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Privacy policy


Geras Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit the website or use the Cheer app (together ‘Cheer’) and tell you about your privacy rights and how the law protects you. 

You are in control of your data. If you are visiting the website, we will only collect the data that you choose to provide us with. You will see that we have set out various examples of personal data, which we have done so that you are aware of what constitutes personal data and how we will treat it if you choose to share it with us.    

1    Important information and who we are

1.1    Purpose of this privacy notice

This privacy notice aims to give you information on how Geras Limited collects and processes your personal data through your use of Cheer and, if applicable, your participation in a Virtual Retirement Community. 

Cheer is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. 

1.2    Controller

Geras Limited is the controller and responsible for your personal data (collectively referred to as “Geras”, “we”, “us” or “our” in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below. 

1.3    Contact details

Our full details are:

Full name of legal entity

Geras Limited

Name or title of data privacy manager

Brian Thornton

Contact details

Phone: 07737 388 821

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues ( We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 

1.4    Changes to the privacy notice and your duty to inform us of changes

This version was produced in June 2023. 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1.5    Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2    The data we collect about you

2.1    Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

2.2    We collect the personal data of the Cheer subscriber, as well as their family members or friends (or other party who is the Cheer subscriber’s main carer or contact).  

2.3    We may collect, use, store and transfer different kinds of personal data about you which we have grouped together below. If you are using the website, we will only process the personal data that you choose to share with us.

2.3.1    Identity Data includes but is not limited to first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, place of birth and gender. 

2.3.2    Contact Data includes but is not limited to billing address, delivery address, email address and telephone numbers.

2.3.3    Financial Data includes but is not limited to bank account and payment card details.

2.3.4    Transaction Data includes details about payments to and from you.

2.3.5    Technical Data includes but is not limited to internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, the time you spent on the Cheer app and the content you watched on it, operating system and platform and other technology on the devices you use to access this website. 

2.3.6    Profile Data includes but is not limited to your username, your Cheer User ID, your interests, hobbies and preferences, details of where you have studied and worked, your daily routine, how you use technology, your feedback and survey responses, depending on what you choose to share with us.  

2.3.7    Usage Data includes but is not limited to information about how you use Cheer.  

2.3.8    Marketing and Communications Data includes but is not limited to your preferences in receiving marketing from us and our third parties and your communication preferences.

2.3.9    Special category data includes but is not limited to religion, health information (including any medications you currently take). We would only collect this with your explicit consent and if you choose to supply us with this information. 

2.3.10  Caregiver / Family data includes but is not limited to Caregiver name/s, username/s, contact information, date of birth, payment details, depending on what you choose to share with us.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

2.4    If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). 

3    How is your personal data collected?

We use different methods to collect data from and about you including through:

3.1    Direct interactions –You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: 

3.1.1    meet with us or attend an interview with us; 

3.1.2    fill out a contact form; 

3.1.3    create an account on our website;

3.1.4    request our newsletter to be sent to you;

3.1.5    give us some feedback

3.1.6    edit your account by yourself or through your Caregiver within the Cheer system or website.

3.2    Automated technologies or interactions – As you interact with Cheer, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

3.3    Third parties or publicly available sources – We may receive personal data about you from third parties as set out below: 

3.4    Technical Data from the following parties: 

3.4.1    analytics providers (such as Google and Vimeo based outside the EU); 

3.5    In respect of the Cheer app only, Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

4    How we use your personal data

4.1    We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

4.1.1    Where we have your consent to using your personal data for a particular purpose. 

4.1.2    In respect of the Cheer app only, where we need to perform the contract we are about to enter into or have entered into with you.

4.1.3    Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.

4.1.4    Where we need to comply with a legal or regulatory obligation.

4.2    Purposes for which we will use your personal data 

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. 

Type of data


Lawful basis for processing including basis of legitimate interest

(a)    Identity 
(b)    Contact

To register you as a new customer (Cheer app only)

Performance of a contract with you

(a)    Identity 
(b)    Contact  
(c)    Financial 
(d)    Transaction 
(e)    Marketing and Communications

To process and deliver your order including: 
(a)    Manage payments, fees and charges 
(b)    Collect and recover money owed to us
(Cheer app only)

(a)    Performance of a contract with you 
(b)    Necessary for our legitimate interests (to recover debts due to us)

(a)    Identity 
(b)    Contact 
(c)    Profile 
(d)    Marketing and Communications

To manage our relationship with you which will include:
(a)    Notifying you about changes to our terms or privacy policy 
(b)    Asking you to leave a review or take a survey

(a)    Performance of a contract with you 
(b)    Necessary to comply with a legal obligation 
(c)    Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

(a)    Identity 
(b)    Contact 
(c)    Technical

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a)    Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) 
(b)    Necessary to comply with a legal obligation

(a)    Identity 
(b)    Contact 
(c)    Profile 
(d)    Usage 
(e)    Marketing and Communications 
(f)    Technical 

To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

(a)    Technical 
(b)    Usage 

To use data analytics to improve Cheer, marketing, customer relationships and experiences

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

(a) Identity 
(b) Contact 
(c) Technical
(d) Usage 
(e) Profile 

To make suggestions and recommendations to you about goods or services that may be of interest to you

Necessary for our legitimate interests (to develop our products/services and grow our business)

(a) Identity 
(b) Contact 
(c) Financial

If you have subscribed to the Virtual Retirement Community, to provide you with the relevant services that you request

Performance of a contract with you

4.3    Marketing 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can update your preferences about how you wish to hear from us, or let us know that you do not wish to receive any marketing, at any time by contacting us at 

4.4    Promotional offers from us 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). 

You will receive marketing communications from us if you have requested information from us and, in each case, you have not opted out of receiving that marketing.

4.5    Third-party marketing 

We will get your express opt-in consent before we share your personal data with any company for marketing purposes. 

4.6    Opting out

You can ask us or third parties to stop sending you marketing messages by contacting us at any time. 

4.7    Cookies

Cookies are small files which are stored on a user’s computer. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. Our website only uses a third-party cookie from Vimeo, the video-sharing website which allows you to watch videos on  Vimeo is responsible for setting out its own privacy policy and explaining the function of cookies it uses. 

4.8    Change of purpose 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5    Disclosures of your personal data (Cheer app only)

5.1    We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

5.1.1    Specific charities, or other organisations, where: 

(a)    You have requested services – we will share your service request with the relevant charity/organisation for the purpose of providing you with the requested service and/or for the purpose of improving the delivery of service; or;  

(b)    You have signed up to attend an event run by a Charity/organisation, we will share your details with that charity/organisation for the purposes of managing that event; or

(c)    You are participating in a trial of Cheer. In this case, we will share some of your personal data with Age UK.

5.1.2    Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. 

5.2    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6    International data transfers

6.1    We do not transfer your personal data outside the European Economic Area (EEA).

7    Data security

7.1    We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

7.2    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8    Data retention

8.1    How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

9    Your legal rights

9.1    Under certain circumstances, you have rights under data protection laws in relation to your personal data. The various rights afforded to you are listed in paragraph 10.3. If you wish to exercise any of them, please contact us. 

9.2    No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

9.3    What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

9.4    Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

10    Glossary

10.1    Lawful Basis

10.1.1    Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

10.1.2    Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

10.1.3    Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

10.2    Third Parties

10.2.1    External Third Parties

(a)    Service providers acting as processors who provide IT and system administration services.

(b)    Professional advisers including lawyers, bankers, auditors and insurers.

(c)    HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.

10.3    Your Legal Rights

You have the right to:

10.3.1    Request access to your personal data (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

10.3.2    Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

10.3.3    Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 

10.3.4    Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

10.3.5    Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

10.3.6    Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 

10.3.7    Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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