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

PurposeLawful Basis
Providing the serviceContract
Processing messagesContract
Coordinating with co-parentContract
Service improvementLegitimate Interest
SecurityLegitimate 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 TypeRetention
Account dataDuration of account + 30 days
Children's dataUntil removed or account deleted
Custody schedulesAccount duration + 1 year
Expenses7 years (tax requirements)
Conversation logs2 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.

Need Help?

If you have any questions about this privacy notice or how we handle your data, please don't hesitate to contact us at privacy@grahamapp.co.uk.