Cheetah Experiences Privacy Notice
Last updated: June 2, 2020
What is Cheetah Experiences?
The Cheetah Experiences product helps our customers deliver interactive experiences and campaigns that engage customers and collect first-party data and zero-party data. Cheetah Digital is a global provider of enterprise marketing technologies and solutions helping brands build long-lasting relationships with their valued customers.
What Does This Privacy Notice Cover?
This notice describes how Cheetah Experiences collects and uses personal data. This notice applies to our corporate customers as users of our platform, features, and related services around the world, unless covered by separate privacy notices, such as our Website Privacy Notice and Cookie Notice.
This notice specifically applies to:
- Experiences customers. Businesses that collect or receive personal data using Cheetah Experiences-powered forms, promotions, social media pages, or other interactive content via our platform.
- Consumers. Individuals who volunteer personal data to our corporate customers when visiting their websites or other digital properties, and interacting with their Experiences-powered content.
This privacy notice does not apply to other collections of personal data on an Experiences customer’s website or other digital properties.
What Data Do We Collect?
Cheetah Experiences collects:
- Business contact data provided by Experiences customers such as during account creation and provisioning
- Consumer data collected by Experiences customers using our tools and services
As a business and data controller
To provide access to the Experiences platform and enable our services we act as a data controller in relation to our customers. We collect and process the following types of personal data in a business-to-business context:
- Registration Information. As our customer, we collect personal information about you when you register to use our platform and services. The information you provide may include items such as your first and last name, company, business role, email address or mailing address.
- Contact Information. As our customer, we collect personal data about you when you provide contact information to us via email, mail, support system, or other contact forms related to the Experiences platform. This personal data typically includes your first and last name, company, business role, phone number, email address, or mailing address you provide through these forms.
- Financial Information. As our customer, with a commercial agreement in place with us (e.g. a subscription to the Experiences platform), we will also collect financial and transactional information, which, depending on the circumstance, will include business accounts, business contacts, business bank details, billing and mailing addresses, and other payment-related information.
Please note that we do not have a direct relationship with consumers and Experiences customers remain the owners and controllers of the personal data collected and used via our platform and services.
If you have questions regarding a customer’s collection and use of personal data, you should contact the customer with your requests or inquiries, or to exercise your privacy rights. We will provide our customers with reasonable assistance with respect to consumer privacy rights and complaints under applicable law.
As a service provider and data processor
When Experiences customers use our platform and services, and allow consumers to interact with the Experiences-powered content they create, we act as a data processor. Cheetah Experiences processes the following types of personal data on behalf of our customers in accordance with our services:
- Directly identifiable information (also known as personally identifiable information) such as name, email address, phone number, and postal address, which enable a variety of direct marketing and non-marketing communications
- De-identified website visitor and behavioral data (including mobile websites) collected via placement of cookie and cookie-like technology by Cheetah Digital or the Customer’s third-party analytics providers to measure the effectiveness of Experiences interactions
- Demographic and preference information such as gender, age, favorite store location, shopping and lifestyle interests, which are used for segmentation and personalization purposes
- Pseudonymous online identifiers such as IP address, Cookie ID, mobile device identifiers (Apple ID, Google Ad ID), and related technical data about the browser or device which helps bring together the various data points
- Other linked or linkable data which helps customers create personalized Experiences and to deliver optimized content when using Cheetah Digital’s other Customer Engagement Suite product offerings.
Special category (sensitive) personal data
European data protection laws define certain special categories of personal data (“special categories of personal data”), which are subject to heightened protections under such laws. These special categories of personal data include information relating to an individual’s physical or mental health, racial or ethnic origin, political opinions, trade union membership, religious beliefs, sexual life or genetic or biometric data.
We will not request, collect or process special categories of personal data in relation to the provision of the Experiences platform or related services.
Cookies and Similar Technologies
Where permitted by applicable law, Experiences collects personal data via cookies and similar technologies, including cookies and similar technologies operated by third parties. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to manage your authenticated session with the Experiences platform and to provide you with a more personal experience on Experiences.
We typically use the following types of cookies and similar technologies:
- Essential, such as those allowing access to secure areas of Experiences;
- Functional, such as to enable various features of the Experiences platform, including remembering preferences or staying logged in during a long session;
- Analytics, consistent with our legitimate interests in how the Experiences platform is used or performs, how customers engage with and navigate through the Experiences platform, what sites users visit before visiting Experiences, how often they visit Experiences, and other similar information; and
- Social media, such as with our Twitter and Facebook integrations so as to, for example, authenticate a social media feed to search for public posts that might relate to your company, brand or product, or when displaying such content within social walls, collages and similar visuals as part of our services.
Note, where permitted by applicable law, some of these technologies can be used by us and/or our third-party partners to identify consumers across platforms, devices, sites, and services.
Grounds for Processing
When providing customer access to the Experiences platform and delivering our services, Cheetah Digital relies on the following lawful grounds:
- Legitimate business interests. We may use personal data for our legitimate business interests to administer our platforms, ensure the integrity of our services, and to enforce our terms and acceptable use policies.
- Consent. To the extent Experiences customers need to collect and share, or allow us to facilitate collection and sharing of personal data to enable our services, it is the responsibility of customers to provide necessary privacy notices and obtain required consent(s).
How We Use the Information We Collect
We use personal data in the following ways:
- Providing the Experiences platform. We use personal data we collect as we believe necessary or appropriate to operate, maintain, administer and improve the Experiences platform; to communicate with our Customers regarding your account including by sending you Experiences platform announcements, technical notices, updates, security alerts, and support and administrative messages; to respond to your enquiries and otherwise deliver customer service; and to process payments made by you;
- Communicating with our Customers. Where permitted by applicable law, we use the personal data we collect to communicate directly with our corporate Customers and prospects, including by sending you product newsletters, promotions or information about new products and services from Cheetah Digital. For more information about our marketing efforts, please see our Website Privacy Notice.
- Improving the Experiences platform and Services. We use personal data we collect as we believe necessary or appropriate to analyze trends, administer or optimize the Experiences platform, monitor usage or traffic patterns (including to track users’ movements around the Experiences platform) and gather demographic information about our user base as a whole.
- Security and fraud prevention. We use personal data we collect as we believe necessary or appropriate to control unauthorized use or abuse of the Experiences platform and our other products and services, or otherwise detect, investigate or prevent activities that violate our policies; in connection with the monitoring and analysis of our IT systems to ensure the security of information, networks, and connected systems.
- Compliance. We use personal data we collect as we believe necessary or appropriate in connection with legal requirements, to protect against, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity and to protect our rights, privacy, safety or property, and/or that of you or others.
How We Share the Information We Collect
Information we collect will be shared with a variety of parties, depending upon the purpose for and context in which that information was provided. We generally transfer data to third parties as follows:
- Service providers. In connection with our general business operations, product/service improvements, to enable certain features, and in connection with our other legitimate business interests, we share your personal data with service providers who provide certain services or process data on our behalf. Service providers include customer relationship management providers, email providers, data storage and hosting providers, our accountants, accounting systems and legal representatives, analytics providers, and customer support system providers.
- Affiliates. In certain circumstances, we share your personal data with any of our current or future affiliated entities, subsidiaries, and parent companies in order to streamline certain business operations, improve personalization, and develop products and services that better meet the interests and needs of our customers, and provide you with information we believe will be of interest to you.
- Social media. If you make any public social media post that includes hashtags or usernames related to Cheetah Digital, or otherwise interact with the Experiences platform via public social media, we may make your public post available via the Experiences platform or to the general public in a social visualization. Social media providers include Facebook, Twitter, Instagram, Snap, Youtube and Vimeo.
- Corporate events. Your personal data will be processed in the event that we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, it is possible that personal data will be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.
Aggregated, De-Identified or Anonymized Information
In certain circumstances, we will also share aggregated, de-identified or anonymized information with third parties for other purposes (e.g. to compare the performance of two promotions with a customer, to provide benchmark metrics to customers or to provide performance metrics on our website). Such information does not identify you individually, but includes anonymized usage, viewing and similar technical information such as the features of Experiences our customers and users generally use, common configurations of their computers, and performance metrics related to the use of the Experiences platform which we collect through our technology. If we are required under applicable law to treat such information as personal data, then we will only use and disclose it as described earlier in this privacy statement.
Other Access To or Disclosure of Personal Data
The Experiences platform contains features that enable consumers to post reviews, provide quotes, make comments or provide other content that is publicly viewable. You should be aware that any personal data you submit as part of such posts can be read, collected, or used by other users. We are not responsible for the personal data you choose to post publicly via the Experiences platform.
Access and Privacy Rights
Cheetah Experiences provides individuals with a variety of ways to learn about, control, and submit questions and comments about our handling of Experiences customer or consumer personal data. Specific to our platform and services, we provide Experiences customers in-platform capabilities and managed support with various privacy rights in the following ways:
- Access, correction, and erasure of personal data. As registered users of the Experiences platform, you can sign in to their account, go to your profile, and make the desired changes. (Please note that if you cease using the Experiences platform or we terminate your access to the Experiences platform in accordance with our commercial agreement, you will no longer have the ability to access or update your information through the Experiences platform.) Otherwise, please contact email@example.com with your request.
- Promotional communication preferences. If you no longer wish to receive newsletters and promotional communications, you may opt-out of receiving them by following the instructions included on such communications, within the Experiences platform, or as provided through our Website Privacy Notice. Please note, however, that you will be unable to opt-out of certain service-related communications and notifications.
- Other opt-outs. We will provide you with the opportunity to “opt-out” of having your personal data used for certain purposes when we ask for this information. If you decide to opt-out, we may not be able to provide certain features of the Experiences platform to you if these are legally dependent on your consent.
- Do Not Track signals. Your Web browser may have a “do not track” setting which, when enabled, causes your browser to send a do not track HTTP header file or “signal” to each site you visit. At present, the Experiences platform does not respond to this type of signal.
- Do Not Sell My Personal Information (California). Cheetah Digital is not in the business of buying or selling consumer personal data.
- Contact Regulator. If you would like to submit a complaint about our use of your personal data or response to your requests regarding your personal data, you may contact us at firstname.lastname@example.org or submit a complaint to the data protection regulator in the jurisdiction where you live or work. For example, you can find your European data protection regulator here.
Please note that, to the extent permitted by applicable law, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort (for instance, requests concerning information residing on backup tapes), jeopardize the privacy of others, would be extremely impractical, or for which access is not otherwise required.
The Experiences platform is not intended for use by children and we do not knowingly collect or solicit personal data from children. In the US, for data protection purposes, a child is anyone under the age of 13. In the EU, a child is anyone under the age of 16.
If you are a child, you may not attempt to register for the Experiences platform or send any information about yourself to us, this includes name, email address or phone number. In the event that we confirm that we have collected personal data from children without verification of parental consent, we will delete that information promptly. If you are a parent or legal guardian of a child and believe that we might have any information from or about such child, please contact us at email@example.com.
Data Security and Retention
The security of your information is important to us. Your information is maintained in a secure environment and we take appropriate steps to protect against loss, misuse and unauthorized access, alteration, disclosure, or destruction of your data in our care. We employ strict controls around employee access to the personal data in our care based on business need and use cases which warrant access.
We take commercially reasonable steps to ensure the ongoing confidentiality, integrity, availability and resilience of our systems and services processing your personal information. In the event of a physical or technical incident, we will restore the availability and access to information in a timely manner. If you have questions about the security of your personal data, please contact us as described below.
We will retain the personal data provided to us by our Customers or that we collect on behalf of our Customers for the length of time needed to fulfill our Services as discussed in this Privacy Notice. This is usually for the life of our commercial agreement with you unless a shorter retention period is requested.
International Data Transfers
We maintain facilities and offices around the world, including in the United States, the European Union, and Japan among other locations. Your personal data may be transferred to, stored, or processed outside of your country or the country in which you were located when you initially volunteered the information.
As a global marketing technology and services provider working on behalf of our international Customers, we take many steps to protect the personal data in our care, including offering contractual assurances to this effect. Should the relationship with one of our group companies, Customers or partners involve cross-border data flows outside the European Economic Area, we shall formally undertake to comply with the highest data protection standards, notably by adhering to the Standard Contractual Clauses adopted by the European Commission and related requirements under EU data protection and privacy laws. (SCCs are encoded into our Data Processing Addendum.)
Changes to This Privacy Notice
This privacy statement is a notice to you and not a contract between us. We reserve the right to change our privacy statement at any time. If we make changes, we will post them and will indicate on this page the statement’s new effective date. If we make material changes to this statement, we will notify you by email or through notice on within the Experiences platform.
Cheetah Digital Head Office
72 W Adams St,
Chicago, IL 60603
Or contact us using this online form
If you wish to escalate your inquiry after contacting the privacy team, you are welcome to contact our Data Protection Officer, ePrivacy GmbH, at firstname.lastname@example.org.
Represented by: Prof. Dr. Christoph Bauer
Große Bleichen 21