbound Links
In the event that you access a website or application provided by a third party, whether through the App or the Site, it is important to note that such third party may also gather information pertaining to you. It is imperative to understand that we neither own nor control, and thus cannot be held responsible for, the privacy practices of third party websites or applications. We advise you to consult the privacy policies of each respective third party for comprehensive insight into how they collect and utilize the information they gather concerning you. Please be aware that this Privacy Policy does not extend to any exchange of information between yourself and any such third party.
11. SecurityProtecting your privacy and personal information stands as a paramount objective for Cheerbay. We uphold stringent measures to ensure the privacy and security of all personally identifiable information furnished to us. Rigorous stress tests are conducted on our systems to facilitate ongoing enhancements. Access to any personally identifiable information is strictly confined to Cheerbay, contractors, agents, as well as Third-Party Partners and service providers, who require such information for the provision, operation, development, maintenance, support, or enhancement of the Service, or to fulfill any of the objectives outlined in this Privacy Policy. Cheerbay employs appropriate technical and physical security measures, including password protection, access logs, and system monitoring, to safeguard the confidentiality and security of all user information against any potential loss or unauthorized disclosure, usage, or modification.
However, due to the inherent nature of the Internet and associated technologies, we cannot guarantee absolute protection of information under our purview against any loss, misuse, or alteration.
Your information may be stored and processed in any country where Cheerbay or their service providers maintain facilities. In this context, or for purposes of sharing or disclosing data as outlined in this Privacy Policy, Cheerbay reserves the right to transfer information outside your country. By utilizing the Service, you consent to any such transfer of information beyond your country's borders.
When transferring personal information internationally, we establish safeguards in accordance with applicable law. Should you require further information regarding our practices concerning personal data transfer, please reach out to us via “Customer Service”.
Additionally, we may pseudonymize or aggregate Personal Information for analytical purposes. This aids us in developing new and enhancing existing services, conducting fraud detection and account safety analyses, analyzing usage trends, and furnishing third-party service providers with fundamental statistics concerning how their service is utilized by Cheerbay users.
12. Retention of Your Data
We shall retain your personal data solely for the duration required to achieve the objectives outlined in this Privacy Policy, unless legal obligations necessitate its retention for an extended period. Upon cessation of necessity for your personal data, we shall proceed to either irreversibly anonymize it or securely delete it from our servers.
13. Your Data Protection Rights
Cheerbay hereby acknowledges your data protection rights as follows:
- Access Right: Cheerbay affirms your entitlement to confirm the processing status of your personal information and to request a copy thereof, where applicable.
- Consent Withdrawal Right: Your consent provides Cheerbay with legal grounds for processing your personal information. You reserve the right to withdraw such consent at any time.
- Rectification Right: You are entitled to request Cheerbay to rectify any inaccuracies in your personal information.
- Erasure Right: Under certain circumstances, you may request the deletion of your personal information. Please note that this right may be limited if such data are necessary for legal compliance or defense against legal claims.
- Processing Restriction Right: You have the right to object to and request restrictions on the processing of your personal information in certain contexts.
- Data Portability Right: You have the right to receive your personal information from Cheerbay in a structured, commonly used, and machine-readable format, and to transmit said information to another controller, subject to certain conditions.
- Objection Right: You have the right to object to the processing of your personal information at any time, provided there are grounds relating to your specific situation.
- Complaint Right: Should you believe that Cheerbay has infringed upon any of your rights, you reserve the right to file a complaint with our Data Protection Officer, whose details are provided below.
Please note that Cheerbay will cease processing your personal information upon objection unless compelling legitimate grounds exist, which override your interests, rights, and freedoms or are necessary for legal claims.
14. Cookie Policy
Cookies are petite textual data files stored on your browser or device by websites, applications, online media, and advertisements during website visits.
We utilize cookies and akin identification technologies like web beacons and pixel tags across our Site, App, emails, and online ads for multifarious intents. These include user verification, retention of user preferences and settings to enrich subsequent visits to our Site or App, provision of pertinent content and ads based on user preferences, location, and usage patterns, monitoring, assessment, and optimization of our Site and App operations, tracking and gauging the efficacy of our ad campaigns, and analysis of traffic on our Site, App, and partner or Cheerbay websites.
You have the liberty to choose whether to accept cookies or not by adjusting your browser settings to tailor your cookie preferences. Though most browsers default to cookie acceptance or prompt users to accept cookies, you retain the prerogative to delete or hinder all browser cookies. However, disabling cookies may impede the proper functioning of certain services, resulting in an inefficacious and non-personalized user experience.
15. Notification of Changes
We retain the right, at our discretion, to amend this Privacy Policy periodically. You are entitled to review updates to our Privacy Policy at any time through links provided on our Website. By accepting electronic communications and/or postings of a revised Privacy Policy on the Website, you acknowledge that such electronic communications or postings serve as notice to you of the Privacy Policy.
In the event of significant alterations to this Privacy Policy, we will inform you by publishing a revised Privacy Policy on our Website, or through a notice on our Site, or as a pop-up within our App, or as required by applicable law. You consent to periodically review the Privacy Policy to stay informed of any changes. Your continued use of the Service following the publication of a revised Privacy Policy or receipt of notice on our Website signifies your acceptance of the updated Privacy Policy.
16. Contact information
If you have any questions about this Privacy Policy, please contact us at contact@cheerbay.info.
17. Date
This Privacy Policy was lastly modified in June 1, 2024.