Privacy Policy

Welcome to CreamSoda!

Welcome to CreamSoda, a division of Inka Inc., company duly registered and existing under the laws of Canada, with its legal address at 701-18 Rean Drive, Toronto, Ontario, Canada (“CreamSoda”, “we”, “us” and/or “our”). This privacy policy (“Privacy Policy”) has been created to provide information about our company and our mobile applications (together with the Website (as defined below), the “Services”) to our users (“you”, “your”). The Services are provided by Inka Inc. (“Inka Inc.” or “we” or “us” or “our”) located at 701-18 Rean Drive, Toronto, Ontario, Canada. This Privacy Policy sets forth CreamSoda’s policy with respect to personal data and other information that is collected by Inka Inc. from visitors to our website located at (the “Website”) and users of the Services.

1. Information we collect

When you interact with us through the Services, we may collect personal data and other information from you, as further described below:
  1. Personal Data That You Provide Through the Services: We collect personal data from you when you voluntarily provide such information, such as when you register for access to the Services (for example email address, first name, and last name), use certain Services, contact us with inquiries, or respond to one of our surveys. 
  2. By voluntarily providing us with personal data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide personal data to us, you acknowledge and agree that such personal data may be transferred from your current location to the offices and servers of Inka Inc. and the authorized third parties referred to herein located in Canada.
  3. Device, Usage Information, and Transactional Data. We collect information about how you use our Services and the computers or other devices, such as mobile phones or tablets, you use to access our Services. Some examples include:
    • IP address;
    • Profile pictures;
    • E-mails;
    • Phone numbers;
    • Unique device identifiers and device attributes, like operating system and browser type;
    • Usage data, such as: web log data, referring and exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used our Services, the frequency of your use of our Services, error logs, and other similar information.
  4. Non-Identifiable or Aggregated Data: When you interact with Inka Inc. through the Services, we receive and store certain personally non-identifiable data. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Inka Inc. may store such information itself or such information may be included in databases owned and maintained by Inka Inc. affiliates, agents or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Services, the number of visitors to each page of our Website or our apps, the domain names of our visitors’ Internet service providers, and how our users use and interact with the Inka Inc. Services.
Also, in an ongoing effort to better understand and serve the users of the Services, Inka Inc. often conducts research on its customer demographics, interests and behavior based on the personal data and other information provided to us. This research may be compiled and analyzed on an aggregate basis. Inka Inc. may share this non-identifiable and aggregate data with its affiliates, agents and business partners, but this type of non-identifiable and aggregate information does not identify you personally. Inka Inc. may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

In operating the Services, we may also use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services and help us analyze Services usage more accurately. For instance, our Services may set a cookie on your browser or device that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Services. In all cases in which we use cookies, we will not collect personal data except with your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Services features.

2. Our Use of Your personal data and Other Information

Inka Inc. uses the personal data you provide in a manner that is consistent with this Privacy Policy. If you provide personal data for a certain reason, we may use the personal data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the personal data you provide to answer your question or resolve your problem. Also, if you provide personal data in order to obtain access to the Services, we will use your personal data to provide you with access to such services and to monitor your use of such services. Inka Inc. and its subsidiaries and affiliates (the “Related Companies”) may also use your personal data and other personally non-identifiable data collected through the Services to help us customize the Services or the messages you receive, improve the content and functionality of the Services, to better understand our users and to improve the Services.

Inka Inc. and its Related Companies may use this information to communicate with you regarding the Services or to tell you about services we believe will be of interest to you. If we do so, any marketing communication we send you will contain instructions permitting you to “opt-out” of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below. Note however that as user of the Service you cannot opt-out of some administrative communications that are reasonably necessary to the Service, such as billing or service notifications.

3. Our Disclosure of Your Personal Data and Other Information

Inka Inc. is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your personal data with certain third parties without further notice to you, as set forth below: 

  • Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, personal data may be part of the transferred assets. 
  • Related Companies: We may also share your personal data with our Related Companies for purposes consistent with this Privacy Policy. 
  • Service Providers and Related Third Parties: Inka Inc., like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. 
  • Legal Requirements: Inka Inc. may disclose your personal data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Inka Inc., (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.

4. Your Choices

You may request that we delete your account, and any information associated with your account, but please note that we may be required (by law or otherwise) to retain certain information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete your information, it will be deleted from the active database but may remain in our archives.

5. Links to Other Websites

This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by Inka Inc. (the “Third Party Websites”). The policies and procedures we described here do not apply to the Third Party Websites. The links from the Services do not imply that Inka Inc. endorses or has reviewed the Third Party Websites. We suggest contacting those websites directly for information on their privacy policies.

6. Integrating Third Party Services within the Services

One of the special features of the Service is that it allows you to enable various online third party services, such as social media and networking services, (“Third Party Services”) to be directly integrated into your CreamSoda experience. To take advantage of this feature, we will ask you to provide us your username and password for the relevant Third Party Services. By enabling such Third Party Services, you are allowing us to pass your log-in information to these service providers for this purpose. When you add a Third Party Service account to the Service, we will collect your login information and other relevant information necessary to enable the Service to access that Third Party Service and your data contained within that Third Party Service. However, please remember that the manner in which Third Party Services use, store and disclose your information is governed solely by the policies of such third parties, and Inka Inc. shall have no liability or responsibility for the privacy practices or other actions of any Third Party Service that may be enabled within the Service.

7. Security

Inka Inc. takes reasonable steps to protect the personal data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet, email or other electronic transmission is ever fully secure or error free, so you should take special care in deciding what information you send to us in this way.

8. Other Terms and Conditions.

Your access to and use of the Services is subject to the Terms of Service.

9. Changes to CreamSoda’s Privacy Policy

The Services and our business may change from time to time. As a result, at times it may be necessary for Inka Inc. to make changes to this Privacy Policy. Depending on the type of change, we may notify you of the change by posting on this page or by email. Please review this policy periodically, and especially before you provide any personal data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

10. Access to Information

To keep your personal data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct personal data in our possession that you have previously submitted via the Services. You may also have the right to access and review information associated with your account, or to request further details regarding how long we use or store your personal data.

Inka Inc. shall, upon the receipt of a written request from individuals, inform them of the existence, use, and disclosure of any personal information about them, and they shall be given access to such information except as may be limited by law. Inka Inc. shall amend personal information as deemed appropriate to ensure continued accuracy.

Requests for disclosure must be made in writing, by email, or letter. We respond to all requests within 30 days.

It is important to verify that the individual requesting information is in fact the person in question. For this reason, we demand that all inquiries be in writing and that our responses, also in writing are sent to the address we have on file. Any alternative handling will require mandatory validation of the requestor’s identity and address information.

Inka Inc. will assist any individual who needs help in preparing the request.

Any responses shall be provided in an understandable manner with adequate explanation of abbreviations or codes. Upon request, Inka Inc. will provide access to personal information in an alternative format for individuals with sensory disabilities, if conversion to an alternate format is reasonable and necessary.

11. Users' Consent

By using our Services, you:

  • acknowledge that your information will be processed as described in this Privacy Policy;
  • consent to having your information transferred to our affiliates and facilities, in Canada or elsewhere, and to the facilities of those third parties with whom we share it as described in this Privacy Policy.

We keep your personal information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws. Where there are technical limitations that prevent deletion or anonymization, we safeguard personal data and limit active use of it.

By signing-up on the Platform you automatically provide your consent for gaining distribution of information or advertisements from the Company or/and its partners.

You may withdraw your consent for us to collect, use or disclose your personal data by giving us a written notice via email at any time with effect for the future. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal. We will not, without your express consent, supply your personal data to any third party for the purpose of their or any other third party’s direct marketing.

12. Minors and Children’s Privacy

Protecting the privacy of young children is especially important. Our Service is not directed to children under the age of 18, and we do not knowingly collect Personal Data from children under the age of 18 without obtaining parental consent. If you are under 18 years of age, then please do not use or access the Service at any time or in any manner. If we learn that Personal Data has been collected on the Service from persons under 18 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 18 years of age has obtained an Account on the Service, then you may alert us at and request that we delete that child’s Personal Data from our systems.

The Service is not intended to be used by minors, and is not intended to be used to post content to share publicly or with friends. To the extent that a minor has posted such content on the Service, the minor has the right to have this content deleted or removed using the deletion or removal options detailed in this Privacy Policy. If you have any question regarding this topic, please contact us as via e-mail Please be aware that, although we offer this deletion capability, the removal of content may not ensure complete or comprehensive removal of that content or information.

13. Data Security

We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission through public internet, and we also employ application-layer security features to further anonymize Personal Data.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Data has been compromised, please contact us immediately.

If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.

14. Data Retention

We only retain the Personal Data collected from a User for as long as the User’s account is active or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as follows:

  • The contents of closed accounts are deleted within 3 months of the date of closure;
  • Backups are kept for 3 months;
  • Billing information is retained for a period of 6 years.
  • Information on legal transactions between Client and Inka Inc. is retained for a period of 6 years.

Additionally, please note that we cannot control the actions of other users with whom you may choose to share your information. Furthermore, even after information posted on the Service is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Service. We cannot and do not guarantee that information you post on or transmit to the Service will not be viewed by unauthorized persons.

15. Data Transfer

We may transfer, process and store any information that identifies or may identify user as a natural person (the “Personal Data”). The Service is hosted in Canada, which, according to the Adequacy Decision of the European Commission, ensures adequate level of Personal Data protection. Data stored in Canada is subject to Canadian jurisdiction and Canadian laws (in particular, the Personal Information Protection and Electronic Documents Act (PIPEDA), and, if it relates to a European data subject, to the GDPR. If a data center in Canada loses control and the data is backed up to a different country, the data becomes subject to the jurisdiction of that country. We will comply with GDPR requirements providing adequate protection for the transfer of personal information from Europe to Canada. Also, we may transfer your data to the EEA, or other countries or regions deemed by the European Commission to provide adequate protection of personal data in connection with storage and processing of data, fulfilling your requests, and operating the Service.

16. Data Controller and Data Processor

Inka Inc. does not own, control or direct the use of any of the Personal Data, reports, addresses, and other files, folders or documents in electronic form that a User stores within the Platform (the “Client Data”). Only Users and Inka Inc. customers (the “Clients”) are entitled to access, retrieve and direct the use of such Client Data. Inka Inc. is largely unaware of what Client Data is actually being stored or made available by a Client or User to the Service and does not directly access such Client Data except as authorized by the Client, or as necessary to provide Services to the Client and its Users.

Because Inka Inc. does not collect or determine the use of any Personal Data contained in the Client Data and because it does not determine the purposes for which such Personal Data is collected, the means of collecting such Personal Data, or the uses of such Personal Data, Inka Inc. is not acting in the capacity of data controller in terms of the European Union’s General Data Protection Regulation (Regulation (EU) 2016/679, the “GDPR”) and does not have the associated responsibilities under the GDPR. Inka Inc. should be considered only as a processor on behalf of its Clients and Users as to any Client Data containing Personal Data that is subject to the requirements of the GDPR. Except as provided in this Privacy Policy, Inka Inc. does not independently cause Client Data containing Personal Data stored in connection with the Services to be transferred or otherwise made available to third parties, except to third party subcontractors who may process such data on behalf of Inka Inc. in connection with Inka Inc.’s provision of Services to Clients. Such actions are performed or authorized only by the applicable Client or User.

The Client or the User is the data controller under GDPR for any Client Data containing Personal Data, meaning that such party controls the manner such Personal Data is collected and used as well as the determination of the purposes and means of the processing of such Personal Data.

Inka Inc. is not responsible for the content of the Personal Data contained in the Client Data or other information stored on its servers (or its subcontractors’ servers) at the discretion of the Client or User nor is Inka Inc. responsible for the manner in which the Client or User collects, handles disclosure, distributes or otherwise processes such information.

Inka Inc. maintains procedures for addressing and responding to all inquiries or complaints from its customers about Inka Inc. handling of personal information. We will inform individuals who make inquiries or lodge complaints of the existence of relevant complaint procedures. If a complaint is found to be justified, we will take appropriate measures, including, if necessary, amending policies and procedures.

17. Changes and Updates to this Policy and its language

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Service, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.

The original language of this Policy is English. Inka Inc. may translate this Privacy Policy into different languages, but in case of conflicts between English version and any translation, the English version shall prevail.

18. How to Contact Us

You may contact us as follows: emailing or Inka Inc: Attention LEGAL; 701-18 Rean Drive, Toronto, Ontario, Canada.