Effective Date: August 25, 2025
Last Updated: August 25, 2025
1. Who We Are
Cheers Technology (“Cheers”, “we”, “our”, or “us”) acts as the Data Controller of your personal data when you use our website, mobile application, or services (collectively, the “Services”). This means we determine the purposes and means of processing your personal data.
We are committed to protecting your privacy and being transparent about how we collect, use, and safeguard your personal information.
Contact Information:
- Company: Cheers Technology
- Email: [email protected]
- Address: Gazi Mh. 1311 Sk. Nur Apt. No: 2B Yenişehir / Mersin, Türkiye
- Phone: +90 530 110 29 78
If you have questions about this Privacy Policy or our data practices, you may contact us at the details above.
2. Information We Collect
We collect several types of information to provide and improve our Services:
2.1 Personal Information You Provide
As a Cheers Partner:
- Business Information: Business name, business owner name, industry
- Contact Information: Phone number, mailing address
- Communication Data: Messages you send us, customer service interactions, and feedback
- App Content: Photos, reviews, comments, and other content you share
As a Cheers Customers:
- Account Information: Name, email address, birth date, and gender
- Communication Data: Messages you send us, customer service interactions, and feedback
- User Content: Photos, reviews, comments, and other content you share
2.2 Information Automatically Collected
- Device Information: IP address, device type, operating system, browser type and version
- Usage Data: Pages visited, time spent on pages, click-through rates, and navigation patterns
- Location Data: General or precise location if you grant permission
- Cookies and Tracking Technologies: Information collected through cookies, web beacons, and similar technologies
2.3 Information from Third Parties
- Business Partners: Data from advertising partners, analytics providers, and marketing platforms
- Public Sources: Publicly available information that we may combine with other data
3. How We Use Your Information
We use your personal information for the following purposes:
3.1 Service Provision
- To provide, maintain, and improve our Services
- To process transactions and send related information
- To provide customer support and respond to inquiries
3.2 Communication
- To send you service-related notifications and updates
- To deliver marketing communications and promotional offers (with your consent)
- To conduct surveys and gather feedback
3.3 Legal and Security
- To comply with legal obligations and regulatory requirements
- To protect against fraud, unauthorized access, and other security issues
- To enforce our terms of service and policies
3.4 Analytics and Improvement
- To analyze usage patterns and improve our Services
- To personalize your experience and content
- To conduct research and development
4. Legal Basis for Processing
We process your personal data only when we have a valid legal basis under GDPR:
- Account Registration and Access – Contract Performance
- Providing and Improving Services – Contract Performance, Legitimate Interest
- Transaction Processing – Contract Performance, Legal Compliance
- Customer Support & Communication – Contract Performance, Legitimate Interest
- Marketing Communications & Promotions – Consent (you may withdraw at any time by using unsubscribe links, adjusting account settings, or contacting us at [email protected])
- Analytics, Personalization & Service Improvements – Legitimate Interests (and Consent for cookies/trackers)
- Legal and Regulatory Compliance – Legal Obligation
- Fraud Prevention & Security – Legitimate Interests, Legal Obligation
- Location Data – Consent (we only collect precise location data if you grant permission in your device settings)
5. How We Share Your Information
We may share your personal information in the following circumstances:
5.1 Service Providers
We share information with trusted third-party service providers who help us operate our business, including:
- Cloud hosting providers (e.g., AWS)
- Email service providers (e.g., Google)
- Analytics and marketing platforms (e.g., Google Analytics)
These providers act on our behalf and only process data under contractual agreements that comply with GDPR, including safeguards for international transfers.
5.2 Business Transfers
In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business.
5.3 Legal Requirements
When required by law, legal process, or to protect our rights, property, or safety, or that of others.
5.4 With Your Consent
When you explicitly consent to sharing your information for specific purposes.
6. Data Retention
We retain your personal information for as long as necessary to:
- Provide our Services to you
- Comply with legal obligations
- Resolve disputes and enforce agreements
- Fulfill legitimate business purposes
Specific retention periods:
- Account Information: Until account deletion plus 30 days
- Transaction Records: 7 years for tax and legal compliance
- Marketing Communications: Until you unsubscribe plus 2 years
- Usage Data: 24 months for analytics purposes
7. Your Privacy Rights
You have the following GDPR rights:
- Access and Portability
- Correction and Deletion
- Processing Control (restrict or object)
- Withdraw Consent: You can withdraw consent at any time by:
- Updating your account settings
- Clicking “unsubscribe” in marketing emails
- Contacting us at [email protected]
- Automated Decision-Making: In some cases, we use automated decision-making and profiling to improve our Services and provide personalized experiences. For example, we may automatically assign you to a loyalty tier or recommend rewards based on your purchase history, frequency of visits, or engagement with our Services.
These decisions are made to offer you relevant benefits and do not produce legal effects concerning you or significantly affect your rights. You have the right to:
- Object to automated decision-making
- Request human intervention
- Express your point of view
- Contest decisions that significantly affect you
To exercise these rights, contact us at [email protected]. We will respond within 30 days of receiving your request. We may request proof of identity before fulfilling your request.
8. Cookies and Tracking Technologies
We use cookies and similar technologies.
- Essential Cookies: Necessary for website operation
- Analytics & Marketing Cookies: Used only with your consent
- Preference Cookies: Save your settings
- Managing Cookies: On your first visit, you will see a cookie banner that allows you to accept or reject non-essential cookies. You may also manage cookies in your browser settings.
9. Data Security
We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:
- Encryption of data in transit and at rest
- Regular security assessments and updates
- Access controls and authentication procedures
- Employee training on data protection practices
However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.
10. International Data Transfers
Where personal data is transferred outside the EEA, we ensure safeguards such as:
- Standard Contractual Clauses approved by the European Commission
- Adequacy decisions
- Binding Corporate Rules (where applicable)
11. Children’s Privacy
Our Services are not directed to individuals under the age of 16. We do not knowingly collect personal data from children under the age of 16, or the lower age limit allowed by local law (not below 13). If we become aware that we have collected personal information from a child under 16, we will take steps to delete such information promptly.
12. California Privacy Rights
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):
Right to Know:
- Categories of personal information collected
- Categories of sources of personal information
- Business or commercial purposes for collection
- Categories of third parties with whom information is shared
Right to Delete: Request deletion of personal information we have collected about you.
Right to Opt-Out: Opt out of the sale or sharing of your personal information.
Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.
To exercise your California privacy rights, contact us at [email protected] or call our toll-free number: +90 530 110 29 78
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make changes, we will:
- Post the updated Privacy Policy on our website
- Update the “Last Updated” date
- Notify you of significant changes via email or through our Services
We encourage you to review this Privacy Policy periodically.
14. Contact Us
If you have questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us by sending us email, calling on phone, or coming directly to the office:
- Email: [email protected]
- Phone: +90 530 110 29 78
- Address: Gazi Mh. 1311 Sk. Nur Apt. No: 2B Yenişehir / Mersin, Türkiye
EU Representative:
- Email: [email protected]
- Phone: +34 637 93 83 59
Supervisory Authority:
If you are located in the EU, you also have the right to lodge a complaint with your local data protection authority. Our lead supervisory authority is the Spanish Data Protection Agency (Agencia Española de Protección de Datos – AEPD):