CheerClub Privacy Policy

Effective Date: July 17, 2026 · Last Updated: July 17, 2026 · Version 1.1

CPM AI, Inc., doing business as CheerClub ("CheerClub," the "Company," "we," "us," or "our"), respects your privacy and is committed to protecting it through our compliance with this Privacy Policy (this "Policy").

This Policy describes the types of information we may collect from you or that you may provide when you use the CheerClub mobile application (the "App"), the CheerClub websites and cheer-recording web pages, currently available at https://cheerclub.app and https://s1drao.github.io/cheer/ (together, the "Site"), and any related services, features, content, or communications (collectively, the "Service"), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Please read this Policy carefully to understand our policies and practices regarding your information. If you do not agree with our policies and practices, do not use the Service. By accessing or using the Service, you agree to this Policy. This Policy may change from time to time (see Section 14); your continued use of the Service after we make changes is deemed to be acceptance of those changes.

1. Who We Are; Scope of This Policy

The Service is owned and operated by:

CPM AI, Inc. (d/b/a CheerClub)
2261 Market Street, STE 72868
San Francisco, CA 94114, United States
Email: support@cheerclub.app

This Policy applies to information we collect: (a) in the App; (b) on the Site, including the cheer-recording web pages accessed via a Runner's share link; (c) in text messages, push notifications, and email between you and the Service; and (d) when you interact with us for support. It does not apply to information collected by any third party, including through any application, content, or link that may be accessible from the Service (see Section 15), or to information you provide to mobile carriers, device manufacturers, or app stores, whose practices are governed by their own privacy policies.

This Policy is incorporated into and forms part of our Terms of Service. Capitalized terms not defined here have the meanings given in the Terms of Service.

2. Definitions

• "Runner" means a person who creates an account in the App to plan runs and receive Cheers.
• "Cheerer" means a person who visits a Runner's share link on the Site and records a Cheer, with or without opting in to text notifications.
• "Cheer" means a short voice recording submitted by a Cheerer for playback to a Runner during a run.
• "Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Personal Information does not include de-identified or aggregated information, or publicly available information as defined by applicable law.
• "Processor" or "Service Provider" means a vendor that processes Personal Information on our behalf pursuant to a written contract.

3. Information We Collect

3.1 Information You Provide to Us Directly

3.2 Information Collected Automatically

3.3 Information We Do Not Collect

We do not knowingly collect: precise or continuous geolocation data (run progress is entered or measured as mileage only); payment card or financial account information (the Service is currently free); biometric identifiers or biometric information; health or medical records; Social Security numbers or other government identifiers; or information revealing racial or ethnic origin, religious beliefs, sexual orientation, immigration status, or union membership. We do not use facial recognition. We do not access your contacts, photos, or files.

3.4 Information From Third Parties

We receive limited technical confirmations from our Service Providers — for example, delivery status of a text message from our SMS provider, or delivery status of a push notification from Apple. We do not purchase Personal Information from data brokers, and we do not enrich your profile with third-party marketing data.

4. How We Use Your Information

We use Personal Information for the following business purposes, and, where required by applicable law, in reliance on the corresponding legal bases:

We do not use your Personal Information for third-party advertising, cross-context behavioral advertising, or automated decision-making that produces legal or similarly significant effects. We do not sell Personal Information.

5. SMS/Text Messaging Program & Consent ("CheerClub Alerts")

CheerClub operates an optional recurring SMS notification program for Cheerers. This Section, together with the SMS provisions of our Terms of Service, constitutes the program's disclosures.

5.1 What You Receive

If you opt in, we will send you: (a) a notification text when a Runner you cheered for starts their run; (b) a notification text when the Cheer you recorded plays in the Runner's headphones during their run; and (c) invitation texts when a Runner you previously cheered for schedules a new run and chooses to notify their cheer squad. We may also send you messages strictly necessary to administer the program (such as an opt-out confirmation).

5.2 How Consent Is Collected

Consent is collected exclusively through a web form on the Site: after you record a Cheer, an optional form asks whether you would like a text when your cheer plays. You opt in by typing your mobile phone number into that form and pressing the confirmation button. The form discloses that message and data rates may apply, that message frequency varies, and that you may reply STOP to opt out or HELP for help, and links to this Policy and to the Terms of Service. Consent is not a condition of using the Service, of recording Cheers, or of any purchase.

5.3 Program Details

• Message frequency varies based on your friends' running activity. You will typically receive one message when a Cheer you recorded plays, and occasional invitations when Runners you know schedule new runs.
• Message and data rates may apply according to your mobile carrier plan. CheerClub does not charge for the messages themselves.
• Opt-out: Reply STOP (or STOPALL, UNSUBSCRIBE, CANCEL, END, or QUIT) to any CheerClub message. You will receive a single confirmation message, after which no further messages will be sent to that number unless you opt in again.
• Help: Reply HELP to any CheerClub message, or contact support@cheerclub.app.
• Supported carriers: major U.S. carriers. Carriers are not liable for delayed or undelivered messages.
• Number changes: if you change or deactivate your mobile number, please text STOP from the old number or notify us so we can remove it.

5.4 The Mobile Information Non-Sharing Commitment

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All the categories of sharing described in Section 7 exclude text messaging originator opt-in data and consent; this information will not be shared with, or sold to, any third party. Phone numbers collected through the SMS opt-in are used solely to deliver the notifications described in this Section, are stored server-side only, and are never displayed to other users of the Service — including the Runner you cheered for.

6. Cookies, Local Storage & Similar Technologies

The Site uses browser local storage (not tracking cookies) for the following strictly functional purposes:

We do not use advertising cookies, analytics cookies from third-party ad networks, cross-site tracking pixels, or fingerprinting techniques. Our authentication provider may set strictly necessary tokens required for Runner sign-in sessions in the App. You can clear local storage at any time through your browser settings; doing so will cause the Site to treat you as a new visitor.

7. How We Disclose Your Information

We do not sell Personal Information and have not sold Personal Information in the preceding twelve (12) months. We do not "share" Personal Information for cross-context behavioral advertising. We disclose Personal Information only as follows:

7.1 Within the Service, at Your Direction

When you record a Cheer, the display name you enter and your recording are delivered to the Runner whose share link you used. Your display name (but never your phone number) may be shown in the "cheer squad" list visible to the Runner and to other visitors who hold the same share link. Runners' display names are shown on their cheer pages to the people they invite.

7.2 Service Providers (Processors)

We disclose Personal Information to a small number of Service Providers that perform functions on our behalf, under contracts that restrict their use of the information to providing services to us:

7.3 Legal Requirements & Protection

We may disclose Personal Information: (a) to comply with any court order, law, or legal process, including responding to any government or regulatory request; (b) to enforce or apply our Terms of Service and other agreements; or (c) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of CheerClub, our users, or others.

7.4 Business Transfers

If CheerClub or substantially all of its assets are acquired, or in the event of a merger, financing, reorganization, bankruptcy, or similar transaction, Personal Information may be among the transferred assets, subject to this Policy. Consistent with Section 5.4, text messaging originator opt-in data and consent will not be transferred for marketing or promotional purposes.

7.5 Aggregated and De-Identified Information

We may use and disclose aggregated or de-identified information that cannot reasonably be used to identify you (for example, total number of cheers recorded) for any lawful purpose. Where we rely on de-identified data, we commit to maintaining it in de-identified form and not attempting re-identification.

8. Data Retention

We retain Personal Information only as long as reasonably necessary for the purposes described in this Policy, unless a longer retention period is required or permitted by law. Representative retention practices:

When retention ends, we delete or de-identify the information. Residual copies may persist in encrypted backups for a limited period before being overwritten in the ordinary course.

9. Data Security

We implement commercially reasonable administrative, technical, and physical safeguards designed to protect Personal Information against accidental loss and unauthorized access, use, alteration, and disclosure, including: encryption of data in transit (TLS/HTTPS) and at rest; row-level security policies restricting database access; capability-based access to cheer pages via unguessable share tokens; server-side-only storage of opt-in phone numbers (never exposed through client applications or to other users); scoped API keys; and the principle of least privilege for administrative access.

The safety and security of your information also depends on you. Keep your device secure and do not share a Runner's link beyond the audience the Runner intends. Unfortunately, the transmission of information via the internet is not completely secure; although we do our best to protect your Personal Information, we cannot guarantee its absolute security. In the event of a breach affecting your Personal Information, we will notify you and applicable regulators as required by law.

10. Your Rights & Choices

10.1 Choices Available to Everyone

• SMS: opt out at any time by replying STOP to any CheerClub message (see Section 5.3).
• Push notifications: disable at any time in your device's notification settings.
• Microphone: deny or revoke microphone permission in your browser at any time (you will not be able to record Cheers without it).
• Local storage: clear your browser's site data to remove the anonymous identifier and saved name.
• Access, correction, deletion, portability: email support@cheerclub.app. We will respond to verified requests within the timeframes required by applicable law (and in any event endeavor to respond within 45 days).

10.2 Verification

To protect your information, we will verify your identity before fulfilling rights requests — typically by confirming control of the phone number or email associated with the relevant records. If you are a Cheerer without an account, we may ask you to make the request from the browser holding your anonymous identifier or to confirm the opted-in phone number via a verification code. You may use an authorized agent to submit a request; we will require proof of the agent's authority and verification of your identity.

10.3 Appeals

If we decline to act on your request, you may appeal by replying to our decision email with the subject line "Privacy Appeal." If your appeal is denied and you are in a jurisdiction that provides for it, you may contact your state attorney general or supervisory authority.

11. State-Specific Privacy Disclosures

11.1 California (CCPA/CPRA)

This subsection applies to California residents. In the preceding 12 months we have collected the categories of Personal Information described in Section 3, which map to the following CCPA categories: Identifiers (name, phone number, IP address, UUID); Audio or similar information (voice recordings); Internet or other electronic network activity information (usage data); and Inferences only to the trivial extent of associating repeat Cheers with the same anonymous identifier. Sources, purposes, and disclosures are described in Sections 3, 4, and 7 respectively.

California residents have the right to: (a) know/access the Personal Information we collect; (b) delete Personal Information; (c) correct inaccurate Personal Information; (d) receive Personal Information in a portable format; (e) opt out of "sale" or "sharing" (we do neither); (f) limit use of sensitive personal information (we do not collect sensitive personal information as defined by the CPRA, except phone numbers used solely for the purposes disclosed); and (g) non-discrimination for exercising rights. Submit requests as described in Section 10. We do not offer financial incentives in exchange for Personal Information. Because we do not sell or share Personal Information, we do not process opt-out preference signals such as Global Privacy Control for those purposes, though we honor them where legally required.

11.2 Virginia, Colorado, Connecticut, Utah, Texas, Oregon & Other State Privacy Laws

Residents of states with comprehensive privacy laws (including the VCDPA, CPA, CTDPA, UCPA, TDPSA, and OCPA) have rights of access, correction, deletion, portability, and the right to opt out of targeted advertising, sale, and profiling. We do not engage in targeted advertising, sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects. You may exercise your rights, and appeal a refusal, as described in Section 10.

11.3 Nevada

Nevada residents may opt out of the sale of certain covered information. We do not sell covered information as defined by Nevada law; you may nonetheless submit a request to support@cheerclub.app.

12. International Users & Data Transfers

The Service is operated from the United States and is intended for users located in the United States. If you access the Service from outside the United States, you understand that your information will be transferred to, stored, and processed in the United States, where data protection laws may differ from those of your jurisdiction.

If the EU or UK General Data Protection Regulation applies to our processing of your information, then: our legal bases are those identified in Section 4; we act as the data controller; you have the rights of access, rectification, erasure, restriction, portability, and objection, and the right to withdraw consent at any time (without affecting prior processing); and you may lodge a complaint with your local supervisory authority. Where we transfer personal data from the EEA, UK, or Switzerland, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses and processor commitments of our Service Providers.

13. Children's Privacy

The Service is not directed to children under 13 years of age, and we do not knowingly collect Personal Information from children under 13. If you are under 13, do not use the Service, register an account, record a Cheer, or provide any information about yourself. If we learn that we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete it. If you believe we might have any information from or about a child under 13, please contact us at support@cheerclub.app. California residents under 16 may have additional rights regarding content they post; contact us for assistance.

14. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, technologies, legal requirements, or the Service. If we make material changes, we will revise the "Last Updated" date above and provide notice as required by law — for example, by posting a prominent notice on the Site, providing in-App notice, or, for opted-in SMS users whose program terms materially change, by text message. Changes are effective when posted unless otherwise stated. We encourage you to review this Policy periodically.

15. Third-Party Websites & Services

The Service may contain links to, or allow you to share content through, third-party websites and services (for example, iMessage, Instagram, or other share destinations). Any information you provide on or to third-party services is provided directly to the operator of that service and is subject to its policies. This Policy does not apply to third-party services, and we are not responsible for their content, privacy practices, or security. Cheer share links you send through a messaging platform are handled by that platform under its own terms.

16. Do Not Track

Some browsers transmit "Do Not Track" (DNT) signals. Because there is not yet a common industry standard for DNT, the Site does not currently respond differently to DNT signals; however, we do not engage in cross-site tracking of any kind, so all visitors receive the equivalent of DNT treatment by default.

17. Accessibility

We are committed to making this Policy accessible. If you have difficulty accessing this Policy or need it in an alternative format, contact support@cheerclub.app and we will provide reasonable assistance.

18. How to Contact Us

To ask questions or comment about this Policy and our privacy practices, or to exercise any of the rights described above:

CPM AI, Inc. (d/b/a CheerClub)
Attn: Privacy Office
2261 Market Street, STE 72868
San Francisco, CA 94114, United States
Email: support@cheerclub.app (subject line "Privacy Request")