Privacy Policy

Last Updated: June 1, 2018

We are concerned about your privacy and want you to be familiar with how we collect, use and share your information. This Privacy Policy outlines the type of information that we collect and receive from you while you are using our Services. Additionally, this Privacy Policy identifies the ways in which we process, and sometimes share, such information and what control and choices you have with regard to the collection and use of your personal information. Please review this Privacy Policy carefully, especially before providing any personal information through the Chepelos Platform. If you do not wish to have us collect, use and share information as described in this Privacy Policy, please do not use the Chepelos Platform and Features or our Services.

Chepelos Marketing Inc. (hereinafter referred to as “Chepelos”, “we”, “us” or “our”) operates a platform and community marketplace that helps people form offline experiences and relationships directly with one another, where they can create, list, discover and try unique business services and goods around the world, whether through our website or our mobile applications (“Platform”).

This Privacy Policy is intended to inform you about how we treat Personal Information that we process about you. If you do not agree to any part of this Privacy Policy, then we cannot provide the Platform or Services to you, and you should stop accessing the Platform and close your Chepelos Account. You can find out more about how to close your Chepelos Account at Help Center.

1. WHAT TYPES OF INFORMATION DOES CHEPELOS GATHER ABOUT ITS USERS?
   
   What is « Personal Information »?
   Personal information is information about you that uniquely identifies you as an individual. Your name, address, e-mail address, or telephone number are all examples of personal information. However, the name, address and telephone number of an individual that appears in a telephone directory that is available to the public (where such individual can refuse to have such information appears in such directory) does not fall under the scope of personal information as it is publicly available information. Also, in some circumstances, some of this information may qualify as business information which is not covered by this Statement.
   
   
   • Information that you give us
     We receive, store and process information, including Personal Information, that you make available to us when accessing or using our Platform and Services. Examples include when you:
     • fill in any form on the Platform, such as when you register or update the details of your user account, or when you supply ID and other verification information;
     • access or use the Platform, such as to search for or post Business, refer or try Business Goods and Services, pay for Referrals, refer or try for any associated services that may be available, post comments or reviews, or communicate with other users;
     • link your account on a Third-Party site (e.g. Facebook) to your Chepelos Account, in which case we will obtain the Personal Information that you have provided to the Third-Party site, to the extent allowed by your settings with the Third-Party site and authorized by you;
     • communicate with Chepelos;
     • and share information with another registered member of Chepelos (“Member”).
   • Information we get from your use of our Platform
     We also receive, store and process information, possibly including Personal Information, when you access or use our Platform and Services, including but not limited to:
     • Mobile Data
       When you use certain features of the Platform, in particular our mobile applications we may receive, store and process different types of information about your location, including general information (e.g. IP address, postal code code) and more specific information (e.g. GPS-based functionality on mobile devices used to access the Platform or specific features of the platform). If you access the Platform through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.
     • Log Data
       We may also receive, store and process Log Data, which is information that is automatically recorded by our servers whenever you access or use the Platform, regardless of whether you are registered with Chepelos or logged in to your Chepelos Account, such as your IP Address, the date and time you access or use the Platform, the hardware and software you are using, referring and exit pages and URLs, the number of clicks, device event information, pages viewed and the order of those pages, and the amount of time spent on particular pages.
     • Cookies and other Tracking Technologies
       Chepelos uses cookies and other similar technologies, such as mobile application and other device identifiers, on the Platform. We may also allow our business partners to use their cookies and other tracking technologies on the Platform. As a result, when you access or use the Platform, you will provide or make available certain information to us and to our business partners.
       
       While you may disable the usage of cookies through your browser settings, we do not change our practices in response to a “Do Not Track” signal in the HTTP header from your browser or mobile application. We track your activities if you click on advertisements for Chepelos services on Third-Party platforms such as search engines and social networks, and may use analytics to track what you do in response to those advertisements.
       
       We may, either directly or through Third Parties we engage to provide services to us, also continue to track your behavior on our own Platform for purposes of our own customer support, analytics, research, product development, fraud prevention, risk assessment, regulatory compliance, investigation, as well as to enable you to use and access the Platform and pay for your activities on the Platform. We may also, either directly or through Third-Parties we engage to provide services to us, track your behavior on our own Platform to market and advertise our services to you on the Platform and Third-Party websites. Third Parties that use cookies and other tracking technologies to deliver targeted advertisements on our Platform and/or Third-Party websites may offer you a way to prevent such targeted advertisements by opting-out at the websites of industry groups such as the Network Advertising Initiative and/or the Digital Advertising Alliance. You may also be able to control advertising cookies provided by publishers, for example Google’s Ad Preference Manager. Please note that even if you choose to opt-out of receiving targeted advertising, you may still receive advertising on or about the Platform – it just will not be tailored to your interests. In addition, if you disable cookies, you may lose some of the features and functionality of using our Platform, Application and Services, as cookies are necessary to track and enhance your use and access.
       
       Third Parties may not collect information about users’ online activities on the Platform except as described in this policy and our Cookie Policy.
     • Third-Party social plugins
       Our Platform may use social plugins which are provided and operated by Third-Parties, such as Facebook’s Like Button.
       
       As a result of this, you may send to the Third-Party the information that you are viewing on a certain part of our Platform. If you are not logged into your account with the Third-Party, then the Third Party may not know your identity. If you are logged into your account with the Third Party, then the Third Party may be able to link information about your visit to our Platform to your account with them. Similarly, your interactions with the social plugin may be recorded by the Third Party.
       
       Please refer to the Third Party’s privacy policy to find out more about its data practices, such as what data is collected about you and how the Third Party uses such data.
2. HOW CHEPELOS USES AND PROCESSES THE INFORMATION THAT YOU PROVIDE OR MAKE AVAILABLE

    

   • We use, store and process information about you for the following general purposes:
     • to enable you to access and use the Platform;
     • to enable you to communicate with other Members, including but not limited to by sending them messages or other information during referral process;
     • to operate, protect, improve and optimize the Platform, Chepelos’s business, and our users’ experience, such as to perform analytics, conduct research, personalize or otherwise customize your experience, and to provide customer service;
     • to help create and maintain a trusted and safer environment on the Platform and Services, such as detection and prevention of actual and potential fraud and other harmful activity, conducting investigations and risk assessments, enforcing our Terms and policies, verifying the address of your listings, verifying any identifications provided by you (including by comparing the photo on that identification to another photo you provide to us), and conducting checks against databases and information sources (such as but not limited to public government databases) for fraud detection and prevention, risk assessment and harm prevention purposes. In this regard, we may do any or all of the foregoing with or without further notifying you;
     • to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
     • to send you marketing, advertising, and promotional messages and other information that may be of interest to you, including information about Chepelos, our services, or general promotions for partner campaigns and services. You can unsubscribe or opt-out from receiving these communications in your settings (in the “Account” section) when you login to your Chepelos Account;
     • to administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Chepelos or our Third Party business partners; and
     • to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with Third Parties.
   • How CHEPELOS Uses and Processes User Communications
     We may, either directly or through Third-Parties we engage to provide services to us, review, scan, or analyze your communications with other users exchanged via the Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research and customer support purposes. For example, as part of our fraud prevention efforts, the Platform may scan and analyze messages to mask contact information and references to other websites. We may also scan, review or analyze messages for research and product development purposes to help make search, Referrals and user communications more efficient and effective, as well as to debug, improve and expand product offerings. We will not review, scan, or analyze your communications for sending Third-Party marketing messages to you. We will also not sell these reviews or analyses of communications to Third Parties. We will also use automated methods to carry out these reviews or analyses where reasonably possible. However, from time to time we may have to manually review some communications. By using the Platform, you consent that Chepelos, in its sole discretion, may, either directly or through Third-Parties we engage to provide services to us, review, scan, analyze, and store your communications, whether done manually or through automated means.
3. WHEN CHEPELOS DISCLOSES OR SHARES YOUR PERSONAL INFORMATION, AND TO WHOM
   
   IMPORTANT: When you use the Platform, your data may be sent to Canada and possibly other countries.
   
   We may transfer, store, use and process your information, including any Personal Information, to countries outside of Canada. Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your information is transferred to or stored, used or processed in, may be different from the privacy laws applicable to the place where you are resident.
   
   Your Personal Information may be disclosed as follows:
    
   • Parts of your public profile page that contain some Personal Information may be displayed in other parts of the Platform to other users for marketing purposes or if you post content in a community forum or other features on the Platform that are visible to the general public.
   • Your public Listing page will always include some minimum information such as the city and neighborhood where the Business is located, your listing description, your public profile photo, your responsiveness in replying to Customers’ queries, and any additional information you share with other Members. Your public Listing page may also include aggregated demand information (such as number of page views over a period of time). Parts of your public Listing page may be displayed in other parts of the Platform to other Members and/or Third Party platforms for marketing purposes. The Platform may also display the Business approximate geographic location on a map, such that a user can see the general area of the Businesses.
   • When you accept a referral from another Member or your referral to another Member is accepted, your full name becomes visible to that Business.
   • When a Customer used your Business or when you used a Service or Goods from a Business, we may ask you to review the Customer, Business, or Goods and Services. If you choose to provide a review, your review may be public on the Platform. Likewise, another Member’s review of you as a Customer or Business may be public on the Platform.
   • You may link your account on a Third-Party social networking site to your Chepelos Account. We refer to a person’s contacts on these Third-Party sites as “Friends”. When you create this linkage:
     • some of the information you provide to us from the linking of your accounts may be published on your Chepelos Account profile;
     • your activities on the Platform may be displayed to your Friends on the Platform and/or that Third-Party site;
     • a link to your public profile on that Third-party social networking site may be included in your Chepelos public profile;
     • other Chepelos users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;
     • the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes; and
     • the publication and display of information that you provide to Chepelos through this linkage is subject to your settings and authorizations on the Platform and the Third-Party site.
   • We may distribute parts of the Platform (including your Listing) for display on sites operated by Chepelos’s business partners and affiliates, using technologies such as HTML widgets. If and when your Listings are displayed on a partner’s site, information from your public profile page may also be displayed.
   • Chepelos may provide your Personal Information to its Affiliates, and their employees, to use and process your Personal Information in the same way and to the same extent that we are permitted to under this Privacy Policy. These related entities comply with the same obligations that we have to protect your Personal Information under this Privacy Policy. Chepelos may share your Personal Information for (i) their everyday business purposes; (ii) to jointly market products or services to you with other financial Third Parties with whom Chepelos has a formal agreement; and (iii) with respect to information about your transactions and experiences only, for their Affiliates’ everyday purposes. You can unsubscribe or opt-out from receiving marketing communications in your settings (in the “Account” section) when you login to your Chepelos account.
   • We may also engage Third Parties, who may be located outside of Canada, to provide services to us, including but not limited to technology services and services to help verify your identification, to help match the photo on your ID to other photos of yourself you send to us, to conduct checks against databases such as but not limited to public government databases (where legally allowed), to otherwise assist us with fraud prevention and risk assessment, to assist us with customer service, to serve targeted ads, and to facilitate the payments or reimbursements you request. We may provide Personal Information about you to these Third Parties, or give them access to this Personal Information, for the limited purpose of allowing them to provide these services. For example, if we hire Third Parties, where permitted by applicable law, to conduct checks against databases such as but not limited to public government databases, we may provide your Personal Information, such as your full name and date of birth, to the Third Parties for the limited purpose of allowing them to conduct such checks, including background or registered sex offender checks, on our behalf. We will ensure that such Third Parties have contractual obligations to protect this Personal Information and to not use it for unrelated purposes.
   • You acknowledge, consent and agree that Chepelos may access, preserve and disclose your account information and Collective Content if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary (a) to respond to claims asserted against Chepelos; (b) to comply with legal process (for example, subpoenas and warrants); (c) to enforce and administer our agreements with users, such as the Terms of Service, the Payments Terms of Service, this Privacy Policy; (d) for fraud prevention, risk assessment, investigation, customer support, product development and de-bugging purposes; or (e) to protect the rights, property or personal safety of Chepelos, its users or members of the public. We will use commercially reasonable efforts to notify users about law enforcement requests for their data unless:
     • providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law; or
     • we believe that providing notice would (a) be futile, (b) be ineffective, or (c) would create a risk of injury or bodily harm to an individual or group, or (d) create or increase a risk of fraud upon Chepelos’s property, its Members, the Platform, Application, or Services (collectively, “Risk Scenarios”).
       In instances where Chepelos complies with legal requests for user data without notice to the user for the reasons described above, Chepelos will use commercially reasonable efforts to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no Risk Scenarios apply.
   • We may also publish, disclose and use Aggregated Information and non-personal information for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
4. HOW TO ACCESS, CHANGE OR DELETE YOUR INFORMATION, OR CANCEL YOUR CHEPELOS ACCOUNT
   You may review, update, correct or delete the Personal Information in your Chepelos Account. If you would like to correct your information or close your Chepelos Account entirely, you can do so by logging into your Chepelos Account. Please also note that any reviews, forum postings and similar materials posted by you may continue to be publicly available on the Platform in association with your first-last name, even after your Chepelos Account is cancelled.


5. CHILDREN'S PRIVACY
   The Chepelos Platform is general audience websites and services and we do not knowingly collect any Personal Information from children younger than the age of 13. If you are under 18, you should use the Chepelos Platform only with involvement of a parent or guardian. If you are under 13, you should not submit any Personal Information to us. If we learn that we have inadvertently collected Personal Information from a child younger than 13, we will take commercially reasonable efforts to delete such Personal Information from our databases.


6. CAN SPAM ACT
   The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
   
   We collect your email address in order to:
   • Send information, respond to inquiries, and/or other requests or questions.
   • Process Transaction and to send information and updates pertaining to Transaction
   • We may also send you additional information related to your product and/or service.
   • Market to our mailing list or continue to send emails to our clients after the original transaction has occurred
   To be in accordance with CANSPAM we agree to the following:
   • NOT use false, or misleading subjects or email addresses
   • Include the physical address of our business or site headquarters
   • Monitor third party email marketing services for compliance, if one is used.
   • Honor opt-out/unsubscribe requests quickly
   • Allow users to unsubscribe by using the link at the bottom of each email
   If at any time you would like to unsubscribe from receiving future emails, you can follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.


7. SECURING YOUR PERSONAL INFORMATION
   We are continuously implementing and updating administrative, technical, and physical security measures to help protect your Personal Information against unauthorized access, destruction or alteration. However, no method of transmission over the Internet, and no method of storing electronic information, can be 100% secure. So, we cannot guarantee the security of your transmissions to us and of your Personal Information that we store.


8. YOUR PRIVACY WHEN YOU ACCESS THIRD-PARTY WEBSITES AND RESOURCES
   The Platform will contain links to other websites not owned or controlled by Chepelos. Chepelos does not have any control over Third-Party websites. These other websites may place their own cookies, web beacons or other files on your device, or collect and solicit Personal Information from you. They will have their own rules about the collection, use and disclosure of Personal Information. We encourage you to read the terms of use and privacy policies of the other websites that you visit. Some portions of the Platform implement Google Maps/Earth mapping services, including Google Maps API(s). Your use of Google Maps/Earth is subject to Google’s terms of use (located at www.google.com/intl/en_us/help/terms_maps.html) and Google’s privacy policy (located at www.google.com/privacy.html), as may be amended by Google from time to time.


9. SPECIAL FEATURES AND PROGRAMS

    

    

   • Referral service and Invitation
     The Platform provides a referral service that allows you to invite your friends and contacts to use the Platform.
     
     We may integrate the Platform with third party sites such as Facebook, so that you can send invitation messages or referrals via the third party site itself. These messages will be sent by the third party site, and Chepelos does not collect or retain the contact information that is used to send them.
     
     You may also send invitation/referral emails via the Platform itself, in which case we will ask you for the contact information to which to send your invitation/referral. You can type in the email addresses or other contact information manually, or you can choose to import the contacts in your address book(s). In both cases, we may use and store this information for the sole purposes of allowing you to send your friends and contacts an invitation or referral, and for fraud detection and prevention. With respect to referrals, we will also store the email addresses of your invitees or referrals to track if your friend joins Chepelos in response to your referral or invitation.
10. CHANGES TO THIS PRIVACY POLICY
    We may change how we collect and then use Personal Information at any time and without prior notice, at our sole discretion. We may change this Privacy Policy at any time. If we make material changes to the Privacy Policy, we will notify you either by posting the changed Privacy Policy on the Platform or by sending an email to you. We will also update the “Last Updated” date at the top of this Privacy Policy. If we let you know of changes through an email communication, then the date on which we send the email will be deemed to be the date of your receipt of that email.
    
    It’s important that you review the changed Privacy Policy. If you do not wish to agree to the changed Privacy Policy, then we will not be able to continue providing the Platform and Services to you, and your only option will be to stop accessing the Platform and Services and close your Chepelos Account.


11. GOT FEEDBACK?
    Your opinion matters to us! If you’d like to provide feedback to us about this Privacy Policy, please email us at support@chepelos.com.

Chepelos Marketing Inc.
860 Steeves Ave,
Saskatoon, SK, S7L 5N1, Canada