OA Cheddar Privacy Policy
Last updated: March 22, 2019

Introduction
Welcome to OA Cheddar! This Privacy Policy informs you about how your personal information is collected, used, secured and shared when you use the Services offered by the Company and the Website located at www.oacheddar.com (“Website,” or “Platform”). 

The Platform is owned and operated by OA Cheddar LLC, a company organized in accordance with the law of the State of Washington (hereinafter “Company,” “We,” “Us,” or “Our”). Any reference in this Privacy Policy to the “Subscriber,” “User,” “You” or “Your,” refers to you, the subscriber who registers to use the Platform and any reference to the Company, refer to OA Cheddar LLC. 

Please carefully read this Privacy Policy before using our Service. If you do not agree with our practices as outlined in this Policy, you should refrain from using our Service. By proceeding to use the Platform, you give us your express consent to the collection and use of your Personal Information as stated herein.

Definitions
Unless expressly specified otherwise, any reference to the following words shall have the meaning as defined below: 

Data Controller” - as defined in the General Data Protection Regulation “the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.” 

Personal Data” - as defined in the General Data Protection Regulation “Any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”. 

Processing” - as defined in the General Data Protection Regulation “Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction”.

Service” - refers to the subscription service as well as other software features and functionality made available by the Company through the Platform. 


INFORMATION WE COLLECT AND PROCESS
INFORMATION YOU PROVIDE US VOLUNTARILY 
There is some personal information that you voluntarily provide us when you use the Service. Some of the voluntarily submitted information is mandatory, and the rest is optional. Mandatory information is required for us to deliver our service to you. We will clearly inform you which elements of personal information are mandatory and which are optional. 

You currently provide us with personal information when you:

Subscribe on the Platform
When you select a plan and subscribe to the Service, we request you to provide us with your full name, your email address, your phone number, and your residential address.  

This information is used to: 
Create your subscriber account on the Platform; 
To enable us to deliver subscription emails to you; and
To enable us to deliver a thank you gift to your residential address.  

When you leave a public review
We love to receive feedback from our subscribers. When you leave a review for our Service, we will have access to the content of your review, and it will be publicly visible to all our Website visitors. Please do not share any personal information in public reviews that you do not wish to be visible to others on the Web. 

When you contact us
When you contact our Customer Support or send us an email, we collect your email address as well as the content of your message. We use this information to reply to your request and to contact you. 

INFORMATION WE COLLECT FROM YOUR USE OF OUR SERVICE
When you visit our Website, we automatically collect certain personal information about you such as the device you use to access our Website, your IP address, your geographical location, and other similar information. We use this information to understand our audience better and to improve our Website user experience.

OTHER REASONS FOR PROCESSING YOUR PERSONAL INFORMATION
In addition to the above, we may also process your personal information for our business analytics purposes. 

USERS WHO ARE RESIDENTS OF THE EUROPEAN UNION 
LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION
In compliance with the General Data Protection Regulation, our legal basis for processing your Personal Information depends on the purpose for which the personal information was collected. 

Subscription Information
Our legal basis for processing this personal information is the performance of our contract with you. 

When you leave a Service Review
Our legal basis for processing this information is our legitimate interest. 

Customer Support Correspondence
Our legal basis for processing this personal information is the performance of our contract and our legitimate interest. 
 
DATA RETENTION 
We will retain your personal information on our records for as long as we have a legitimate business purpose for retaining such personal information. 

Your Subscription Information
We will retain this information for as long as your account is active. We will not retain this personal information on our records for more than two years after the termination of your subscription. 

Customer Support Correspondence
We will retain your past communication with us for six months after the resolution of your query after that we will anonymize this information.

SHARING YOUR PERSONAL INFORMATION
We may share your personal information for the following purposes:  

Email distribution Tools
When you subscribe to our Service, we will use third-party email distribution tools to send emails to you, and your personal data is shared/stored on our selected email distribution tool. 

Third-Party Service Providers
From time to time we may employ other service providers to help us in facilitating our Service to you and to assist us with intelligent analysis of how our Users use our Service. These Third-Party Service Providers may gain access to your personal data in the course of performing these tasks on our behalf.

Compliance With the Laws
We reserve the right to disclose your Personal Information when required to do so for our compliance with any applicable laws and upon reasonable requests of any government bodies or regulatory authorities. 

To enforce our rights
We may share your personal information to enforce our contractual or other legal rights arising out of our Agreement with you.

Mergers and Acquisitions
In the event we undergo any merger or acquisition, we may share your personal data with the other entity. Please note, where we disclose your personal data with a new entity in the event of a merger or acquisition, you will retain substantially the same privacy rights as you have under this privacy policy.


Data Controller
The Company is the data controller for all personal data we collect from our Users. 


DO NOT TRACK
California Online Privacy Protection Act (“CalOPPA”) requires us to inform our Users how we respond to Do Not Track (“DNT”) signals. We currently do not respond to DNT signals. 


Cookies
We make use of cookies on our Website. 

What are cookies?
Cookies are small files with data that we use to identify you as a unique User. We do not associate any of your Personal Information with these unique identifier files. We send cookies to your browser from our website, and these cookies are stored on your computer’s hard drive. You can tell your browser to decline all cookies or to indicate when a cookie is being sent. If you decide to decline cookies from our Website, you may not be able to use some parts of our Service. We use cookies to improve your user experience on our Website. 

How long do cookies remain on my device?
We use session cookies as well as persistent cookies on our Website. Session cookies are immediately deleted from your hard drive after the end of your browser session. However, persistent cookies remain on your hard drive for a minimum period of time unless you clear them manually from your device. 

Don’t want to accept cookies? 
You can set your default browser setting to reject cookies from third-party websites. To learn more about cookies, please visit www.allaboutcookies.org. 

Security of your data
We do not collect or store any sensitive financial data about our Users on our database to reduce risks in the event of any data breach. 

We also take all reasonable steps to secure the personal data that we hold on our database using industry best practices; however, you acknowledge that any transmission of information over the internet carries some inherent risks of unauthorized access; therefore we are unable to offer any guarantees as to the security of your personal information. In the event of any security breach which impacts our users’ personal data, we will immediately take steps to notify you with all relevant details of the nature of breach and steps taken by us. 

Transfer of data
Our Website is hosted on servers that are located in the United States of America as well as other parts of the world where the local data protection laws may be different from those of your country of current residence. By accessing or in any way interacting with our Website from outside of United States, you give us your express consent to transfer and process your data in and outside the country of your current residence for the purposes outlined in this Privacy Policy and those that are compatible with the specified purposes. Whenever we transfer your personal information to another jurisdiction, we take all necessary steps to ensure that your data is adequately protected in such recipient location. 

YOUR PERSONAL INFORMATION RIGHTS
The General Data Protection Regulation grants data subjects more control over their personal data. Here are some of the rights that you can exercise:  
Your right to access your personal information
Your right to rectify your personal information 
Your right to be forgotten
Your right to withdraw your consent


Complaints
If you believe that we have infringed any of your privacy rights, we would appreciate it if you would contact us with your concern. 

If you are resident in the European Union, you have the right to file a complaint with your local data protection authority at https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. 


Links To Other Sites
Our Website may contain links to third-party websites that are not owned or operated by us. When you click on such links, you will be redirected to such third-party website. All third-party websites are governed by their own Privacy Policy. You are advised to always review the Privacy Policy of a third-party website before providing your personal information. The Company will not be held liable for any actions, losses or claims arising from your use of such third-party websites or their practices. Your decision to access any third-party website is entirely at your own risk.


Changes To This Privacy Policy
We reserve the right to modify and update this Privacy Policy at any time. When we make any changes in our privacy practices or this policy we will notify you of such changes by updating the last modified date on the top of this page. You are advised to review this Policy periodically. All changes will be effective from the date the updated Privacy Policy is posted on our website.


Protection of Children’s Privacy
Our Service is not targeted at persons under the age of 18 ("Children"). If you are aware that a child has provided his/her personal information to us, please contact us with the details of the incident, and we will take steps to remove such information from our database. 

Contact Us
If You have any questions about this Privacy Policy, please contact us at team@oacheddar.com. 
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