Privacy Policy
Last modified: June 1, 2023
Introduction
Service Solutions Pro s.r.o., doing business as Cheelee Wallet ("Cheelee Wallet", "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 Wallet collects and process
your personal data through your use of our websites https://cheeleewallet.io/and the Cheelee
Wallet 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 Wallet (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. 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 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
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
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:
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● 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.
● Transaction IDs. When performing an exchange through a third-party API provider, we
may log information such as the wallet addresses and the transaction IDs involved.
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.
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● 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.
● Facilitate the connection of third-party services or applications.
● Find and prevent fraud, detect security incidents, and respond to trust and safety issues
that may arise.
● Contract with third-party API providers, including providing customer service, verifying
customer information.
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.
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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
(c) Transaction
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
(c) Profile
(d) Marketing and
Communications
(a) Performance of a contract with
you
(b) Necessary to comply with a
legal obligation
(c) Necessary for our legitimate
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
(c) Profile
(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
(c) Technical
(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
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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
(c) Profile
(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
Apps, products/services,
marketing, customer
relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate
interests (to define types of
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
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and
Communications
Necessary for our legitimate
interests (to develop our
products/services and grow our
business)
To Contract with third-party
API providers, including
providing customer
service, verifying
customer information.
(a) Identity
(b) Contact
(c) Technical
(d) Profile
(a) Performance of a contract with
you
(b) Necessary to comply with a
legal obligation
(c) Necessary for our legitimate
interests
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 – СhangeNOW
https://changenow.io/,https://partner.guardarian.com/,https://www.simplex.com/c
● 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
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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 Term of service.
● 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.
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.
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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 Term of Service https://cheeleewallet.io/
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.
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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
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:
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