Privacy Policy

Last updated on 19 August, 2021

Welcome to the Privacy Policy («Policy») of *Cheery. The privacy of our website visitors is very important to us, and we are committed to safeguarding it. This policy explains what we will do with your personal information in accordance with the EU Regulation 2016/679 (‘GDPR’), local legislation applicable to us and where applicable relevant California State implementing legislation and Brazilian related General Data Protection Law.

*Cheery («our Website») is owned and operated by ADME (CY) LTD, , a company having its registered seat in 62 Agiou Athanasiou at 62 Agiou Athanasiou Avenue, BG Waywin Plaza, Office 101, Limassol, Cyprus, which for the purposes of this Policy shall be the data controller («we», «us», or «our»). We have designated a contact person responsible for compliance and implementation of this Policy and related personal data rights and may be contacted as described in the ‘Contact Us’ section hereinbelow.

1. Types of Personal Information That Might Be Collected

When you visit our Website, the following types of data about you may be collected:

your IP address;
your operating system and browser software used to access our Website;
other information, as will be explained in Section 4 (With Whom We Share Information) below;
and
in the event you contact us by email, we may keep a record of that correspondence; such record may include, apart from your email address, the data that you will include in the communication.

Such data are collected by Our Partners (as such term is explained in Section 4).

If you wish to register on our Website in order to receive our subscription-based services, we will ask you to provide the following data:

your email address;
your gender;
and
your date of birth.

In addition, when subscribing for any of the services offered on our Website you will be requested to identify your display name and choose your profile image which may be an avatar or a photo. The display name is what will be displayed next to your comments on our Website. We strongly encourage you not to use your real-life name and/or surname as your display name.

We never share with third parties any of the data supplied by you as part of subscription-based services/registration.

For the purposes of this Policy, the collected data mentioned in this Section, shall be defined as ‘Personally Identifiable Information’.

2. Ways Personal Information Might Be Used

Use of Personal Data by Us. We collect and use your Personally Identifiable Information for the purposes of the following legitimate business interests pursued by our data controller company and the group of companies to which it belongs:

to carry out general data analysis and to administer our Website and affiliated sites;
to generate statistics and measure web traffic and popularity of specific areas of our Website;
to identify usage trends and expand our business activities;
to build higher quality and develop more useful services by performing statistical analyses of the collective characteristics and behavior of our users
to improve or modify our Website, develop new services and functionality;
to comply with applicable legal requirements, legal process and relevant industry standards, and satisfy requests by governmental and supervisory authorities;
and
to identify and prevent fraud.

Additionally, if you choose to register on our Website in order to receive our subscription-based services, your Personally Identifiable Information will be used in order to communicate with you.

Under such circumstances, the legal basis for providing this service to you would be your express consent. You may withdraw your consent at any time and detailed unsubscribe instructions will be displayed at the bottom of each email. Withdrawal of your consent will not affect the legality of our data processing for the time before the consent was withdrawn.

Use of Personal Data by Our Partners. Our Partners (as such term is explained in Section 4, With Whom We Share Information) may be collecting and using your Personally Identifiable Information to tailor the content that advertisers display to you, including building relevant data segments based on what you click and view and when or how many times you have viewed it; for these purposes, they use the information collected by technologies, such as pixel tags or cookies, to improve the services provided by third-party advertising companies, which include Google. The list of Google partners can be viewed at partners.

LiveRamp
We make use of LiveRamp a data connectivity platform to leverage complete customer data for analytics, targeting, and content personalization in an effective and safe way.
When you use our website, we share information that we collect from you, such as your email (in hashed form), IP address or information about your browser or operating system, with LiveRamp as our identity partner / service provider. This partner of ours returns an online identification code that we may store in our first-party cooke for our use in online, in-app and cross-channel advertising and it may be shared with advertising companies to enable interest-based and targeted advertising. To opt out of this use by LiveRamp, please click here.

3. What You Agree to by Using Our Website

We will ask for your consent and agreement that we may collect and use your Personally Identifiable Information in accordance with this Privacy Policy, and as permitted or required by applicable law. You are free to refuse to give consent or to withdraw the consent that you had given. Please note, however, that if you refuse or withdraw your consent some of the features available on our Website may not be available to you. Please note that we may also rely on legitimate interests or fulfillment of a contract to continue processing your Personally Identifiable Information. Consent can be withdrawn at any time by sending your request to privacy@thesoul-publishing.com. You also may contact us by sending a letter or request to General Counsel ADME (CY) LTD 62 Agiou Athanasiou Avenue, BG WAYWIN PLAZA, ofﬁce 101 Limassol 4102, Cyprus.

Please understand that, if you decide to register on our Website in order to receive our subscription-based services, by submitting any Personally Identifiable Information to us, you are giving consent and agreeing that we may collect and use all Personally Identifiable Information that you submit in accordance with this Privacy Policy and as permitted or required by law. If you do not agree with these terms, please do not provide any Personally Identifiable Information to us.

Before using Personally Identifiable Information for a purpose other than any of the purposes set out in the preceding Section 2 (Ways Personal Information Might Be Used) we will request your explicit consent.

4. With Whom We Share Information

Except as set forth in this Policy or as explicitly agreed by you, we will not disclose any of your Personally Identifiable Information. In addition to the other uses set forth in this Policy, we may disclose and otherwise use Personally Identifiable Information as described below.

Our Partners. We allow third parties, including carefully selected ad networks and business partners (referred to as «Our Partners»), to display advertising on our Website. Our Partners may, for instance, collect, use and share your information to make or help us make predictions about your interests, and may provide you with offers, promotional materials, and advertisements. In addition, Our Partners may be collecting certain information either by you or from your device. Our Website permits Our Partners to collect your Personally Identifiable Information to provide personalized advertising to you. Our Partners are leading digital performance-based advertising groups which put great effort in making sure that your personal information is safe and used properly.

Service Providers. Your information may be collected by entities that provide services to us, including companies that deliver web analytics, data processing, data enhancement and customer insights, advertising, email distribution, and other services.

Other Parties (when required by law or as necessary to protect our services). We may disclose your information (including Personally Identifiable Information) to other parties in order to:

protect our legal rights or property, the legal rights or property of our affiliates, and sites or services we work with;
protect the rights, safety and security of our users, ourselves, or any other person or entity;
prevent fraud (or for risk management purposes);
or
comply with applicable legal requirements, legal process or request for cooperation by a governmental or supervisory authority, whether or not legally required. For example, we may be required to disclose your information to meet national security or law enforcement requirements.

Other Parties (in connection with transfer of assets). If we make a sale or transfer of assets, or are otherwise involved in a merger or transfer (or due diligence related to such a transaction), or in the unlikely event of bankruptcy, we may transfer your Personally Identifiable Information as part of that transaction.

Use for Analytical and Ad Serving Purposes. We use standard tools common within the industry, including but not limited to Google Analytics, to collect information about use of our Website. These tools collect information such as how often you visit our Website and what other sites you visited prior to reaching our Website. We use the information we obtain from analytical tools for the purposes of improving our Website. The analytical tools collect only the IP address assigned to your computer or other device and your browser settings as of the moment you visit our Website, rather than your name or other identifying information.

We also use standard tools common within the industry, such as DoubleClick for Publishers operated by Google, enabling placement and management of personalized advertising services on our Website. These tools use cookies to target advertising based on what is relevant to you as a user to improve advertising and to avoid showing ads that you have already seen. Cookies themselves contain no Personally Identifiable Information. They relate to your web activity, rather than your identity. Tools such as DoubleClick will send a cookie to your web browser after any impression, click, or other activity by you on our servers. If your web browser accepts the cookie, the cookie will be planted on your web browser. DoubleClick will usually send a cookie to your web browser when you visit any webpage displaying DoubleClick ads. Webpages containing DoubleClick ads include ad tags that instruct web browsers to request ad content from our servers. When the server delivers the ad content, it will also send a cookie.

Finally, our Website relies on common industry tools Google Display Network Impression Reporting and Google Analytics Demographics and Interest Reporting. These tools help us understand the composition of viewers of our Website in terms of gender, age and interests. We need this information in order to understand what types of creative content we need to develop to suit the interests of different demographic and interest groups. In addition, Our Partners may need this information to develop marketing content. You may, at any time, opt out of Google Analytics tracking, including Google Display Network Impression Reporting and Google Analytics Demographics and Interest Reporting, by installing the Google Analytics Opt-Out Browser Add-On. You may also opt out of ad serving through Google’s opt-out page.

The personal data privacy aspects of all Google products, services and features, including Google Analytics and DoubleClick, are covered by Google Privacy Policy. Please be assured that we never combine the information collected through the use of Google Analytics or DoubleClick with any other Personally Identifiable Information. Moreover, permanent cookies planted on your web browser by Google products to identify you as a unique user the next time you visit our Website, cannot be used by anyone but Google. The ability of Google to use and share information collected by Google Analytics or DoubleClick about your visits to our Website is restricted by DoubleClick Terms and Conditions, Google Analytics Terms of Use and Google Privacy Policy.

You can opt out of ads personalization using Google’s Ads Settings by following the instructions contained on the following resource of Google — Google Ads Settings. If you choose to opt out of ads personalization, you will no longer receive personalized advertising.

The above mentioned policies are issued and updated by the respective developers and should be considered by our Website users independently.

5. Cross-Border Transfer of Information

We generally maintain centralized servers and systems in Europe and may maintain servers and systems elsewhere. These servers and systems are managed by us or on our behalf, or by our affiliates located in Europe.

In the event of transfer and processing of your Personally Identifiable Information outside the EEA for the purposes described above, we will ascertain that the information receives the same level of protection as if it remained within the EEA, including when entering into data transfer agreements, using the EU Commission approved Standard Contractual Clauses, or by relying on certification schemes such as the EU-US Privacy Shield.

6. How We Keep Your Information Secure

We use commercially reasonable physical, electronic, and procedural safeguards to protect your Personally Identifiable Information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction in accordance with requirements of applicable laws.

7. Use of ‘Cookies’

We also use (or may use) ‘cookies’ when you visit our Website. For more information on our use of cookies, please refer to our Cookie Policy.

8. Use of Information for Personal Advertising

The information collected by Our Partners is used to analyze trends, understand user activities and gather demographic information to enable, manage and develop their personalized ads and related services. Our Partners may share such information with their affiliates. To do this, Our Partners use technologies such as cookies and web beacons to collect information about your interaction with our Website and third-party websites. This type of information does not identify you personally and, typically, is aggregated with other data to create segments —groups of users and general interest categories that are inferred based on a range of factors (for example, «sports fan»). Our Partners use this information to form a more accurate picture of the interests of the audiences with which they interact — including you — so that their ads are more relevant to those interests.

In addition, Our Partners may use the information collected from these types of cookie or similar technologies for a variety of other purposes, including:

in conjunction with advertising that appears on other third-party websites;
to measure the effectiveness of web-based and email advertisements;
and
for reporting website traffic, statistics, advertisement data and other interaction with ads and the websites on which they are served.

Our Partners retain your information in accordance with their legitimate business purposes for processing. Thereafter, the information is removed, archived for restricted legitimate interests, or anonymized. Non-identifying information may be kept without time and use limitations.

9. Retention of Personal Information

If you reside or are located in the EEA, your Personally Identifiable Information will be stored for no longer than necessary for the purpose for which the Personally Identifiable Information was collected. The length of time Personally Identifiable Information is retained depends on the purpose for which such information was collected and/or as required to comply with applicable laws and establish, exercise or defend our legal rights.

10. Your Legal Rights

You have certain rights in relation to your Personally Identifiable Information. Depending on the jurisdiction, you have the right to request that we:

provide access to any Personally Identifiable Information we, or Our Partners, hold about you;
update any Personally Identifiable Information which is out of date or incorrect;
delete any Personally Identifiable Information which we, or Our Partners, are holding about you, or withdraw your consent, where applicable;
object to certain means of processing of Personally Identifiable Information (e.g., opt-out from marketing communications);
restrict the way in which we process your Personally Identifiable Information;
provide your Personally Identifiable Information to a third-party service provider;
or
provide you with a copy of any Personally Identifiable Information which we hold about you.

The above requests shall be processed by us within reasonable time and unless provided otherwise from the local applicable law, within one month from the submitted written request. This period of time may be extended under certain circumstances by further two months.

You will not have to bear any cost to exercise any of your rights. We may though charge a reasonable fee should your requests be clearly unfounded or excessive. due to their repetitive character, or refuse to comply with such requests

Where applicable, we may request specific information to assist us confirm your identity and ensure your capacity to enforce your rights. This is part of our security measures to certify that your Personally Identifiable Information is not disclosed to any person who has no right to receive it.

11. Children’s Privacy

No part of our Website is directed to children or minors under the age of 18, and we do not knowingly collect Personally Identifiable Information from anyone that we know is under 18 years of age. If you are under 16 years of age (unless a lower age threshold between 13 and 16 applies in your country), then please do not use or access this Website, or ask your parents for permission before using our Website or sending any information about yourself to anyone over the Internet. We will take appropriate steps to delete any Personally Identifiable Information of persons less than 13 years of age that has been collected on our Website without verifiable parental consent upon learning of the existence of such Personally Identifiable Information.

12. Your Brazilian Privacy Rights

If you are a Brazilian citizen or Brazilian resident under the Brazilian General Data Protection Law (n. 13.709/18) you have a series of rights related to your Personally Identifiable Information. We are committed to fulfilling these rights and, in this Section, we will explain what these rights are and how you can exercise them:

1. Confirmation of the existence of processing: You can request our confirmation regarding the existence or non-existence of activities to process your Personally Identifiable Information.
2.Access to your personal data: You may request and receive a copy of your Personally Identifiable Information that we hold about you.
3. Correction of your personal data: You can request correction and/or rectification of your Personally Identifiable Information if you identify that some of them are incorrect. However, for this correction to take effect, we may need to check the validity of the Data you will provide us.
4. Deletion of your personal data: You can request the removal of your Personally Identifiable Information from the databases we use to process them. All data collected will be removed from our servers when you request it or when it is no longer necessary or relevant for us to offer our services, unless there is any other reason for its maintenance, such as any legal obligation to retain data or need of preservation of these to protect the rights of the company.
5.Objection to the processing of personal data: You may object to our handling of your Personally Identifiable Information for certain purposes. In certain situations, we can demonstrate that we have legitimate reasons to treat your data, which may eventually override your rights, if, for example, they are strictly essential for the functionality of a certain aspect of the Website.
6. Portability of your personal data: You may request that you (or any third party you choose and authorise) be provided directly with your Personally Identifiable Information in a structured and interoperable format.
7.Consent withdrawal: In cases where you have provided your consent for us to carry out specific processing activities with your Personally Identifiable Information, you can withdraw your consent. This will not affect the legality of any activity carried out prior to your consent withdrawal. In addition, if you withdraw your consent, we may not be able to provide certain products, services, benefits or advantages. If this happens, we will provide you with specific information to help you make your decision.
8. Review of Automated Decisions: You may request a review of decisions made solely on the basis of the automated processing of your Personally Identifiable Information that affects your interests.

If you wish to delete any of the personal information we collect and retain about you, please contact us by sending a written request to the following address: General Counsel, ADME (CY) LTD, 62 Agiou Athanasiou Avenue, BG WAYWIN PLAZA, office 101, Limassol 4102, Cyprus. We will verify your request using the information associated with your account, including your email address. Official personal identification may be required.

If you would like to disable the use of your personal information for the purposes listed above, you may do so by contacting us at legalops@thesoul-publishing.com.

If you would like more information about disclosing personal information to third parties for marketing purposes, please email legalops@thesoul-publishing.com or write to: ADME (CY) LTD, General Counsel, 62 Avenue Agiou Athanasiou, BG WAYWIN PLAZA, Office 101, Limassol 4102, Cyprus.

13. Your California Privacy Rights

Under the California Consumer Privacy Act of 2018 (CCPA), California residents are entitled to request to know more details about the categories or specific pieces of personal information we collect, use, disclose and “sell” (under CCPA “sale” is broadly defined and it may include allowing third parties access to information like cookies, IP address, geolocation - which all allow us to personalize your Website and mobile application experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website and mobile applications), to delete their personal information, to opt-out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

In the past 12 month we collected, disclosed and “sold” the following personal information to our business partners for the purposes described below:

What type of the personal information	Collected	How do we get the personal information	We may use, disclose and “sell” the personal information	To whom
A. Identifiers, including cookies, IP address, email address, account name	Yes	From you and your device	To process your requests for products/services and/or information, to communicate with you, to improve our Services, for the administration and protection of our business, and to comply with applicable law, regulations, and legal and regulatory processes.	Service providers, our business partners.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	No
C. Protected classification characteristics under California or federal law.	No
D. Commercial information.	No
E. Biometric information	No
F. Internet or other similar network activity.	Yes	From your device	To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites	Service providers, our business partners.
G. Geolocation data.	Yes	From your device	To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites	Service providers, our business partners.
H. Sensory data.	No
I. Professional or employment-related information	No
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	No
K. Inferences drawn from other personal information.	Yes	From you and your device	To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites	Service providers, our business partners.
Other Identifiers and Internet Activity Information	Yes	From you and your device	To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites	Service providers, our business partners.

If you are California resident you can submit your request for access or deletion of any of your personal information that we collected from you and retained, subject to certain exceptions, via this form, or by submitting a written request to the following address: General Counsel, ADME (CY) LTD, 62 Agiou Athanasiou Avenue, BG WAYWIN PLAZA, office 101, Limassol 4102, Cyprus. We will verify your request using the information associated with your account, including email address. Government identification may be required. You can also designate an authorized agent to exercise these rights on your behalf. You may only make a verifiable consumer request for access or deletion twice within a 12-month period.

You may also request to opt-out from the “sale” of your personal data. CCPA broadly defines “sale” and it may include allowing third parties access to information like cookies, IP address, geolocation - which all allow us to personalize your Website and mobile application experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website and mobile applications.

If you would like to opt-out of our use of your personal information for such purposes, you may do so by contacting us at privacy@thesoul-publishing.com. You have the right not to be discriminated against for exercising any of your CCPA rights.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website 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 privacy@thesoul-publishing.com or write us at: ADME (CY) LTD, General Counsel, 62 Agiou Athanasiou Avenue, BG WAYWIN PLAZA, ofﬁce 101, Limassol 4102, Cyprus.

14. Automated decision making, including profiling

Automated decisions within the meaning of applicable law mean that a decision having a legal effect on you or significantly affects you in a similar way is automatically made - including profiling - without verifications by a natural person. We do not use automated decisions.

15. Questions, Suggestions and Complaints

If you have any privacy-related questions, suggestions, unresolved problems, or complaints you may contact us at privacy@thesoul-publishing.com.

If you reside or are located within the EEA, we may assist with all queries regarding our processing of Personally Identifiable Information. We request that you please attempt to resolve any issues related to your Personally Identifiable Information with us first. If you reside or are located within the EEA, you may also make a complaint to the supervisory authority for data protection in your country of residence, place of work, or place of the alleged infringement of your Personally Identifiable Information or seek a remedy through local courts if you believe that your rights have been breached. More information about how to contact the supervisory authorities across the EEA, can be found in the European Data Protection Board’s website here (https://edpb.europa.eu/about-edpb/about-edpb/members_en).

If you reside or are located outside the EEA, you may contact your local supervisory authority for further information and guidance.

16. External Links

Our Website may display links to websites of third-party content providers, other than Our Partners. We do not disclose your Personally Identifiable Information to third parties, other than Our Partners, without obtaining your consent specifically permitting such disclosure. We do not endorse and are not responsible for the privacy practices and content of such third parties. We encourage you to review their privacy policies to understand how they collect and process your Personally Identifiable Information.

17. Changes to This Policy

We revise and evaluate this Policy periodically in light of changing business practices, technology and legal requirements. As a result, this Policy will be updated from time to time. Any such changes will be posted on this page. Any change, update, or modification will be effective immediately upon posting on our Website.

18. Contact Us

If you have any questions or concerns regarding this Policy, our privacy practices, or to exercise your rights, please contact us by email at privacy@thesoul-publishing.com. You also may contact us by sending a letter or request to:

General Counsel
ADME (CY) LTD
62 Agiou Athanasiou Avenue, BG WAYWIN PLAZA, office 101
Limassol 4102, Cyprus