Privacy Policy

CHEERS PRIVACY POLICY
Last updated: May 23 2025

1. Who We Are

“Cheers,” “we,” “us,” or “our” means Cheers Technologies, Inc., 1395 22nd Street, Apt 643, San Francisco, CA 94107 USA. Contact our Privacy Officer at info@cheers.tech.

2. Scope of This Policy

This Policy explains how we collect, use, disclose, and protect Personal Information when you:

• visit https://cheers.tech or any website we own (the “Site”),

• use the Cheers dashboard, APIs, or mobile interfaces,

• interact with a Cheers NFC tag or QR code,

• communicate with us by email, SMS, phone, social media, or at events, or

• otherwise use our Services.

It does not cover third-party sites or services that link to or from ours.

3. Key Definitions

• Personal Information / Personal Data – data that identifies or can reasonably be linked to a natural person.

• Processing – any operation performed on Personal Information (collecting, storing, using, disclosing, etc.).

• Controller – the party that decides why and how Personal Information is processed (typically Cheers).

• Processor – a party that processes Personal Information on a Controller’s behalf (when your employer uses Cheers, we act as its Processor under our Data Processing Addendum).

• Cookies – small text files stored on your device that hold information.

4. What We Collect

Account and Contact Data
Name, company, title, postal address, email, phone, login credentials.

Content and Feedback
Reviews, ratings, tips, survey answers, photos, free-text comments, recordings of customer-employee interactions (where lawful).

Employee Metrics
Tap counts, conversion rates, location ID, timestamps, revenue generated, tips earned.

Device and Usage Data
IP address, device identifiers, browser type, language, referring URL, pages viewed, time on pages, clicks.

Transactional Data
Payment tokens, partial card data, amounts (handled by PCI-compliant processors such as Stripe).

Marketing Data
Preferences, event attendance, campaign engagement, opt-in consents.

Sensitive Data
Only if you voluntarily provide it (e.g., precise geolocation or health info in a review). We never request biometric templates or government IDs.

We do not knowingly collect data from children under 16.

5. Legal Bases for Processing (EEA/UK)

We rely on:

• Contract performance – to provide, secure, and improve the Services.

• Legitimate interests – to operate, innovate, and market our Services (balanced against your rights).

• Consent – for optional marketing or collection of sensitive data.

• Legal obligations – to meet record-keeping, tax, and compliance duties.

• Legitimate interests – for business transfers such as mergers or acquisitions.

You may withdraw consent at any time.

6. How We Use Information

1. Create and manage accounts; authenticate users.

2. Fulfil NFC tap flows for reviews, tips, referrals, or app downloads.

3. Generate dashboards, benchmarks, and predictive models.

4. Send service, security, and transactional notices.

5. Provide support and training.

6. Improve, test, and troubleshoot features and algorithms.

7. Conduct marketing and event outreach (opt-out any time).

8. Detect, investigate, and prevent fraud or security incidents.

9. Comply with legal requests and enforce our rights.

7. Disclosure and International Transfers

We share Personal Information only when necessary and with appropriate safeguards:

• Service providers – cloud hosting, analytics, customer-success tools, email/SMS platforms, payment processors, security vendors.

• Employer customers – if your employer uses Cheers, it receives the data relevant to its workforce.

• Business transfers – data may transfer as an asset if we merge, sell, or are acquired.

• Legal compliance – when lawfully compelled to do so or to protect rights, safety, or property.

• Aggregated or de-identified data – never identifies you personally.

Data is hosted in the United States and may be transferred internationally under Standard Contractual Clauses or other approved mechanisms.

8. Retention

We retain Personal Information only as long as needed for the purposes above and any additional period required by law, contract, or litigation hold. When no longer necessary, we delete or irreversibly anonymize the data.

9. Security

We protect Personal Information using:

• Encryption in transit (TLS 1.2+) and at rest.

• Role-based, least-privilege access controls.

• Continuous monitoring, logging, and alerting.

• Annual penetration testing and vulnerability scanning.

• Secure development lifecycle and code reviews.

No online system is perfectly secure. If a breach occurs, we will notify affected individuals and regulators as required.

10. Your Privacy Rights

EEA/UK (GDPR) – Access, rectify, erase, restrict/object, portability, and lodge a complaint with a supervisory authority.
California (CPRA) – Know, delete, correct, opt-out of “sharing”/“selling,” limit use of sensitive data, and freedom from retaliation.
Virginia, Colorado, Connecticut, Utah – Access, correct, delete, portability, opt-out of targeted ads and profiling.
Nevada – Opt-out of future sale of personal information.
Canada (PIPEDA) – Access, correct, withdraw consent, complain to the Privacy Commissioner.

To exercise any right, email info@cheers.tech. We will verify your identity and respond within the timeframe required by law. You may designate an authorized agent where permitted.

11. SMS & Telemarketing

• Marketing SMS or autodialed calls are sent only with express written consent.

• Message and data rates may apply.

• Reply “STOP” to opt out or “HELP” for assistance.

• SMS opt-in data is not sold or shared with third parties except vendors that deliver messages on our behalf.

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12. Cookies and Similar Technologies

We use first- and third-party Cookies, SDKs, and pixels to:

• Operate the Site and remember preferences.

• Measure traffic and performance.

• Personalize content and ads on other sites.

Where required, we ask for consent via our Cookie banner. You can manage Cookies through your browser or our “Cookie Settings” link. Disabling some Cookies may affect functionality. We honor Global Privacy Control signals.

13. Third-Party Links

The Site may link to services like Stripe, Google, Apple, LinkedIn, or X. Their privacy practices are their own; review their policies before providing data.

14. Children

The Services are not intended for children under 16. If you believe we hold a child’s data, contact us and we will delete it promptly.

15. Changes to This Policy

We may revise this Policy periodically. Material changes will be announced by email (if we have it) and/or a notice on the Site 30 days before taking effect. Continued use after the effective date constitutes acceptance.

16. Contact Us

Cheers Technologies, Inc.
Attn: Privacy Officer
1395 22nd Street, Apt 643
San Francisco, CA 94107 USA
info@cheers.tech

If we cannot resolve a concern, you may lodge a complaint with your local data-protection authority.

17. Supplemental U.S. State Disclosures

A detailed notice describing the categories of Personal Information collected, sources, purposes, and disclosures as required by the California Privacy Rights Act and similar laws is available on request via info@cheers.tech.

Thank you for trusting Cheers to power measurable frontline excellence.