Last updated 25th March 2023
1. Information we collect
In general, you may visit our Site without providing any personal information. However, in order to use certain features of our Site, we may need to collect your personal information. For example:
- We collect your username, email address and password when you create an account or public user profile. You may be required to provide additional information such as your first name, last name or your Instagram username. We collect additional information that you choose to add to your account or public user profile, such as a profile picture or information about your hobbies and interests.
- We collect your name, contact information and payment card information when you purchase a product or service through our Site (such as a subscription or classified advertisement).
- If you use a social media account to create an account on our Site, to log-in to our Site, or if you otherwise interact with a social media service through our Site (such as by using a plug-in), we will receive personal information from the social media service, such as your username, email address, gender, public profile information and any other information that you have agreed to share with us, whether explicitly or through your privacy settings.
- Our Site may offer public forums or communication platforms that allow you to communicate with other users, post information, content, images, photos or videos, post your opinions on surveys, or submit reviews or ratings (collectively, your “Content”). Your Content will be associated with your public user profile. Your Content and public user profile is public, unencrypted and non-confidential. This means that it can be read and used by others, including advertisers. We are not responsible for the information you choose to submit in these public areas. You should exercise caution when deciding to disclose personal information in public areas of our Site.
- We collect geographical location information if the Site you are using is location-enabled and your device transmits location data and/or your IP address, so we can provide location-specific information to you.
- We may collect personal information when you participate in a survey, poll, contest or promotion, such as your name and contact information and responses to survey or poll questions or the information you provide on a contest entry form.
- We may collect other personal information with your consent or where required or permitted by law.
We, our service providers and third party advertising partners also collect information about Site visitors automatically using cookies and other tracking technologies. See Cookies, tracking technologies and interest-based advertising below.
2. How we use the information we collect
We generally use the personal information we collect to provide the product, service, feature or information you have requested and for our reasonable business purposes, including:
- to manage our Site and provide our services, such as to create and administer accounts and facilitate the use and enjoyment of forums and communication platforms;
- to enable geographic-specific features, such as geographic-specific pricing and information;
- to process payments;
- to notify you of changes to your account or our Site’s services, terms, conditions or policies and to provide you with administrative messages, updates, legal notices, technical notices or security alerts;
- to customize your user experience, including by tailoring the advertisements that are displayed to you to make them more useful and relevant to you;
- to conduct research and development, analyze and understand trends and user behaviour and to improve our Sites, products and services;
- to respond to your inquiries and provide you with technical and other support;
- to ensure compliance with our Terms of Use and prevent fraud;
- to provide you with newsletters, information, promotional offers and other advertising about us or our advertising partners;
- to facilitate your participation in a contest or similar promotion, or a survey or poll;
- to meet contractual obligations; and
- for other purposes with your consent or as permitted or required by law.
3. Cookies, tracking technologies and interest-based advertising
We, our service providers and third-party advertising partners use technologies that automatically collect information about Site visitors.
We automatically collect information about how you access, navigate and leave our Site, including the website you came from before visiting our Site, what browser type and operating system you are using, the internet protocol (IP) address you are accessing the Site from, your mobile device ID or Advertising ID if you visit our Site from a mobile device, the pages of our Site that you are navigating through, the date and time of your visit, how long you spend on our Site or certain pages of our Site, and what website you go to after visiting our Site. This information may be used to determine how many visitors visit our Site or certain areas of our Site, how long they remain on our Site, whether they use the hyperlinks we provide or respond to advertising and to tailor our advertisements to you. We may share this information with partners who referred you to our Site, and with advertising partners, who may use the information to optimize the traffic they send to us and for delivering targeted ads to you when you visit other websites.
We, our service providers and third-party advertising partners collect information about Site visitors using cookies and other tracking technologies (including browser cookies, pixels etc). We use these technologies to remember your preferences and facilitate your navigation of our Site. We and our service providers and third-party advertising partners also use these technologies to track your activities on our Site and other websites, including the websites and web pages that you visited, the ads or content that you clicked on, any items you may have purchased and the search terms you used, in order to deliver tailored advertising to you. We may also share a hashed or encrypted version of your email address or telephone number with advertising partners so that you may be served with tailored advertising on our websites or other third party websites. These advertising partners are not permitted to use your hashed or encrypted email address for any other purpose.
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject any cookies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. If you don’t want us to share your hashed or encrypted email address with advertising partners, simply opt-out of our promotional communications. See Your Choices below.
At this time, we do not respond to browser “do not track” signals. However, you may also opt-out of network advertising programs that track your activities across multiple websites to deliver personalized advertising content to you. Please visit Digital Advertising Alliance of Canada Opt-Out Page, European Interactive Digital Advertising Alliance, NAI Opt-Out Page and the Ad Choices Opt-Out Page.
We use Google Analytics to help us understand how our Site visitors use the Site, and as well as certain features of Google Analytics Display Advertising to advertise online, sell advertising and to develop content. You can opt out of Google Analytics and customize Google’s Display Network ads. Please visit Google’s Ad Settings and Google Analytics Opt-out Browser Add-on. Please visit How Google uses data when you use our partners’ sites or apps for a description of how Google uses information sent by our browser and for ways you can control the information sent to Google.
4. How we share your information
We may share information we collect about you in the following circumstances.
Advertising partners
We share information with our third-party advertising partners as described in the Cookies, tracking technologies and interest-based advertising section above.
Service Providers
We may use service providers (including affiliates acting in this capacity) to provide services to us or to you on our behalf. For example, our service providers may host our Site, analyze data collected from our Site, provide customer service on our behalf, administer our promotions, facilitate and process transactions and payments, provide marketing or promotional assistance, distribute emails and other communications, post our advertisements (including online through targeted advertising campaigns), and collect your feedback on our Site and advertisements. We share your personal information with our service providers solely for the purposes of providing services to you and to us. They are not permitted to use your personal information for other purposes. Some of our service providers are located outside of Canada, including in the United States. While your personal information is located outside Canada it will be subject to legal requirements applicable to our service providers, for example, lawful requirements to disclose personal information to national security agencies or government authorities in certain circumstances. For EU residents see Users from the European Union section below.
Aggregate or de-identified information
We may use your personal information to create aggregate statistics and de-identified data. We may use, share and sell this information for any purpose.
With your consent
We may share your personal information with third parties with your consent. For example, if you provide us with your contact information, such as an e-mail address, for the purposes of signing up for information, newsletters, contests, or marketing offers from a third party, or for receiving business offers or service quotes from a third party, we may share your personal information for that purpose. Once shared, your personal information will be subject to the privacy policy of that third party.
Business Transactions
We may disclose personal information to third parties in connection with the proposed or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of Cheeky Clouds or our business or assets. These third parties may use the information, for the purposes of evaluating and/or completing the proposed transaction. We will use reasonable efforts to ensure that our successors or assigns process the information we transfer to them in a manner that is consistent with this Privacy Policy.
Other
We may disclose your personal information in other circumstances where permitted or required by law or other legal process. For example, we may disclose your personal information: (a) to collect a debt owed to us; (b) as necessary to comply with a subpoena, warrant, court order or other legal process; (c) if disclosure is requested by an investigatory body, law enforcement official or governmental authority which has lawful authority to request the disclosure of the information in respect of an investigation or other legal process; or (d) if we have reasonable grounds to believe that the information relates to a breach of an agreement or contravention of a law, or to protect the personal safety of our users or defend our rights or property.
5. How we store and protect personal information
Personal information is maintained on our servers (or those of our service providers). In an effort to protect your personal information against unauthorized access or disclosure. For example, accounts you create on our Sites are password protected. In identified parts of our Sites, we use SSL-encryption to protect data transmissions. We limit access to personal information to employees, representatives and service providers who require access in connection with their job responsibilities. Please note it is not possible to transmit data with absolute security over the internet, and we cannot and do not guarantee the security of your personal information.
6. Links to external content
Our Site may link or direct you to other websites, services or external content provided by third parties. We do not exercise any control over these third party websites or services. We are not responsible for the privacy practices of such third party websites or services. We recommend that you read the privacy policy for any third party website that you visit or service that you use.
7. Children
Our Sites are not directed to and we do not knowingly request or collect personal information from children – persons under 13 years of age, or another age if required by applicable law – without prior verifiable parental consent. If we become aware that we have unknowingly collected personal information about a child without verifiable parental consent, we will delete this information from our records or, if that is not reasonable, we will take reasonable available steps to de-identify the information.
8. Accessing or correcting your personal information
We encourage you to keep your personal information accurate and up to date. You can access and correct the information in your account or public user profile by logging in to your account or profile and making the necessary edits.
You can request access to or correction of your personal information in our custody or control by contacting us as set out below. We may take reasonable steps to authenticate your identity before providing you with access to your personal information or making corrections. Please also note that in some cases we may not be able to provide you with the personal information you have requested (for example, if the information is subject to solicitor-client privilege or contains personal information of others that cannot be severed).
9. Users from the European Union
This section of the Privacy Policy supplements the information in this Privacy Policy and applies only if you reside within and use our website, mobile or other applications covered by this Privacy Policy from a country that is a Member State of the European Union.
Cheeky Clouds is the data controller for processing of information defined as personal data under applicable data protection law (“Personal Data”).
Retention
Your personal information will be retained for as long as reasonably necessary for the purposes set out above, considering criteria such as applicable rules on statute of limitations, legal requirements and the duration of your use of our Site and receipt of our services.
Legal Basis for Data Processing
We process Personal Data for the purposes set out in this Privacy Policy, as described above. Our legal basis to process Personal Data includes processing that is: necessary for the performance of the contract between you and Cheeky Clouds (for example, to provide you with the services you request and to process payments); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you and to improve the Site and our services); and based on your consent (for example, to communicate with you about our products and services and provide you with marketing information), which may subsequently be withdrawn at any time without affecting the lawfulness of processing based on consent before its withdrawal.
In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our website.
International Transfers of Personal Data
Our personnel and some of the third-parties to whom we disclose Personal Data (as set out above) may be located in countries outside of the European Economic Area (“EEA”), including in countries that may not provide the same level of data protection as your home country. We take appropriate steps to ensure that recipients of your Personal Data are bound to duties of confidentiality and, where required under law, we implement measures such as standard data protection contractual clauses to ensure that any transferred Personal Data remains protected and secure.
Your Rights
You may be entitled, in accordance with applicable law, to object to or request the restriction of processing of your Personal Data, and to request access to, rectification, erasure and portability of your own Personal Data.
If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected. You may lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, if you consider that our processing of your Personal Data infringes applicable law.
10. Your Choices
You may opt out of receiving promotional communications from us at any time by following the unsubscribe instructions included in each communication and/or by selecting your communication preferences in an account or profile.
You may be able to control the information we received from your device or from third parties (such as social media networks) by changing your device settings, browser settings or privacy settings.
You may withdraw your consent to our collection, use or disclosure of your personal information, subject to contractual or legal restrictions and reasonable notice. However, if you withdraw your consent to certain collections, uses or disclosures of your personal information, we may not be able to provide you with certain products or services.
11. How to contact us
If you have any questions or comments about this Privacy Policy, please contact us via our contact page.