Privacy Notice
Last Updated: January 2026 | Company Number: 16947492
1. Who We Are
Graham is a co-parenting coordination service that helps separated and divorced parents manage shared responsibilities for their children.
Data Controller: JEFFREY TECHNOLOGIES LTD (trading as Graham)
Company Number: 16947492
Contact: privacy@grahamapp.co.uk
2. What Information We Collect
Information You Provide
- Account Information: Phone number, name, timezone
- Children's Information: Names, dates of birth (for scheduling)
- Custody Schedules: Patterns, dates, arrangements
- Financial Information: Expenses, support payments
- Communications: Messages to Graham, voice notes
Information Collected Automatically
- Usage data (features accessed, timestamps)
- Device information (browser, operating system)
- Technical logs (for security and debugging)
3. How We Use Your Information
| Purpose | Lawful Basis |
|---|---|
| Providing the service | Contract |
| Processing messages | Contract |
| Coordinating with co-parent | Contract |
| Service improvement | Legitimate Interest |
| Security | Legitimate Interest |
| Analytics (if enabled) | Consent |
4. Children's Data
We recognise that children's data requires enhanced protection. We comply with the UK Age Appropriate Design Code (Children's Code).
- We only collect children's names and dates of birth
- We do not collect photos, location, or behavioural data from children
- We do not profile children or use their data for AI training
- Children's data is only shared between verified co-parents
5. Who We Share Your Data With
Your Co-Parent
When you join a couple, your co-parent can see shared data including:
- Custody schedules
- Expenses you submit
- Children's information
Your co-parent cannot see your private messages to Graham.
Service Providers
We use trusted third-party services:
- Supabase (EU) - Database hosting
- Anthropic (USA) - AI message processing
- OpenAI (USA) - Voice transcription
- Meta/WhatsApp (USA) - Messaging platform
6. International Data Transfers
Some service providers are based outside the UK. We ensure appropriate safeguards through Standard Contractual Clauses (SCCs) and Data Processing Agreements.
7. How Long We Keep Your Data
| Data Type | Retention |
|---|---|
| Account data | Duration of account + 30 days |
| Children's data | Until removed or account deleted |
| Custody schedules | Account duration + 1 year |
| Expenses | 7 years (tax requirements) |
| Conversation logs | 2 years |
8. Your Rights
Under UK GDPR, you have the right to:
- Access: Request a copy of your data
- Rectification: Correct inaccurate data
- Erasure: Request deletion of your data
- Restriction: Limit how we process your data
- Portability: Receive your data in machine-readable format
- Object: Object to certain processing
To exercise any of these rights, contact privacy@grahamapp.co.uk or message Graham on WhatsApp.
9. AI and Automated Processing
Graham uses AI to process your messages and provide coordination assistance.
- AI parses your messages to understand intent
- AI generates helpful responses and suggestions
- AI does not make decisions with legal effects
- You can request human review of any AI decision
10. Cookies
Our website uses cookies. For details, see our Cookie Policy.
11. Contact and Complaints
For privacy questions: privacy@grahamapp.co.uk
To complain to the regulator:
Information Commissioner's Office (ICO)
ico.org.uk/make-a-complaint
Phone: 0303 123 1113
12. Changes to This Notice
We may update this privacy notice. Significant changes will be communicated via in-app notification or WhatsApp message.