Privacy Policy


Gesture Group Ltd (we, us, our) is committed to protecting your privacy and personal information. This Privacy Policy (Privacy Policy) details the steps we take to protect your personal information when you access our service (Gesture) and use it to redeem items (gestures) from one of our business partners. It describes the personal information that we collect, the purposes for which we use such information, your choices regarding our use of it, the steps we take to protect your personal information and how you can review and correct your personal information. By accessing and using the Gesture, you are consenting to the information collection and use practices described in this Privacy Policy. We reserve the right to modify this Privacy Policy at any time and the version that will apply to your access to and use of the Gesture will be the version that is current and displayed on the Gesture Group website on the date on which you access it, so please ensure that you check this page periodically for any updates. This Privacy Policy was last updated in May 2018.

If you have questions regarding this policy or our handling of your personal information, please email us at [email protected]

Our legal status under UK data protection law is that of a data controller, and in this capacity we will securely store and process your personal information which you have provided to us. Data controller is a legal term used in the Data Protection Act 1998 (the Act) to signify the person who controls what to do with any given personal information. As data controller we have registered with the Information Commissioner’s Office and our registration number is ZA307444.


By accessing and using the Gesture you agree that this Privacy Policy will apply. The personal information we collect about you may include:

  • your first and last names;
  • your date of birth;
  • your email post code;
  • your mobile phone number;
  • your gender;
  • details of your contacts;
  • your charity preferences;
  • metadata relating to any feedback you send via Gesture; and
  • the content of any feedback you send via Gesture.

This information may be collected by us or on our behalf by our third-party partners from time to time. You are not required to provide any of this information but, if you do not, we may not be able to provide your services.

How is your personal information used?

We will use the personal information you provide to us to:

  • notify you that our app is enabled for you to download;
  • enable you to download our app;
  • provide you with our services which you have signed up for;
  • provide occasional updates, including marketing messages from us;
  • provide personalized communications from us;
  • enable you to receive gestures;
  • identify you in online/offline communications;
  • better understand how you interact with and use the Gesture; and
  • develop our offering and the layout of Gesture to ensure that our services are as useful and enjoyable as possible.


We will never sell, trade, or rent your personal information to others without the users consent, however we may share your information with selected third parties including:

  • advertisers and advertising networks that require the data to select and serve adverts about our services to you and others. It will only be passed to third party advertisers in order to provide services on our own behalf; and
  • third party data, service and software providers that assist us in the function, improvement and optimisation of our applications.

The platform allows for users to give permission to be contacted by email by charities and businesses they select. In this incidence name, email address and demographic data only will be share with the selected third party for the purposes of direct communication between the business and/or charity and you the User. We will not pass on your post code, date of birth or phone number.

We may also disclose depersonalised data (such as aggregated statistics) about the users of Gesture to our business partners in order to help them improve their services for users. Depersonalised data in the form of statistics may also be used in order to describe our sales, customers, traffic patterns and other information to prospective partners, advertisers, investors and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifying information.

We may occasionally be required by law, court order or governmental authority to disclose certain types of personal information. Examples of the type of situation where this would occur are:

  • in the administration of justice; and
  • where we have to defend ourselves legally.

Finally, in the event of a reorganisation, sale or takeover we may need to disclose personal information.


We will retain your personal information for so long as you are registered with Gesture and for up to 6 years thereafter. Where such personal information is no longer necessary we may delete it sooner.

The requirements of data protection law

We regard the lawful and correct treatment of your personal information by us as very important to our successful operation, and to maintaining confidence between us and our users. We ensure that our organisation treats personal information lawfully and correctly. To this end we fully endorse and adhere to the ‘Data Protection Principles’ set out in the Act. In particular, without your consent or first amending this Privacy Policy to reflect any change in our usage of personal information:

  • we will not use your personal information for any purpose that is incompatible with this Privacy Policy;
  • we will only collect sufficient personal information for the uses set out above;
  • we will endeavour to keep your personal information up-to-date;
  • we will not retain your personal information longer than necessary unless required to do so by law;
  • we will operate appropriate technical and organisational processes to protect your personal information against unauthorised or unlawful access or processing and against accidental loss or destruction. The detailed measures we take are described elsewhere in this Privacy Policy; and
  • we will not transfer your personal information outside the European Economic Area unless safeguards are in place to protect your personal information to the standards that apply within the EEA.


We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorised access, use, or disclosure. For example, we procure the storage of personal information you provide on cloud storage facilities, access to which is limited using password protection.


You have the following rights in relation to your personal data:

  • a right of access to a copy of the information comprised in your personal data;
  • a right to object to processing that is likely to cause or is causing damage or distress;
  • a right to object to decisions being taken by automated means;
  • a right in certain circumstances to have inaccurate personal data rectified, blocked, erased or destroyed; and
  • a right to claim compensation for damages caused by a breach of the Data Protection Act.

If you are unsure about your rights or are concerned about how your personal data may be processed you should contact the Information Commissioner’s Office.

If you contact us in relation to your rights we will do our best to accommodate your request or objection. Please note, however, that not all rights are absolute.

Please send us an email at [email protected] if you would have any queries about, or would like to enforce, your rights set out above.


You can review and correct personal information provided to Gesture by going to your Profile page on the App and altering the information. In all cases, you can make a subject access request to review your personal information collected via Gesture or ask us to stop using it by sending us an email at [email protected]. We may take steps to verify your identity before providing you access to your personal information and may request a small administrative fee. You can help us to maintain the accuracy of your information by notifying us of any change.


We do not knowingly collect information from children and do not target or direct our site to children. Where we do collect information from children we will ensure that all processing and information provided is appropriate to the age of the child.


Cookies are small files that websites save to your hard disk or to your browser’s memory. You have the ability to accept or decline cookies. Most Internet browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies or to notify you when a cookie is being placed on your computer. If you choose to decline cookies, you may not be able to fully experience the features of Gesture or other websites that you visit and apps that you use. To learn more about cookies and how to disable them we recommend you visit the Information Commissioner’s website here.

Promotional cookies collect information about your browsing in order to deliver promotions relevant to you and your interests as well as your IP address in order to determine your geographic location and for fraud filtering. They are usually placed by third party advertising networks. They remember that you have visited a website and this information is shared with other organisations such as media publishers.

These organisations do this in order to provide you with targeted adverts more relevant to you and your interests. This type of advertising can include targeting you based on what pages of our applications you have visited and online behavioural advertising based on your browsing history.

We may from time to time use this type of cookie on our applications to deliver promotions relevant to you. Promotional cookies may also be used to limit the number of times you see a promotion as well as help measure the effectiveness of the promotion.

When we send you an email, we may track whether you have opened that email and whether you have clicked any links it may contain. This helps us measure and improve the performance of our email campaigns.

Our applications use Google Analytics, a web analytics service provided by Google, Inc. (‘Google’). The cookies used by Google Analytics are third party cookies referred to above, and help our applications analyse how you use them. The information generated by the cookie about your use of our applications (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information to provide us with reports on application activity and other services relating to application activity. For more information about how Google uses your data please see Google’s Privacy & Terms.

You can withdraw your consent to us using Google Analytics at any time. If you wish to do so, please send us an email at [email protected].

Social Sharing Cookies provide you with additional functionality to share content from our applications to social media websites and email using the social media widgets or buttons found on our applications. Use of these widgets or buttons may place a cookie on your device to make their service easier to use and to ensure your interaction is displayed on webpages (e.g. the social share count cache is updated). We encourage you to review each provider’s privacy information before using any such service.

The cookies we use, including analytics cookies, are used solely in relation to the provision of Gesture and so as to better understand how you interact with Gesture. They allow us to:

monitor the number of people using our websites and applications and monitor their activities;

  • see how people arrive at our website and applications;
  • gather technical information about people using our websites and applications, such as their geographic location and the type of web browsers they are using; and
  • display adverts on other websites and applications, to people who have previously accessed our websites and applications. We cannot identify individuals to whom adverts may be displayed.

By using the Gesture you consent to us using the above cookies.