Last modified: 21

October 2022

Introduction

Nutson Ltd doing business as Cheelee ("Cheelee", "Company" or "We") respect your privacy

and are committed to protecting it through our compliance with this policy.

This Privacy Policy aims to give you information on how Cheelee collects and process your

personal data through your use of our websites https://cheelee.io/ and the Cheelee apps,

including any data you may provide through this website when you sign up to our newsletter,

purchase a product or service or take part in a competition.

This Policy also describes:

● The types of information we may collect or that you may provide when you purchase,

download, install, register with, access, or use Cheelee apps (the "Apps").

● Our practices for collecting, using, maintaining, protecting, and disclosing that

information.

Please read this policy carefully to understand our policies and practices regarding your

information and how we will treat it. If you do not agree with our policies and practices, do not

download, register with, or use this App or website. By downloading, registering with, or using

this App, you agree to this privacy policy. This policy may change from time to time (see

Changes to Our Privacy Policy). Your continued use of this App after we revise this policy

means you accept those changes, so please check the policy periodically for updates.

Controllers

In terms of the GDPR and UK GDPR Nutson Ltd and its affiliates is the data controller and

responsible for your personal data (also referred as "Company", "we", "us" or "our" in this

Our authorised representative under article 27 GDPR in the EU is Elena Riazanova with her

postal address at Cullera 11, 3C, Madrid, Spain.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us at

support@cheelee.io

Children Under the Age of 13

The Apps and websites are not intended for children under 13 years of age, and we do not

knowingly collect personal information from children under 13. If we learn we have collected or

received personal information from a child under 13 without verification of parental consent, we

will delete that information. If you believe we might have any information from or about a child

under 13, please contact us at support@cheelee.io

California residents under 16 years of age may have additional rights regarding the collection

and sale of their personal information. Please see Your California Privacy Rights section for

more information.

Information We Collect and How We Collect It

We collect information from and about users of ours Apps and websites:

● Directly from you when you provide it to us.

● Automatically when you use the Apps and websites.

Information You Provide to Us

When you download, register with, or use our Apps or upload your content we may ask you

provide some information:

● By which you may be personally identified, such as name, email address, telephone

number any other identifiers by which you may be contacted online or offline or ANY

OTHER INFORMATION THE APP COLLECTS THAT IS DEFINED AS PERSONAL

OR PERSONALLY IDENTIFIABLE INFORMATION UNDER AN APPLICABLE

LAW ("personal information").

● That is about you but individually does not identify you.

This information includes:

● Information that you provide by filling in forms in the App. This includes information

provided at the time of registering to use the App, subscribing to our services, posting

material or requesting further services. We may also ask you for information when you

enter a contest or promotion sponsored by us, or when you report a problem with the

App.

● Records and copies of your correspondence (including email addresses and phone

numbers), if you contact us.

● Your responses to surveys that we might ask you to complete for research purposes.

● Details of transactions you carry out through the Apps and of the fulfillment of your

orders. You may be required to provide financial information before placing an order

through the Apps.

● Your search queries on the Apps.

You may also provide information for publication or display ("Posted") on public areas of the

app or websites you access through the Apps/Websites (collectively, "User Content"). Your User

Content is Posted and transmitted to others at your own risk. Additionally, we cannot control the

actions of third parties with whom you may choose to share your User Content. Therefore, we

cannot and do not guarantee that your User Contributions will not be viewed by unauthorized

persons.

Automatic Information Collection and Tracking

When you download, access, and use the Apps, they may use technology to automatically

collect:

● Usage Details. When you access and use the App, we may automatically collect certain

details of your access to and use of the App, including traffic data, logs, and other

communication data and the resources that you access and use on or through the Apps.

● Device Information. We may collect information about your mobile device and internet

connection, including the device's operating system, browser type, mobile network

information..

● Stored Information and Files. The App also may access metadata and other information

associated with other files stored on your device. This may include, for example,

photographs, audio and video clips, personal contacts, and address book information if

you allow the app to access this data in order to operate correctly.

If you do not want us to collect this information do not download the App or delete it from your

device.

We also may use these technologies to collect information about your activities over time and

across third-party websites, apps, or other online services (behavioural tracking). Click here

www.aboutads.info for information on how you can opt out of behavioural tracking on or

through this app and how we respond to browser signals and other mechanisms that enable

consumers to exercise choice about behavioural tracking.

Information Collection and Tracking Technologies

The technologies we use for automatic information collection may include:

● Cookies (or mobile cookies). A cookie is a small file placed on your smartphone or

laptop. It may be possible to refuse to accept mobile cookies by activating the appropriate

setting on your smartphone. However, if you select this setting you may be unable to

access certain parts of our App.

● Web Beacons. Pages of the App and our emails may contain small electronic files known

as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit

the Company, for example, to count users who have visited those pages [or opened an

email] and for other related app statistics (for example, recording the popularity of certain

app content and verifying system and server integrity).

Third-Party Information Collection

When you use the Apps or its content, certain third parties may use automatic information

collection technologies to collect information about you or your device. These third parties may

include:

● Analytics companies.

● Advertisers, ad networks, and ad servers.

● Your mobile device manufacturer.

● Your mobile service provider.

Third party vendors, including Google, use cookies and similar technologies to serve ads based

on a user's prior visits to your website or other websites.

Google's use of advertising cookies enables it and its partners to serve ads to your users based on

their visit to your sites and/or other sites on the Internet.

You may opt out of personalized advertising by visiting Google Ads Settings or opt out of a

third-party vendor's use of cookies for personalized advertising by visiting www.aboutads.info.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal

information, to:

● Allow users to create accounts and to use our Services.

● Provide you with the Apps and their contents, and any other information, products or

services that you request from us.

● Fulfill any other purpose for which you provide it.

● Give you notices about your account/subscription, including expiration and renewal

notices.

● Carry out our obligations and enforce our rights arising from any contracts entered into

between you and us, including for billing and collection.

● Notify you when Apps updates are available, and of changes to any products or services

we offer or provide though it.

The usage information we collect helps us to improve our Apps and to deliver a better and more

personalised experience by enabling us to:

● Estimate our audience size and usage patterns.

● Store information about your preferences, allowing us to customize our Apps according

to your individual interests.

● Speed up your searches.

● Recognize you when you use the Apps.

We may also use your information to contact you about our goods and services that may be of

interest to you and subject to your consent.

We have set out below, in a table format, a description of all the ways we plan to use your

personal data, and which of the legal bases we rely on to do so for EU based users.

Purpose/Activity

Type of data

Lawful basis for processing

including basis of legitimate

interest

To register you as a new user

(a) Identity

(b) Contact

Performance of a contract (user

agreement) with you

To process and deliver your

order including:

(a) Manage payments, fees

and charges

(a) Identity

(b) Contact

Performance of a contract (user

agreement) with you

To manage our relationship

with you which will include:

(a) Notifying you about

changes to our terms or

(b) Asking you to leave a

review or take a survey

(a) Identity

(b) Contact

(d) Marketing and

Communications

(a) Performance of a contract with

you

(b) Necessary to comply with a

legal obligation

interests (to keep our records

updated and to study how customers

use our products/services)

To enable you to partake in a

prize draw, competition or

complete a survey

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and

Communications

(a) Performance of a contract with

you

(b) Necessary for our legitimate

interests (to study how customers

use our products/services, to

develop them and grow our

business)

To administer and protect our

business, websites and Apps

(including troubleshooting,

data analysis, testing, system

maintenance, support,

reporting and hosting of data)

(a) Identity

(b) Contact

(a) Necessary for our legitimate

interests (for running our business,

provision of administration and IT

services, network security, to

prevent fraud and in the context of a

business reorganisation or group

restructuring exercise)

(b) Necessary to comply with a

legal obligation

To deliver relevant websites

and Apps content and

advertisements to you and

measure or understand the

effectiveness of the

advertising we serve to you

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and

Communications

(f) Technical

Necessary for our legitimate

interests (to study how customers

use our products/services, to

develop them, to grow our business

and to inform our marketing

strategy)

To use data analytics to

improve our websites and

(a) Technical

(b) Usage

Necessary for our legitimate

interests (to define types of

Apps, products/services,

marketing, customer

relationships and experiences

customers for our products and

services, to keep our website

updated and relevant, to develop our

business and to inform our

marketing strategy)

To make suggestions and

recommendations to you

about goods or services that

may be of interest to you

(a) Identity

(b) Contact

(d) Usage

(e) Profile

(f) Marketing and

Communications

Necessary for our legitimate

interests (to develop our

products/services and grow our

business)

Disclosure of Your Information

We may disclose personal information that we collect or you provide:

● To our subsidiaries and affiliates.

● To service providers, and other third parties we use to support our business and who are

bound by contractual obligations to keep personal information confidential and use it

only for the purposes for which we disclose it to them, for example our hosting provider

Amazon Web Services.

● To a buyer or other successor in the event of a merger, divestiture, restructuring,

reorganisation, dissolution, or other sale or transfer of some or all of our assets, whether

as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which

personal information held by us about our Apps users is among the assets transferred.

● To fulfil the purpose for which you provide it. For example, if you give us an email

address to use the "email a friend" feature of our Websites or Apps, we will transmit the

contents of that email and your email address to the recipients.

● For any other purpose disclosed by us when you provide the information.

● To comply with any court order, law, or legal process, including to respond to any

government or regulatory request.

● To enforce our rights arising from any contracts entered into between you and us,

including the Terms of use.

● If we believe disclosure is necessary or appropriate to protect the rights, property, or

safety of the Companies, our customers or others. This includes exchanging information

with other companies and organisations for the purposes of fraud protection and credit

risk reduction.

Your Choices About Our Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the personal information you provide to us. This

section describes mechanisms we provide for you to control certain uses and disclosures over

your information.

● Tracking Technologies. You can set your browser to refuse all or some browser cookies,

or to alert you when cookies are being sent. If you disable or refuse cookies or block the

use of other tracking technologies, some parts of the App may then be inaccessible or not

function properly.

● Targeted Advertising by the Company. If you do not want us to use information that

we collect or that you provide to us to deliver advertisements according to our

advertisers' target-audience preferences, you can opt-out by opt out by visiting

www.aboutads.info. Also you can opt out of receiving targeted ads from members of the

Network Advertising Initiative ("NAI") on the NAI's website.

California residents may have additional personal information rights and choices. Please see

Your California Privacy Rights section for more information.

Your Legal Rights

Accessing and Correcting Your Personal Information

You can review and change your personal information by logging into the Apps and visiting your

account profile page.

You may also send us an email at support@cheelee.io to request access to, correct, or delete any

personal information that you have provided to us. We cannot delete your personal information

except by also deleting your user account. We may not accommodate a request to change

information if we believe the change would violate any law or legal requirement or cause the

information to be incorrect.

If you delete your User Content from the Apps, copies of your User Content may remain

viewable in cached and archived pages, or might have been copied or stored by other Apps users.

Proper access and use of information provided on the Apps, including User Content, is governed

by our Terms of use.

In some of the jurisdictions including EEA area and United Kingdom You may have

additional rights to:

Request access to your personal data (commonly known as a "data subject access request"). This

enables you to receive a copy of the personal data we hold about you and to check that we are

lawfully processing it.

Object to processing of your personal data where we are relying on a legitimate interest (or

those of a third party) and there is something about your particular situation which makes you

want to object to processing on this ground as you feel it impacts on your fundamental rights and

freedoms. You also have the right to object where we are processing your personal data for direct

marketing purposes. In some cases, we may demonstrate that we have compelling legitimate

grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend

the processing of your personal data in the following scenarios:

● If you want us to establish the data's accuracy.

● Where our use of the data is unlawful but you do not want us to erase it.

● Where you need us to hold the data even if we no longer require it as you need it to

establish, exercise or defend legal claims.

● You have objected to our use of your data but we need to verify whether we have

overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or

a third party you have chosen, your personal data in a structured, commonly used,

machine-readable format. Note that this right only applies to automated information which you

initially provided consent for us to use or where we used the information to perform a contract

with you.

Withdraw consent at any time where we are relying on consent to process your personal data.

However, this will not affect the lawfulness of any processing carried out before you withdraw

your consent. If you withdraw your consent, we may not be able to provide certain products or

services to you. We will advise you if this is the case at the time you withdraw your consent.

Right to make a complaint at any time to your local supervisory authority. We would, however,

appreciate the chance to deal with your concerns before you approach the supervisory authority

so please contact us in the first instance.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding

the use of your personal information.

Right to Opt Out of Sale. CCPA gives you a right to direct a business that sells your personal

information to stop selling your personal information and to refrain from doing so in the future.

We do not sell any of your personal information and will require our service providers not to sell

your personal information.

You also have the right not to be discriminated against for exercising any of the rights listed

above.

To the date when this privacy policy has been drafted, Cheelee is not subject to the CCPA.

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our App that

are California residents to request certain information regarding our disclosure of personal

information to third parties for their direct marketing purposes. To make such a request, please

send an email to support@cheelee.io

Data Security

We have implemented measures designed to secure your personal information from accidental

loss and from unauthorised access, use, alteration, and disclosure. All information you provide to

us is stored on our secure servers behind firewalls.

The safety and security of your information also depends on you. Where we have given you (or

where you have chosen) a password for access to certain parts of our Apps, you are responsible

for keeping this password confidential. We ask you not to share your password with anyone. We

urge you to be careful about giving out information in public areas of the Apps like message

boards. The information you share in public areas may be viewed by any users of the Apps.

Changes to Our Privacy Policy

We may update our privacy policy from time to time. If we make material changes to how we

treat our users' personal information, we will post the new privacy policy on this page with a

notice that the privacy policy has been updated or notify you with an in-App alert the first time

you use the App after we make the change.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

support@cheelee.io