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Privacy Policy

Last revised November 12, 2022

 

This Privacy Policy describes the categories of information that Cream Guide LLC (“Cream”, “we”, “our,” or “us”) (see Contact Information below) collects from visitors to and users of any of the websites at https://www.allthecream.com (a “Website”) and any mobile application (each, an “App” and collectively, the “Apps”) (the Website and the Apps are collectively referred to hereinafter as the “Service”) and how we use it, how we disclose or share it, how we protect it, your choices regarding it (see Your Choices Regarding Your Information below) and your rights (see Your Rights and Retention below). The information we collect and the purposes for which we use, disclose or share it will depend to some extent on how you use the Service and how you interact with us. Throughout this Privacy Policy, “information” includes personal information about you.

 

PLEASE READ THIS PRIVACY POLICY AND THE TERMS OF SERVICE (“TOS”) CAREFULLY. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY OR OUR TOS, DO NOT USE OR VISIT ANY OF THE WEBSITES OR APPS. BY USING OR VISITING ANY OF THE WEBSITES OR APPS, YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY AND OUR TOS.

 

CONTACT INFORMATION

Cream Guide LLC

5830 E 2nd St #1718

Casper, WY, 82609

Legal inquiries: legal@allthecream.com

Data Protection Office: dataprotection@allthecream.com

Please contact us with your comments or questions regarding this Privacy Policy by submitting a support request at support@allthecream.com 

INFORMATION WE COLLECT

  1. You may voluntarily provide us with information, including:

    • Service information, such as your real name, alias, email address, date of birth, profile name, profile photo, account name, picture, gender identity, preferred pronouns, personal interests, travel plans and information, other social networking service or other service user names, payment card numbers and other payment information, and a profile name and password that you create and any other information to register for and to use the Service.

While you may voluntarily provide us with sensitive information about yourself such as your gender identity, ethnicity, personal interests, relationships and preferences, there is no requirement to do so. Where you choose to provide us with such sensitive information, you are explicitly consenting to our processing of your information.

Additional information, such as information you provide when you contact or otherwise interact with us or a service provider, third party and/or other party (for example, regarding support or employment opportunities and participating in surveys).

 

  1. We can automatically collect hardware and software information about you and your device, including:

  • An identifier that is unique to the device on which you install an App and some device identifiers may be persistent device identifiers;

  • Advertising identifiers;

  • Operating system;

  • Browser type;

  • Mobile network information;

  • The make, model and serial number of your mobile device;

  • Your Internet Protocol (IP) address;

  • Domain name of your Internet service provider;

  • Platform type;

  • The Service pages that you visit and the date and time of your visits;

  • Information regarding your access to and use of an App;

  • Information regarding App crashes;

  • Anonymized information;

  • A history of your prior geographic locations; and

  • Your current geographic location.


We ask for your consent to access your geographic location information. If you allow such access, we collect your geographic location to determine your distance from other users through GPS, Wi-Fi and/or cellular technology in your mobile device. You may change such access to geographic location information via the settings on your mobile device. Your last known geographic location can be stored for the purpose of calculating your distance from other users. If you do not allow such access, you may not be able to use all portions or all functionality of the Service. Prior to your installation of an App, we may have already collected information about the other apps that you have used via our service providers, third parties and/or other parties.
 

We automatically collect certain information that is generated through your use of the Service, including information about the pages that you have viewed and the products and services you have purchased or considered purchasing through the Service.

 

We can automatically collect such information via use cookies, Web beacons, persistent device identifiers, advertising identifiers and other technologies. Please see Cookies and Other Technologies; Do Not Track below.

  1. We also can derive information or draw inferences about you based on information we collect from or about you to create a profile about you reflecting your inferences drawn from any of the foregoing information to create a profile about you reflecting your preferences, characteristics, predispositions, behavior and attitudes.

  2. We can collect information about you from:

  • publicly accessible sources;

  • users; and

  • our service providers, third parties and/or other parties.

  1. We can combine any of the information we collect from or about you and use it and disclose or share it in the manner described in this Privacy Policy.

  2. We can supplement any of the information we collect from or about you with other information.

Please see How We Can Use Your Information, How We Can Disclose or Share Your Information, Cookies and Other Technologies; Do Not Track, Your Choices Regarding Your Information, Your Rights and Retention below.
 

HOW WE CAN USE YOUR INFORMATION

We can use the information that we collect from and about you to conduct our business and for any of the purposes described in this Privacy Policy, subject to applicable law. Examples are as follows.

  1. To Provide You with Services and Products. To provide or facilitate providing you with services and products (for example, the Service), including to process, manage, maintain and service your registered account and your profile and to fulfill your transactions and process your payments.

  2. To Allow You to Participate in Interactive Features on the Service.

  3. For Travel Recommendations and Features. To make travel-related recommendations and enable travel-related features.

  4. To Administer and Troubleshoot the Service.

  5. To Communicate with You. To communicate with you to provide information, Service-related notifications, promotions and recommendations, including, without limitation, based on information you provide in your profile such as community identifications (including those related to health details and gender identity), sex preferences, and safer-sex practices.

  6. To Respond to You. To respond to you, such as when you make a request or an inquiry or share comments with us, and to provide you with support.

  7. For Personalization and Enhancement of Your Experience Using the Service. For personalization and enhancement of your experience using the Service, including to remember your interests and preferences, customize our products and services that we share with you, facilitate your interactions with us and track and categorize your activity and interests on the Service.

  8. For Marketing and Advertising. For marketing and advertising, such as to send you marketing and advertising communications and to show you marketing and advertising on the Service. For example, an advertiser can engage Cream directly to present you with an advertisement on an App. We can also run advertising on other websites and applications via our advertising display partners.

  9. To Conduct Service Provider, Third Party and/or Other Party Promotions.

  10. For Analytics. For analytics, including to understand how you use the Service, determine how you access the Service and improve the Service.

  11. For Our Business Purposes. For our business purposes, such as to operate and improve upon our business and lawful business activities, to maintain our accounts and records; for research, to determine your satisfaction with our services and products (for example, the Service), to detect and prevent fraud or misuse of our services and for any other business purpose that is permitted by applicable law.

  12. Surveys and Research. To create and/or administer surveys and conduct research of user behavior.

  13. To Improve the Service and To Develop New Services and Products.

  14. For Legal and Safety Purposes. For legal and safety purposes, including to defend or protect us, you or others, from harm or in legal proceedings, protect our rights, protect our security and the security of others and property, respond to court orders, lawsuits, subpoenas and government requests, address legal and regulatory compliance, enforce our TOS and notify you of safety issues.

  15. Anonymized Information. For collecting, compiling and/or creating anonymized information, which we or a service provider, third party and/or other party can do, subject to applicable law, and which we or a service provider, third party and/or other party can use for any purpose, subject to applicable law.

  16. With Your Consent. We can use your information other than as described in this Privacy Policy if we notify you and you consent to such use.

  17. At Your Request. We can use your information at your request, subject to applicable law.

  18. For Any Other Purpose with Notice by Us. We can use your information for any other purpose for which we provide you with notice, subject to applicable law.

  19. Cookies and Other Technologies; Do Not Track. Please see Information We Collect above and Cookies and Other Technologies; Do Not Track below.

 

Please see Information We Collect, How We Can Disclose or Share Your Information, Cookies and Other Technologies; Do Not Track, Your Choices Regarding Your Information, Your Rights and Retention below.

WHERE WE STORE YOUR INFORMATION

We store the information that we collect on our systems. If you are located outside of the United States, please note that the Service is hosted on our systems in the United States. Therefore, your information can be processed and stored in the United States. As a result, United States federal and state governments, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your information through laws applicable in the United States. By using the Service, you understand that your information can be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.

HOW WE CAN DISCLOSE YOUR INFORMATION

Information can be disclosed to or shared with other users and service providers, third parties and/or other parties in accordance with this Privacy Policy, subject to applicable law. Please note that a user can choose not to disclose or share certain information. Please see Information We Collect and How We Can Use Your Information above and Cookies and Other Technologies; Do Not Track, Your Choices Regarding Your Information, Your Rights and Retention below.

  1. Profile. The name and profile of a user of the Service, as well as other information relating to the use of the Service (such as geographic location information which can include any or all of the following - GPS coordinates; listing address and details for residential and other properties; travel plans; and trip information) and online status, may be visible to other users. Please see Information We Collect above.

  2. Geographic Location Information. The geographic location of a user of the Service, as well as other information relating to the use of the Service (such as age, ethnicity and content of questions that you ask as more particularly described in our TOS) can be disclosed to or shared with other users and service providers, third parties and/or other parties. The geographic location of a user of the Service can be used to determine which services, disclosures, features, content and information will be available to you and certain services, disclosures, features and content and information made available through the Service may only be available to users in certain geographic locations. Please see Information We Collect above.

  3. Service Providers, Third Parties and/or Other Parties. We can use service providers, third parties and/or other parties to provide the Service or to perform functions in connection with the Service, including without limitation, monitoring compliance by users with and enforcement of and applying our TOS and Profile Guidelines. We can disclose or share information about you that they need to perform their functions (for example, customer support and payment card and other payment processing and performing any of the other actions or activities allowed under this Privacy Policy). For example, we disclose or share your device identifier and demographic information with our analytics partners. We can also run advertising on other websites and applications via our advertising display partners. We can disclose or share your geographic location information and any other information that we collect or that you provide in connection with your use of the Service and any other information derived from or based upon the foregoing information with service providers, third parties and/or other parties, including without limitation, our software developers, other specialists, educators and health care providers for any reason. Service providers, third parties and/or other parties can also collect information directly from you and about you from other sources (including without limitation, other mobile applications). Please see Information We Collect above.

  4. Service Provider, Third Party and/or Other Party Promotions. We can disclose or share your information with service providers, third parties and/or other parties to conduct promotions.

  5. Business Changes. If we become involved in, or engage in the preparatory steps leading to, a merger, acquisition, sale of assets, divestiture, joint venture, securities offering, financing, bankruptcy, reorganization, liquidation, dissolution, or other transaction or if the ownership of all or substantially all of our business otherwise changes, we can disclose or share or transfer your information to another party or other parties in connection therewith and it can be used subsequently by such party or parties.

  6. Legal and Safety. Other parties such as law enforcement, government entities, courts or service providers, third parties and/or any other parties as required or allowed by applicable law and/or for enforcement of or applying our TOS and Profile Guidelines, such as for the legal and safety purposes described in How We Can Use Your Information above or otherwise to help prevent harm or fraud to us, you or others.

  7. Anonymized Information. We can disclose or share anonymized information relating to visitors to and users of the Service with any service provider, third party and/or other party for any purpose, subject to applicable law.

  8. For Analytics. We or a service provider, third party and/or other party can use analytics to understand how you use the Service, determine how you access the Service and improve the Service.

  9. With Your Consent. We can disclose or share your information other than as described in this Privacy Policy if we notify you and you consent to the disclosure or sharing thereof.

  10. At Your Request. We can disclose or share your information with any other individual or service provider, third party and/or other party at your request, subject to applicable law.

  11. For Any Other Purpose with Notice by Us. We can disclose or share your information for any other purpose for which we provide you with notice, subject to applicable law.

  12. Cookies and Other Technologies; Do Not Track. Please see Cookies and Other Technologies; Do Not Track below.

COOKIES AND OTHER TECHNOLOGIES; DO NOT TRACK

We, along with our service providers, third parties and/or other parties, use cookies, Web beacons, persistent device identifiers, advertising identifiers and other technologies.

  1. Cookies. Cookies are small bits of information that are transferred to and stored in separate files within your computer’s browser. You can instruct your browser to stop accepting cookies. But if you do not accept cookies, you may not be able to use all portions or all functionality of the Service. Please see www.allaboutcookies.org for additional information about cookies.

    • Persistent cookies remain on the visitor’s or user’s computer after the browser has been closed.

    • Session cookies exist only during a visitor’s or user’s online session and disappear from the visitor’s or user’s computer when they close the browser software.

 

  1. Web Beacons. Web beacons are small strings of code that provide a method for delivering a graphic image on a Web page or in an email message for the purpose of transferring data. You can disable the ability of Web beacons to capture information by blocking cookies.

  2. Persistent Device Identifiers. Persistent device identifiers are unique strings that are associated with the mobile device that you use to connect to the Service. Persistent device identifiers can be modified or disabled by sophisticated users.

  3. Advertising Identifiers. Advertising identifiers are unique strings associated with your mobile device provided by the operating system. Advertising identifiers can be modified or disabled by users in the operating system settings. Please see Do Not Track below for more information about how to configure these settings.

  4. Service providers, third parties and/or other parties may collect personally identifiable information about an individual user's online activities over time and across different Internet services when a user uses the Service.

  5. Below are links to resources for opting out of online tracking.
    Google Analytics collects information from website visitors and users and reports website trends without identifying individual visitors or users. Google Analytics uses its own cookie to track visitor and user interactions. Website owners can view a variety of reports about how visitors and users interact with their website so they can improve their website and how people find it. Google’s privacy policy applies to their collection, use and disclosure of your information. Please review the following links to better understand their practices: https://policies.google.com/privacy, https://policies.google.com/technologies/partner-sites, https://www.google.com/analytics/terms/ and https://tools.google.com/dlpage/gaoptout.
    We use Google Analytics to better understand who is using the Service, and how people are using it. Google Analytics uses cookies and persistent device identifiers to collect and store such information as time of visit, pages visited, time spent on each page of a Website, IP address, and type of operating system used. We use this information to improve the Service and make it appealing to users.

  6. Do Not Track. At this time, we do not respond to "do not track" signals sent from Web browsers or other mechanisms that provide users the ability to exercise choice regarding the collection of personally identifiable information about a user’s online activities over time and across service provider, third party and/or other party Internet services.
    Mobile devices provide the ability for users to enable a "do not track" setting that disables your advertising identifier. If the “do not track” setting is disabled, we can record when a user installs an App, and whether or not this action was the result of a tap on an ad outside of such App. We can also run advertising on other websites and applications via our advertising display partners. For users who have enabled the "do not track" setting on their mobile device, this data will not be collected. Please note that the “do not track” setting may not be available on all operating systems or versions of an App. We may update these instructions periodically as new information becomes available from mobile device operating system manufacturers.

 

SECURITY

We use administrative, technical and physical measures to help protect the information you submit via the Service from accidental or unlawful destruction, loss or alteration and from unauthorized access, use, or disclosure. Please be aware, however, that no security measures can guarantee absolute security. No Internet, email or mobile application transmission or method of electronic storage is ever fully secure or error free. Email or other communications sent through the Service may not be secure. You should use caution whenever submitting information through the Service and take special care in deciding which information you provide us with.

 

LINKS TO OTHER WEBSITES AND MOBILE APPLICATIONS

When you click on a link to any other website, mobile application or content, you will leave a Website and go to another website or other mobile application and another entity can collect information from or about you. We have no control over, do not review, and cannot be responsible for, these websites or mobile applications or their content. Please be aware that the terms of this Privacy Policy do not apply to these websites or mobile applications or content, or to any collection of data after you click on links to these websites, mobile applications or content. Please also read our TOS carefully.

YOUR RIGHTS

  1. Processing. We process the information of individuals in the European Union based on one or more of the following legal bases:

  • Performance of a contract: we or a third party process your information to perform the contract that you have with us (for example, providing the Service to you).

  • Legitimate interests: we or a third party can use your information where we or such third party have legitimate interests to do so (for example, analyzing users’ behavior on the Service to improve our offerings and processing information for administrative, fraud detection and other legal purposes).

  • We can ask for your consent to use your information for specific purposes. You can withdraw your consent to our processing of your personal information at any time by submitting a support request at support@allthecream.com

  • Legal obligation: we may be required to use your information to comply with a legal obligation (for example, complying with law, in response to legal process or cooperating with government or law enforcement agencies or officials or service providers, third parties and/or any other parties).

  • The processing is necessary to protect the vital interests of our users or of others (for example, processing personal information, including disclosing data with law enforcement agencies in case of threats to the safety of users or of others).

RETENTION

We will retain your personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so in connection with your registered account, or as required by law (for example, for legal, tax, accounting or other purposes), whichever is the longer.

 

If you have elected to receive email communications from us, we retain information about your email preferences until you opt out of receiving these email communications and in accordance with our policies.

 

To determine the appropriate retention period for your personal information, we will consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we use your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. In certain circumstances, we can anonymize your personal information, subject to applicable law.

Please also see Your Choices Regarding Your Information and Your Rights above.

 

CHILDREN

We do not knowingly collect personal information from individuals under age 18. If you are under the age of 18, please do not access, use or submit any personal information through the Service. If you have reason to believe that we may have accidentally received personal information from an individual under age 18, please submit a support request immediately at support@allthecream.com for users of the Cream App.

 

CHANGES TO PRIVACY POLICY

We reserve the right to update or modify this Privacy Policy at any time and from time to time and we can require your consent thereto. Please review this Privacy Policy periodically, and especially before you provide any information. This Privacy Policy was made effective on the date indicated above.

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