Last modified: 22

November 2024

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 privacy

policy).

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

[email protected]

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 [email protected]

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

PP.

• 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 privacy

policy

(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 [email protected] 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

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

[email protected]

Marketing Communications

By using our Services, you agree to receive notifications about new products, services, special offers,

and events from the Company. These communications may be sent via email or other contact

methods provided by you during registration. You may opt out of receiving such notifications at any

time by contacting us at [email protected] with the subject line "Unsubscribe from marketing

communications."

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:

[email protected]