Privacy Policy

Updated:

Oct 6, 2025

Effective Date: October 6, 2025

1. Introduction

Cheers (operated by Cheers Reviews Inc, "we," "us," or "our") provides a Generative Engine Optimization (GEO) platform. We help service businesses enhance their online reputation and visibility on AI assistants by turning frontline employees into a reputation engine.

This Privacy Policy describes how we collect, use, disclose, and protect information in connection with our website (https://www.cheers.tech), our GEO platform, mobile tools, and related services (collectively, the "Services").

2. Our Role: Data Controller vs. Data Processor

Data protection laws distinguish between a "Data Controller" (who determines the purposes and means of processing personal data) and a "Data Processor" (who processes data on behalf of the Controller).

  • Data Controller: Cheers is the Data Controller for information we collect directly from visitors to our website ("Visitors") and from the administrative users of our business customers ("Clients") (e.g., when managing Client accounts or marketing our Services).


  • Data Processor (Service Provider): Cheers is the Data Processor (or Service Provider under laws like the CCPA) for data collected by our Clients using our platform ("Service Data"). This includes information about our Clients’ employees ("Frontline Users") and the individuals who interact with those employees (the "End-Customers," such as people leaving reviews). In this capacity, we process Service Data strictly on behalf of our Clients and according to their instructions.

If you are a Frontline User or End-Customer, the business you work for or interacted with is the Data Controller of your information. Please direct any privacy-related inquiries to them.

3. Information We Collect

We collect various types of information to provide and improve our Services.

A. Information We Collect as Data Controller

We collect the following information from Clients and Visitors:

  • Account and Registration Information: Company name, administrator names, work email addresses, phone numbers, job titles, and login credentials.

  • Billing and Payment Information: Billing details and financial information. Payment card information is collected and processed directly by our secure third-party payment processors.

  • Communications: Information provided when you request a demo, contact customer support, subscribe to newsletters, or otherwise communicate with us.

B. Information Collected Automatically (as Data Controller)

When you visit our website or use our administrative platform, we automatically collect:

  • Log and Usage Data: IP addresses, access dates and times, pages viewed, features used, links clicked, and the page you visited before navigating to our Services.

  • Device Information: Browser type, operating system, hardware model, and unique device identifiers.

  • Cookies and Tracking Technologies: We use cookies and similar technologies to analyze trends, administer the Services, and gather demographic information. (See Section 6).


C. Information Processed on Behalf of Clients (as Data Processor)

We process the following Service Data on behalf of our Clients:

  • Frontline User Information: To enable attribution, Clients provide us with information about their Frontline Users, including names, employee IDs, work contact information (email or phone), and location/branch affiliation.

  • Performance and Attribution Data: Data generated through the use of our tools (NFC taps, links, flows), including the volume of reviews generated, tips received, and referrals collected. This data is tied to specific Frontline Users.

  • End-Customer Feedback and Content: Reviews, ratings, comments, social proof (e.g., photos at the point of service), tip amounts, and any contact information provided by End-Customers during the feedback process.

D. Information from Third Parties

  • Public Reputation Data: As part of our GEO analysis, we collect publicly available information about our Clients' online reputation, including reviews, citations, and evidence (e.g., badges, certifications) from third-party platforms (e.g., Google, industry sites, social media).

  • Integrations: If a Client integrates Cheers with other business software (e.g., CRM), we may receive information from those services as necessary to perform the integration.

4. How We Use Information

4.1. Use of Information as Data Controller

We use the information we control to:

  • Manage Accounts and Billing: Process registrations, manage billing, and administer Client accounts.

  • Communicate: Respond to inquiries, send administrative updates, security alerts, and provide customer support.

  • Marketing and Promotion: Send promotional communications about new features, GEO insights, or events. You can opt-out of these at any time.

  • Improve Our Services: Analyze usage trends, conduct research, and develop new features for the Cheers platform.

  • Security and Compliance: Protect the security and integrity of our Services, prevent fraud, and comply with legal obligations.

4.2. Use of Service Data as Data Processor

We use Service Data strictly in accordance with our Clients’ instructions to:

  • Provide the Services: Enable the capture of reviews, referrals, tips, and social proof.

  • Attribute Outcomes: Link feedback and outcomes to the specific Frontline User and location that generated them.

  • Generate Analytics: Provide Clients with insights into employee performance and reputation management so they can coach, reward, and scale what works.


5. How We Share and Disclose Information

We do not sell your personal information. We may share information in the following circumstances:

  • With Our Clients: We share Service Data (Frontline User performance, attribution data, and End-Customer feedback) with the respective Client on whose behalf the information was collected.

  • With Service Providers: We engage third-party providers to support our business (e.g., cloud hosting, database management, payment processing, analytics). These providers are authorized to use the information only as necessary to provide these services to us.

  • Third-Party Platforms: When an End-Customer provides a review via Cheers, they may be directed to post that review on public third-party platforms (e.g., Google Maps) according to the strategy defined by the Client.

  • Legal Requirements: We may disclose information if we reasonably believe disclosure is required by applicable law, regulation, legal process, or governmental request (e.g., a subpoena or court order).

  • Business Transfers: If Cheers engages in a merger, acquisition, or sale of assets, information may be transferred as part of that transaction, subject to standard confidentiality arrangements.

  • With Consent: We may share information with other third parties when we have explicit consent to do so.

6. Cookies and Tracking Technologies

We use cookies, pixel tags, and similar technologies on our website and platform.

  • Essential Cookies: Necessary for the Services to function (e.g., authentication).

  • Analytics Cookies: Help us understand how users interact with our Services.

  • Advertising Cookies: We may use third-party advertising partners to manage our advertising on other sites.

You can control the use of cookies through your browser settings. However, disabling certain cookies may limit the functionality of our Services.

7. Data Security and Retention

Security: We implement industry-standard technical and organizational measures designed to protect the security of the personal information we process. This includes encryption, access controls, and regular security assessments. However, no method of electronic transmission or storage is 100% secure.

Retention:

  • Data Controlled by Cheers: We retain this information for as long as the Client account is active or as needed to provide Services, comply with legal obligations (e.g., tax or accounting), resolve disputes, and enforce agreements.

  • Service Data (Processed for Clients): We retain Service Data according to the terms of our agreement with the Client and their instructions, and we delete it upon the Client's request or termination of the agreement, subject to legal requirements.

8. Your Rights and Choices

You have certain rights regarding your personal information, subject to local data protection laws.

  • Marketing Opt-Out: You can opt-out of receiving promotional communications from Cheers by following the unsubscribe instructions in those communications. We will still send you non-promotional, service-related communications.

  • Access, Correction, and Deletion: You may request access to, correction of, or deletion of your personal information.

How to Exercise Your Rights:

  • Clients and Visitors: Please contact us using the information in Section 13 to exercise your rights regarding data for which Cheers is the Controller.

  • Frontline Users and End-Customers: If your information is part of the Service Data processed on behalf of a Client, you must contact the Client (the business/employer) directly to exercise your rights. As a Processor, we will assist our Clients in responding to these requests as required by law.

9. California Privacy Rights (CCPA/CPRA)

If you are a resident of California, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides you with specific rights regarding data for which we are the "Business" (Controller).

  • Information Collected: In the preceding 12 months, we have collected the following categories of personal information: Identifiers (e.g., name, email, IP address), Commercial Information (e.g., purchase history), Internet or Other Electronic Network Activity Information (e.g., usage data), Geolocation Data (approximate location based on IP), and Professional or Employment-Related Information (e.g., job title).

  • Use and Disclosure: We use this information for the business purposes described in Section 4 and disclose it to the categories of third parties described in Section 5.

  • Sale or Sharing: We do not "sell" personal information in the traditional sense. However, we may "share" information (as defined by the CPRA), such as Identifiers and Internet Activity, with third-party advertising partners for cross-context behavioral advertising.

  • Your Rights: You have the right to request access to the specific pieces of personal information we have collected about you, request deletion of your personal information, request correction of inaccurate information, and opt-out of the sharing of your information.

  • Exercising Rights: You can exercise these rights by contacting us at privacy@cheers.tech or by utilizing Global Privacy Control (GPC) signals to opt-out of sharing.

10. European Economic Area (EEA), UK, and Switzerland Privacy Rights (GDPR)

If you are located in the EEA, UK, or Switzerland, you have certain rights under the General Data Protection Regulation (GDPR) or equivalent local laws regarding data for which we are the Controller.

  • Legal Bases for Processing: We process personal data based on the following legal bases:

    • Contractual Necessity: To fulfill our contract with our Clients.

    • Legitimate Interests: For purposes such as R&D, marketing (where consent is not required), security, and improving our Services, provided these interests do not override your fundamental rights and freedoms.

    • Consent: When you provide explicit consent (e.g., for certain cookies or marketing).

    • Legal Obligation: When processing is necessary to comply with the law.

  • Your Rights: You have the right to access, rectify, erase, restrict processing, object to processing, the right to data portability, and the right to lodge a complaint with a supervisory authority.

11. International Data Transfers

Cheers is based in the United States. Your personal information may be transferred to, processed, and stored in the United States and other countries where our service providers operate. These countries may have data protection laws different from those of your country. We ensure that international transfers of personal data are protected by appropriate safeguards, such as the European Commission’s Standard Contractual Clauses or other approved mechanisms, where required by law.

12. Children's Privacy

Our Services are intended for businesses and are not directed to individuals under the age of 16. We do not knowingly collect personal information from children under 16. If we become aware that we have collected such information, we will take steps to delete it.

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will post the changes to this page and update the "Effective Date." If we make material changes, we will provide additional notice, such as via email or through the Services.

14. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at:

Cheers, Cheers Reviews Inc.
1395 22nd Street, Unit 643, San Francisco, CA 94107
Email: info@cheers.tech