Privacy Policy นโยบายความเป็นส่วนตัว

1. Introduction

CheersFriends ("we," "our," or "us") operates the website cheersfriends.cc (the "Platform"). We are committed to protecting your personal data and respecting your privacy rights in accordance with:

• Singapore's Personal Data Protection Act 2012 (PDPA)
• Thailand's Personal Data Protection Act B.E. 2562 (2019) (PDPA Thailand)
• General international data protection principles

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Platform.

2. Information We Collect

2.1 Information You Provide Directly

• Account Information: Name, email address, password, date of birth, gender
• Profile Information: Photos, bio, interests, location, relationship preferences, education, occupation
• Payment Information: Payment card details processed securely through our payment provider (we do not store full card numbers)
• Communications: Messages, comments, feedback, and customer support inquiries
• Identity Information: Government-issued ID (if voluntarily provided for account recovery)

2.2 Information Collected Automatically

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Data: Pages viewed, features used, time spent, interaction patterns
• Location Data: Approximate location based on IP address or precise location (with your permission)
• Cookies and Tracking: Session cookies, analytics cookies, preference cookies

3. How We Use Your Information

We use your personal data for the following purposes:

• Service Provision: To create and manage your account, provide matchmaking services, and facilitate connections
• Communication: To send notifications, updates, and respond to inquiries
• Safety & Security: To prevent fraud, ensure platform safety, and enforce our policies
• Personalization: To customize your experience and show relevant matches
• Payment Processing: To process subscriptions and marketplace transactions
• Analytics: To improve our services, analyze usage patterns, and develop new features
• Legal Compliance: To comply with legal obligations and respond to lawful requests
• Marketing: To send promotional communications (with your consent, where required)

4. Legal Basis for Processing (Singapore & Thailand)

Under the PDPA (Singapore and Thailand), we process your personal data based on:

• Consent: You have given explicit consent for specific purposes
• Contract Performance: Processing is necessary to fulfill our agreement with you
• Legal Obligation: We are required to process data to comply with laws
• Legitimate Interests: Processing is necessary for our legitimate business interests (fraud prevention, service improvement)

5. How We Share Your Information

We may share your information with:

• Other Users: Profile information visible to other users based on your privacy settings
• Service Providers: Third-party vendors for hosting, payment processing, storage, email services, analytics, and customer support
• AI Services (OpenAI): We use OpenAI (United States) for two things. First, every photo you upload is checked automatically for sexual content, graphic violence or self-harm before other members can see it; a photo that may break our rules is not published and is reviewed by our staff. Second, when you use the AI image feature, the description you write is sent to generate the image. OpenAI processes this on our behalf, does not use it to train its models under its API terms, and may keep it for a limited time to detect abuse.
• Business Transfers: In case of merger, acquisition, or sale of assets
• Legal Requirements: When required by law, court order, or to protect rights and safety
• With Your Consent: Other disclosures with your explicit permission

Cross-Border Transfers: Your data may be transferred to and processed in countries outside Singapore/Thailand. We ensure adequate safeguards are in place, including standard contractual clauses.

6. Data Retention

We retain your personal data for as long as necessary to provide our services and comply with legal obligations:

• Active Accounts: Data retained while your account is active
• Deleted Accounts: Most data deleted within 30 days; some retained for legal/safety purposes (up to 7 years)
• Messages: Retained for the duration of your account unless deleted
• Financial Records: Retained for 7 years as required by law

7. Your Rights

Under Singapore and Thailand data protection laws, you have the following rights:

• Access: Request a copy of your personal data
• Correction: Update or correct inaccurate information
• Erasure: Request deletion of your data (subject to legal obligations)
• Data Portability: Receive your data in a structured, machine-readable format
• Withdraw Consent: Withdraw consent for processing (may limit service availability)
• Object to Processing: Object to certain types of processing
• Restrict Processing: Request limitation of how we use your data
• Lodge a Complaint: File a complaint with the relevant data protection authority

To exercise these rights, contact us at: [email protected]

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data:

• Encryption of data in transit (SSL/TLS) and at rest
• Secure password hashing
• Access controls and authentication
• Regular security audits and monitoring
• Secure cloud infrastructure
• Employee confidentiality agreements and training

However, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security.

9. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Keep you logged in
• Remember your preferences
• Analyze site usage and performance
• Provide personalized content

You can control cookies through your browser settings. Disabling cookies may affect platform functionality.

10. Children's Privacy

Our Platform is only for people aged 18 and over. We do not knowingly collect personal data from children.

When you join, we ask for your date of birth once. It is used only to check your age: it is kept private and is never shown on your profile.

If the date of birth given is under 18, or we otherwise learn that a member is under 18, we lock the account straight away. It can no longer be used, and the member is hidden from everyone else. The member can still delete the account themselves. After a review, normally within 30 days, we delete the account and its personal data, keeping only what is needed to stop the same sign-in from opening a new account.

If a date of birth was entered by mistake, write to us and we will correct it after checking. Contact us at: [email protected]

11. Third-Party Links

Our Platform may contain links to third-party websites. We are not responsible for the privacy practices of these sites. We encourage you to review their privacy policies.

12. International Users

Our Platform is operated from Thailand and Singapore. If you access our Platform from other countries, your data may be transferred to and processed in Thailand, Singapore, or other countries. By using our Platform, you consent to such transfers.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy, please contact:

Regulatory Authorities:

• Singapore: Personal Data Protection Commission (PDPC) — www.pdpc.gov.sg
• Thailand: Personal Data Protection Committee — www.pdpc.or.th

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Posting the updated policy on this page with a new "Last Updated" date
• Sending an email notification (for significant changes)
• Displaying a prominent notice on our Platform

Your continued use of the Platform after changes constitutes acceptance of the updated policy.

16. The CheersFriends App for Android

The CheersFriends app for Android uses the same account and the same data as CheersFriends in LINE, as described above. This section says what is specific to the app.

• Location. If you give the app permission, it reads your phone's location to place you on the map and to show people and events near you. You can refuse the permission, switch location sharing off, or choose a different area in the app. The app does not collect your location in the background.
• Photos and videos. The app uploads only the photos and videos you choose. A video is shortened and compressed on your phone before it is sent.
• Crash reports. If the app crashes, it sends a crash report to Google Firebase Crashlytics, which processes it for us. A report contains the technical trace of the fault, your phone model, Android version and app version, and a random identifier for that installation of the app. We do not attach your name, your account, your messages, your photos or your location to a crash report. We use crash reports only to find and fix faults.
• Signing in. The app keeps you signed in with a token stored in encrypted form on your phone. It is excluded from Android's backups and device-to-device transfer, so on a new phone you sign in again.
• No advertising. The app shows no advertisements, does not use an advertising identifier, and we do not sell your data.
• Reports and safety. When you report a member, a photo or a video, we keep the report and the reported content so that our staff can review it. Staff can remove content from a conversation and restrict, suspend or close an account. See our Child Safety Standards.
• Deleting your account. You can delete your account in the app at any time. What is deleted and what is kept is set out on the Delete your account page.

17. Ambassador Programme

Members who accept the Ambassador Agreement and are named as ambassadors participate in our cash commission programme. This section describes what we collect and how we use that data.

17.1 Information We Collect

• Agreement Acceptance: Which version of the Ambassador Agreement you accepted, the date of acceptance, and your confirmation that you reside in Thailand
• Payout Details: Your Wise account email or Wisetag, or your Thai bank, account name and account number. They are shown to you masked and in full only to the staff who make payouts
• Commission Ledger: A record of all invoices paid by friends you referred, commission amounts, payment status, and payout history
• Referral Links: Tracking which friends joined through your referral to determine eligibility

17.2 How We Use This Data

• To calculate and track your commissions according to the Ambassador Agreement
• To pay you through Wise, into your Wise account or your Thai bank account
• To provide you with a ledger and statement in the app of earnings and payment status
• To comply with accounting and tax requirements

17.3 Sharing With Service Providers

Wise (Payment Processor): We share your full name, payout details (your Wise email or Wisetag, or your Thai bank, account name and account number) and the amounts paid with Wise to facilitate international payment transfers from Singapore to Thailand. Wise acts as a data processor and is responsible for securing this information. For details, see Wise's Personal Customer Privacy Notice for Thailand.

17.4 Data Retention

Because VIZNEO is registered in Singapore, we keep business records as Singapore law requires. Your agreement acceptance records, your commission ledger and the record of each payment we made to you (date, amounts, exchange rate, Wise reference, and the name and masked account it was paid to) are kept for 5 years after the end of the year they relate to, even if you leave the Programme or delete your account. Your full payout details (Wise email, Wisetag or bank account number) are kept only while you have an account and are deleted when you delete it. Once you have left the Programme and received your last payment, you can also ask us to delete them sooner.

17.5 Your Rights

You have the same rights described in Section 7 (Your Rights) for all data we hold about you, including Ambassador programme data. You can request access, correction, deletion (subject to legal obligations), or portability of your commission records by contacting [email protected].