Guardian Jem Trust Centre
Trust Built Into Every Connection.
Guardian Jem is built to protect both people and information. Explore how we manage privacy, security, safeguarding, data protection, and responsible platform governance.
Our Trust Commitments
Built around transparency, responsible protection, and safeguarding-first design.
We do not sell, rent, or commercially trade personal information.
Responsible Data Use
You control permissions, connected access, and privacy settings at all times.
Privacy Controls
Data is protected using secure transmission, controlled access, and appropriate safeguards.
Data Security
Information is used to support safeguarding, service functionality, and protection improvements.
Safeguarding Purpose
Trust Centre
Explore how Guardian Jem manages privacy, security, safeguarding responsibilities, and data protection across our services.
1 | Introduction
Our Privacy Commitment
Guardian Jem Limited is committed to protecting your personal information and respecting your privacy.
This Privacy Policy explains what information we collect, how we use it, why we collect it, who we share it with, how long we keep it, and the rights you have over your data.
Guardian Jem is built around safeguarding, trust, and responsible technology. Because our services may involve families, guardians, vulnerable individuals, and organisations, we take privacy and data security seriously.
This Privacy Policy applies to:
- Our website
- Our mobile applications
- Guardian Jem services
- Connected wearable products
- Business and organisational platform services
- Customer support interactions
- Marketing communications where consent has been provided
Guardian Jem Limited is the data controller for the personal information described in this policy unless otherwise stated.
Who We Are
Guardian Jem Limited
Company Number: 16996297
United Kingdom
Contact us: hello@guardianjem.com
If you have questions about privacy, data handling, or your personal information, you can contact us using the details above.
Who This Policy Applies To
This Privacy Policy applies to:
- Parents
- Guardians
- Family members
- App users
- Business customers
- Schools
- Childcare providers
- Care providers
- Hospitality operators
- Venue operators
- Organisational administrators
- Website visitors
- Individuals connected through Guardian Jem safeguarding environments
Some services involve users who may be children or vulnerable individuals. Additional safeguards apply where required by law.
Key Definitions
"Guardian" refers to an individual responsible for monitoring or safeguarding another connected person.
"Jem" refers to an individual connected within the Guardian Jem safeguarding ecosystem.
"Personal Data" means information that identifies or can identify a living individual.
"Special Category Data" means sensitive personal data that receives additional legal protection under UK GDPR.
"Processing" means collecting, storing, using, analysing, sharing, or deleting personal information.
"Data Controller" means the organisation that decides why and how personal data is processed.
"Data Processor" means a third party that processes data on behalf of a controller.
"Organisation Account" means a Guardian Jem account operated by a business, institution, or organisational customer.
"Connected Device" means a mobile phone, wearable, accessory, or authorised technology linked to Guardian Jem services.
"Safeguarding Event" means an event, alert, separation, escalation, status change, or connected safeguarding trigger generated through Guardian Jem services.
2 | Information We Collect
Information You Provide Directly
We collect personal information you provide when using Guardian Jem services.
This may include:
- Account Information
- Full name
- Email address
- Mobile telephone number
- Password credentials (stored securely in encrypted form)
- Account role (e.g. parent, guardian, business administrator)
Profile Information
- Profile name
- Relationship role (e.g. parent, guardian, carer)
- Connected user details
- Optional profile images
Support & Contact Information
- Customer support enquiries
- Contact form submissions
- Demo requests
- Business enquiry submissions
- Feedback submissions
- Complaint information
Business Account Information
- Where organisations use Guardian Jem, we may collect:
- Organisation name
- Business email address
- Job title
- Contact telephone number
- Organisation account administrator details
- Billing contact details
Information Collected Automatically
When you use our website, app, or connected services, certain technical information is collected automatically.
This may include:
Device & Technical Information
- Device type
- Operating system
- Browser type
- App version
- Device identifiers
- Mobile device model
- IP address
- Network connection details
- Language settings
- Time zone settings
- Diagnostic logs
- Crash reports
- Performance telemetry
Usage Information
- Pages viewed
- Features used
- Session activity
- App interactions
- Navigation behaviour
- Click activity
- Referral source information
- Date and time access logs
This helps us maintain service security, reliability, performance, and product functionality.
Location & Safeguarding Data
Guardian Jem’s safeguarding functionality may rely on location and proximity-based information.
Depending on permissions and product functionality, we may collect:
- GPS location data
- Approximate location data
- Bluetooth proximity signals
- Connected device movement indicators
- Separation detection events
- Safeguarding alert triggers
- Escalation event timestamps
- Guardian acknowledgement actions
- Safety status updates
- Incident resolution records
Location-related processing only occurs where required for the relevant safeguarding service functionality.
Connected Device & Wearable Data
Where Guardian Jem connected hardware or wearable services are used, additional operational information may be processed.
This may include:
- Device identifiers
- Device pairing records
- Connection health data
- Signal strength indicators
- Battery status
- Device status information
- Firmware version information
- Connection event logs
- Device sync records
- Device alert events
This data supports connected safeguarding functionality, device performance, and service integrity.
Information From Third Parties
We may receive personal information from trusted third-party providers where necessary to operate Guardian Jem services.
Examples may include:
- Payment providers
- Authentication providers
- Cloud hosting providers
- Customer support platforms
- Analytics providers
- Business software integrations
- Organisational account administrators
We only process third-party information where there is a lawful basis to do so.
Sensitive Information
Some Guardian Jem safeguarding use cases may involve information requiring additional legal protection.
This may include:
- Vulnerability-related safeguarding context
- Accessibility-related support information
- Incident context where safeguarding intervention is required
We only process sensitive personal information where lawful, necessary, and appropriately protected.
Information We Dd Not Collect
Guardian Jem does not intentionally collect unnecessary personal information.
We do not knowingly collect:
- Unrelated personal data
- Excessive information beyond service needs
- Sensitive personal information without lawful basis
- Children’s personal information outside authorised safeguarding use
3 | How Information Is Collected
App Permissions & Device Access
Guardian Jem services may request access to certain device permissions where necessary for core safeguarding functionality.
This may include:
- Location services
- Bluetooth access
- Push notifications
- Camera access (where relevant)
- Microphone access (where relevant)
- Background activity permissions
- Device connectivity permissions
Permissions are only requested where necessary for service functionality.
Users remain responsible for managing device-level permission settings.
Disabling certain permissions may limit or prevent service functionality.
Automatic Technology Collection
Some information is collected automatically when you interact with our website, applications, or connected services.
Collection methods may include:
- App telemetry
- Device event logging
- Browser technologies
- Session tracking
- Error monitoring systems
- Diagnostic reporting tools
- Performance monitoring services
- API interactions
- Security monitoring tools
This supports:
- Service reliability
- Performance improvement
- Threat detection
- Technical troubleshooting
- Product security
- Service continuity
Cookies & Similar Technologies
Our website uses cookies and similar technologies to collect technical and usage information.
These technologies help us:
- Maintain website functionality
- Manage user sessions
- Improve performance
- Understand visitor behaviour
- Measure traffic sources
- Support communications preferences
- Detect abuse or suspicious activity
Non-essential cookies are managed through user consent mechanisms where required.
Further details are provided in our Cookie Policy.
Connected Wearables & Linked Devices
Where connected wearable products or Guardian Jem hardware are used, data may be collected through linked technology interactions.
Collection methods may include:
- Bluetooth pairing
- Device handshake authentication
- Connectivity monitoring
- Signal event detection
- Device synchronisation
- Safety event triggers
- Firmware/device communication processes
This information supports active safeguarding functionality and connected service delivery.
Business & Organisation Setup
Where businesses or organisations use Guardian Jem services, information may be collected during onboarding, account configuration, or service administration.
This may include:
- Organisational registration information
- Administrative account setup
- User provisioning
- Team access configuration
- Billing setup
- Business support interactions
- Service deployment processes
Organisation administrators may also provide user information where authorised to do so.
Third-Party Service Integrations
Guardian Jem may collect information through approved third-party technology providers that support service delivery.
Examples include:
- Cloud infrastructure providers
- Payment processors
- Authentication services
- Analytics platforms
- Customer communication platforms
- Customer support systems
- Security monitoring services
These providers operate under contractual, legal, and security controls.
Safeguarding Events & Platform Activity
Certain information is generated as part of Guardian Jem service operation.
This includes events created through system use such as:
- Status changes
- Connectivity events
- Alert acknowledgements
- Escalation actions
- Safety confirmations
- Guardian responses
- Incident activity records
- Administrative safeguarding actions
This operational data forms part of the safeguarding service functionality.
Information Provided By Others
In some cases, information may be provided by another authorised individual.
Examples include:
- A parent adding a child profile
- A guardian adding a connected family member
- A business administrator registering authorised users
- An organisation setting up a managed safeguarding environment
Where this occurs, the person providing the information must have lawful authority to do so.
4 | How We Use Your Information
Delivering Guardian Jem Services
We use personal information to provide and operate Guardian Jem services.
This includes:
- Creating and managing user accounts
- Connecting guardians and authorised users
- Enabling safeguarding functionality
- Supporting active monitoring services
- Detecting relevant safety-related events
- Generating alerts and notifications
- Managing safeguarding escalations
- Recording safety acknowledgements
- Supporting incident resolution workflows
- Maintaining connected profile relationships
- Delivering business safeguarding services
Without this processing, core Guardian Jem services cannot function.
Safeguarding & Safety Protection
Guardian Jem is designed to support safeguarding and responsible safety oversight.
We use information to:
- Detect separation events
- Monitor connected safeguarding conditions
- Trigger safeguarding alerts
- Verify user safety states
- Support guardian intervention
- Enable escalation workflows
- Maintain incident histories
- Support responsible response management
- Reduce safeguarding blind spots
This processing forms part of the core purpose of Guardian Jem.
Service Operations & Platform Performance
We use information to maintain, improve, and operate our services.
This includes:
- Monitoring platform performance
- Diagnosing technical issues
- Preventing service disruption
- Managing software updates
- Supporting connected device performance
- Improving reliability
- Testing system integrity
- Monitoring operational health
- Maintaining product functionality
Security & Fraud Prevention
We use information to protect our systems, users, and services.
This includes:
- Identity verification
- Authentication management
- Account protection
- Threat monitoring
- Abuse detection
- Fraud prevention
- Unauthorised access prevention
- Security investigations
- System integrity monitoring
- Incident response
Protecting users and safeguarding services requires active security monitoring.
Customer Support & Communications
We use information to communicate with users and provide support.
This includes:
- Responding to enquiries
- Handling customer support requests
- Resolving technical issues
- Managing complaints
- Sending service-related updates
- Delivering important account communications
- Responding to business enquiries
- Supporting onboarding processes
These communications are necessary for service delivery.
Business Operations & Administration
We use information for legitimate operational management.
This includes:
- Account administration
- Subscription management
- Billing administration
- Payment processing coordination
- Service management
- Organisational account administration
- Audit management
- Internal reporting
- Legal recordkeeping
Analytics & Product Improvement
We use certain technical and usage information to improve Guardian Jem.
This includes:
- Understanding product usage
- Measuring feature performance
- Identifying service issues
- Improving usability
- Enhancing safeguarding workflows
- Optimising user experience
- Supporting future product development
Analytics processing is managed in accordance with applicable consent and privacy requirements.
Marketing Communications
Where legally permitted or where consent has been provided, we may use information to send:
- Product updates
- Service announcements
- Launch communications
- Promotional messages
- Business service updates
- Relevant company communications
Users can opt out of marketing communications at any time.
Service-critical communications cannot be opted out of where necessary.
Legal, Regulatory & Compliance Obligations
We may use information where required to:
- Comply with legal obligations
- Respond to lawful regulatory requests
- Support law enforcement obligations
- Protect legal rights
- Defend legal claims
- Enforce contractual rights
- Meet compliance requirements
- Support safeguarding-related legal responsibilities
5 | Legal Bases For Processing
Our Legal Basis For Processig Personal Information
Under UK data protection law, Guardian Jem must have a lawful basis for processing personal information.
Depending on the service, we rely on one or more of the following legal bases:
- Contractual necessity
- Legitimate interests
- Legal obligation
- Consent
- Protection of vital interests
- Additional lawful conditions where sensitive data is involved
The legal basis depends on the purpose of the processing and the nature of the service being used.
Contractual Necessity
We process personal information where necessary to provide the services you request or to fulfil our contractual obligations.
This includes:
- Creating and managing accounts
- Delivering app functionality
- Connecting guardians and users
- Enabling safeguarding services
- Managing subscriptions
- Supporting connected wearable services
- Delivering business platform services
- Providing customer support linked to contracted services
Without this processing, Guardian Jem cannot provide the requested service.
Legitimate Interests
We process certain personal information where this is necessary for our legitimate business interests, provided those interests do not override your rights and freedoms.
This includes:
- Service security
- Fraud prevention
- Platform monitoring
- Technical diagnostics
- Product improvement
- Service administration
- Operational reporting
- Business continuity
- Customer service management
- Safeguarding service optimisation
Where legitimate interests are relied upon, we assess necessity, proportionality, and privacy impact.
Consent
Where required by law, we rely on your consent.
This may include:
- Marketing communications
- Non-essential cookies
- Optional product features requiring permission
- Certain device permissions
- Specific optional communications preferences
Consent can be withdrawn at any time.
Withdrawal does not affect processing already carried out lawfully.
Legal Obligations
We process personal information where required to comply with legal or regulatory obligations.
This may include:
- Regulatory compliance
- Financial recordkeeping
- Tax obligations
- Law enforcement requests
- Legal disclosure requirements
- Fraud investigations
- Compliance monitoring
- Safeguarding-related obligations where legally applicable
Protection Of Vital Interests
In limited circumstances, we may process personal information where necessary to protect an individual’s vital interests.
This may apply where processing is necessary to help protect life, health, safety, or immediate wellbeing.
This basis would only be used where genuinely appropriate.
Sensitive Personal Information
Where Guardian Jem processes sensitive personal information (also known as special category data), additional legal conditions are required.
Where applicable, processing may occur because:
- Explicit consent has been provided
- Processing is necessary for safeguarding-related purposes where legally permitted
- Processing is necessary to protect vital interests
- Processing is otherwise permitted under applicable law
Additional safeguards apply to this category of information.
Children's Information
Where personal information relates to children, Guardian Jem applies additional legal safeguards.
Processing involving children will only occur where there is an appropriate lawful basis and authorised responsibility for that processing.
We take heightened care where children’s data is involved.
Business Organisational Accounts
Where Guardian Jem services are used by organisations, the legal basis may vary depending on the service structure.
In some cases:
- Guardian Jem acts as a data controller
- The organisation acts as a data controller
- Guardian Jem acts as a data processor on behalf of the organisation
The applicable legal responsibilities will depend on the service arrangement.
6 | Who We Share Information With
Our Approach To Data Sharing
Guardian Jem does not sell personal information.
We only share personal information where this is necessary to:
- Deliver Guardian Jem services
- Support safeguarding functionality
- Operate our platform
- Meet legal obligations
- Protect users, systems, or services
- Process payments
- Support authorised business services
All third-party sharing is subject to contractual, legal, operational, or security controls where required.
Service Providers & Technology Partners
We share personal information with trusted service providers that support Guardian Jem operations.
This may include providers supporting:
- Cloud hosting infrastructure
- Application hosting
- Database services
- Payment processing
- Identity authentication
- Email delivery
- Customer communications
- Customer support systems
- Analytics platforms
- Security monitoring
- Performance diagnostics
- Infrastructure management
- Device connectivity services
- Push notification delivery
These providers only receive information necessary to perform their services.
Payment Providers
Where paid services are used, payment-related information is processed through authorised payment providers.
This may include:
- Billing details
- Transaction identifiers
- Subscription records
- Payment status information
Guardian Jem does not store full payment card details where secure third-party payment infrastructure is used.
Business & Organisational Customers
Where Guardian Jem services are used through a business, organisation, or managed safeguarding environment, relevant information may be visible to authorised administrators.
This may include:
- User account details
- Role-based access information
- Safeguarding activity records
- Operational account activity
- Incident management information
- Administrative service records
Access is controlled according to service design and authorised account permissions.
Connected Guardians & Authorised Users
Guardian Jem is built around connected safeguarding relationships.
Relevant information may be shared between authorised connected users where required for safeguarding functionality.
This may include:
- Safety status updates
- Alert notifications
- Escalation activity
- Connected safeguarding events
- Guardian acknowledgements
- Resolution actions
Only authorised connected participants receive relevant safeguarding information.
Professional Advisers & Corporate Services
We may share information with professional service providers where necessary for legitimate business operations.
This may include:
- Legal advisers
- Accountants
- Auditors
- Compliance consultants
- Insurance providers
- Corporate advisers
- Business operations partners
Access is limited to legitimate operational need.
Regulators, Legal Authorities & Law Enforcement
We may disclose information where legally required or where disclosure is necessary to protect rights, safety, or legal obligations.
This may include:
- Courts
- Regulators
- Law enforcement agencies
- Government authorities
- Safeguarding authorities where applicable
- Fraud prevention bodies
Disclosures only occur where there is a lawful basis.
Corporate Transactions
If Guardian Jem undergoes:
- Investment
- Acquisition
- Merger
- Business restructuring
- Sale of assets
- Corporate reorganisation
relevant personal information may be transferred to authorised parties involved in that transaction.
Any such transfer will be subject to appropriate legal safeguards.
What We Do Not Do
Guardian Jem does not:
- Sell personal information
- Trade personal information
- Share personal information for unrelated commercial exploitation
- Permit unauthorised third-party access
- Share excessive information beyond service necessity
7 | Data Retention & Deletion
How Long We Keep Information
Guardian Jem keeps personal information only for as long as necessary to deliver services, meet legal obligations, maintain safeguarding records where appropriate, resolve disputes, protect our systems, and support legitimate business operations.
Retention periods depend on:
- The type of information
- The purpose for which it was collected
- Legal or regulatory obligations
- Security requirements
- Safeguarding operational needs
- Contractual requirements
- Dispute or investigation requirements
When information is no longer required, it is securely deleted, anonymised, or otherwise appropriately disposed of.
Account Information Retention
We retain account-related information for as long as an account remains active.
This may include:
- User profile information
- Account credentials
- Connected relationship records
- Subscription information
- Administrative account settings
- Organisational access records
Where an account is closed, certain information may be retained for a defined period where necessary for legal, fraud prevention, contractual, safeguarding, or security purposes.
Safeguarding & Operational Records
Certain safeguarding-related operational records may be retained where necessary to support service integrity, safeguarding review, incident management, dispute resolution, or legitimate audit requirements.
Examples may include:
- Alert records
- Escalation histories
- Safety acknowledgements
- Incident timelines
- Resolution logs
- Administrative safeguarding records
Retention periods will be proportionate to operational necessity and legal obligations.
Technical, Security & Diagnostic Data
Technical logs, security records, diagnostic information, and operational telemetry may be retained for limited periods to support:
- Security monitoring
- Threat detection
- Incident response
- Fraud prevention
- System integrity
- Technical troubleshooting
- Service reliability
Retention periods vary according to technical and security need.
Payment & Financial Records
Financial and transaction-related records may be retained where required for:
- Tax compliance
- Accounting obligations
- Audit requirements
- Fraud prevention
- Contractual administration
Retention periods are determined by applicable legal and regulatory requirements.
Business & Organisational Records
Where Guardian Jem services are used by organisations, certain business-related information may be retained for contractual, audit, safeguarding, compliance, and administrative purposes.
This may include:
- Organisation account records
- Administrative user records
- Billing records
- Service activity records
- Support records
- Contract-related documentation
Retention will align with contractual and legal obligations.
Marketing Data
Marketing preferences and communications records are retained only for as long as relevant to the communication purpose or until consent is withdrawn or preferences are updated.
Users can opt out of marketing communications at any time.
Deletion Requests
Where users request deletion of personal information, Guardian Jem will assess the request in line with applicable legal rights and operational obligations.
Information may be deleted, anonymised, or retained where lawful retention remains necessary.
Examples where retention may still be required:
- Legal obligations
- Fraud prevention
- Ongoing disputes
- Security investigations
- Safeguarding-related recordkeeping
- Contractual obligations
Secure Deletion
Where personal information reaches the end of its retention lifecycle, Guardian Jem applies appropriate disposal measures.
This may include:
- Secure deletion
- Access revocation
- System purge processes
- Anonymisation
- Backup lifecycle expiration
- Controlled destruction processes
8 | Your Privacy Rights
Your Privacy Rights
Under applicable data protection law, you have rights regarding your personal information.
These rights may apply depending on the nature of the information and the legal basis being relied upon.
Guardian Jem is committed to respecting these rights and responding appropriately to valid requests.
Right Of Access
You have the right to request access to the personal information Guardian Jem holds about you.
This allows you to understand:
- What information we hold
- Why we hold it
- How it is used
- Who it is shared with
- How long it is retained
- The legal basis for processing
This is commonly known as a Subject Access Request.
Right To Correction
You have the right to request correction of inaccurate or incomplete personal information.
Where information is incorrect, outdated, or incomplete, we will take appropriate steps to correct it.
Some information may also be updated directly through account settings where functionality allows.
Right To Deletion
You may request deletion of your personal information in certain circumstances.
This right is not absolute.
Guardian Jem may retain information where lawful retention remains necessary, including for:
- Legal compliance
- Fraud prevention
- Security investigations
- Safeguarding record requirements
- Contractual obligations
- Dispute resolution
Where deletion applies, information will be securely deleted or anonymised as appropriate.
Right To Restrict Processing
You may request restriction of certain processing activities in specific circumstances.
This may apply where:
- Accuracy is disputed
- Processing is being challenged
- Temporary review is required
- Legal rights need preservation
Where restriction applies, processing will be limited as required by law.
Right To Object
You may object to certain processing where Guardian Jem relies on legitimate interests.
This may apply to:
- Certain operational processing
- Direct marketing
- Specific analytics activities where applicable
We will assess objections in accordance with legal requirements.
Direct marketing objections will be respected.
Right To Data Portability
Where legally applicable, you may request a copy of certain personal information in a structured, commonly used, machine-readable format.
This right typically applies where processing is based on consent or contract and is carried out by automated means.
Right To Withdraw Consent
Where processing relies on consent, you may withdraw that consent at any time.
Examples may include:
- Marketing preferences
- Optional permissions
- Certain non-essential processing activities
Withdrawal does not affect processing already carried out lawfully before withdrawal.
Rights Relating To Automated Decision Making
Where legally applicable, you have rights relating to automated decisions that significantly affect you.
If Guardian Jem introduces processing that falls into this category, relevant protections will apply.
At present, Guardian Jem does not rely on solely automated decision-making that produces legally significant effects without appropriate safeguards.
Children & Authorised Representatives
Where personal information relates to a child or vulnerable individual, requests may need to be made by an authorised parent, guardian, organisation, or legally authorised representative.
Identity and authority verification may be required.
How To Exercise Your Rights
To exercise your privacy rights, contact:
hello@guardianjem.com
We may request information to verify identity before processing a request.
Requests will be handled in accordance with applicable legal timescales.
9 | Data Security Measures
Our Security Commitment
Guardian Jem takes the security of personal information seriously.
We apply technical, organisational, and operational safeguards designed to protect personal information against unauthorised access, loss, misuse, disclosure, alteration, or destruction.
Security controls are designed proportionately to the nature of the service, the information involved, and the associated risks.
Technical Security Controls
Guardian Jem applies technical security measures designed to protect systems and personal information.
These may include:
- Encryption in transit
- Encryption at rest where appropriate
- Secure authentication controls
- Access management controls
- Role-based access restrictions
- Session protection measures
- Secure API communication
- Infrastructure hardening
- System monitoring
- Threat detection controls
- Security patching processes
- Secure configuration management
Security controls are reviewed as services evolve.
Access Controls
Access to personal information is restricted to authorised individuals with legitimate operational need.
Access protections may include:
- Role-based permissions
- Least privilege access principles
- Administrative access restrictions
- Authentication controls
- Access review processes
- Internal security oversight
- Credential protection measures
Unauthorised access is prohibited.
Infrastructure & Hosting Security
Guardian Jem uses infrastructure and hosting environments designed with security protections appropriate to service delivery.
This may include:
- Secure hosting controls
- Network protections
- Firewall controls
- Segmentation protections
- Backup protections
- Availability safeguards
- Environment monitoring
- Secure infrastructure management
Where third-party infrastructure providers are used, security due diligence and contractual controls apply.
Monitoring & Threat Detection
To help protect users and services, Guardian Jem may operate monitoring and detection controls.
This may include:
- Security event monitoring
- Abuse detection
- Fraud monitoring
- Authentication anomaly detection
- Service integrity monitoring
- Diagnostic review
- Incident investigation support
Monitoring is proportionate to legitimate security needs.
Incident Management
Guardian Jem maintains processes for identifying, investigating, managing, and responding to security incidents.
This may include:
- Threat assessment
- Incident containment
- Technical investigation
- Risk mitigation
- Service recovery
- Legal or regulatory notification where required
Where a personal data breach creates legal notification obligations, affected parties and regulators will be informed in accordance with applicable law.
Vendor & Third-Party Security
Where third-party providers support Guardian Jem operations, appropriate controls are expected.
This may include:
- Security due diligence
- Contractual data protection obligations
- Access limitations
- Transfer safeguards
- Operational security requirements
- Ongoing provider review where appropriate
Third-party access is limited to necessary service delivery functions.
Staff & Operational Security
Guardian Jem applies internal operational measures to reduce privacy and security risk.
This may include:
- Confidentiality expectations
- Access governance
- Operational process controls
- Security awareness measures
- Internal oversight
Access to personal information is controlled and limited appropriately.
User Responsibilities
Security is a shared responsibility.
Users are responsible for:
- Protecting account credentials
- Maintaining device security
- Managing access permissions
- Reporting suspicious activity
- Using Guardian Jem services responsibly
- Keeping software updated where relevant
Guardian Jem cannot protect against risks arising from compromised user devices or shared credentials outside our control.
No Absolute Guarantee
While Guardian Jem applies security measures designed to protect personal information, no technology, infrastructure, or transmission method can be guaranteed completely secure.
We continuously work to strengthen protections and respond appropriately to evolving risks.
10 | Cookies & Website Technologies
What Are Cookies
Cookies are small text files placed on your device when you visit a website.
They help websites function properly, remember preferences, improve performance, and provide insight into how services are used.
Guardian Jem uses cookies and similar technologies on its website and digital services where applicable.
How We Use Cookies
Guardian Jem uses cookies and similar technologies to support website functionality, security, performance, and user experience.
This may include:
- Keeping website sessions active
- Remembering preferences
- Supporting navigation functionality
- Improving website performance
- Monitoring technical reliability
- Measuring website usage
- Understanding visitor interactions
- Supporting security protections
- Detecting suspicious activity
Types of Cookies We Use
Guardian Jem may use the following categories of cookies:
Strictly Necessary Cookies
Required for core website functionality and security.
Examples:
- Session management
- Security authentication
- Form functionality
- Load balancing
- Fraud prevention protections
These cookies do not require consent where legally exempt.
Analytics Cookies
Used to understand how visitors interact with our website.
Examples:
- Traffic measurement
- Page performance analysis
- Visitor behaviour insights
- Navigation analysis
- Service improvement analytics
These cookies require consent where required by law.
Preference Cookies
Used to remember settings and user choices.
Examples:
- Language preferences
- Consent choices
- Interface preferences
Functional Cookies
Support enhanced website experiences.
Examples:
- Embedded functionality
- Interactive website tools
- Service enhancements
Cookie Consent
Where legally required, Guardian Jem requests consent before placing non-essential cookies on your device.
Users can:
- Accept cookies
- Reject non-essential cookies
- Adjust preferences
- Change consent settings later where functionality allows
Strictly necessary cookies remain active where required for service operation.
Third-Party Cookie Technologies
Some website functionality may rely on authorised third-party technologies.
These may involve cookies or similar technologies used for:
- Analytics
- Performance monitoring
- Embedded services
- Security services
- Website functionality
Where required, these technologies are subject to applicable consent controls.
Managing Cookies
Most browsers allow users to control or disable cookies through browser settings.
Users can typically:
- Delete stored cookies
- Block future cookies
- Restrict third-party cookies
- Manage tracking preferences
Disabling certain cookies may affect website functionality or performance.
Cookie Policy Updates
Guardian Jem may update its cookie practices as services evolve or legal requirements change.
The latest version will always be reflected within our privacy and cookie disclosures.
11 | Children, Vulnerable Individuals & Accessibility
Our Safeguarding Responsibility
Guardian Jem is designed to support safeguarding, connected safety awareness, and responsible protection for individuals who may require additional support.
This can include:
- Children
- Teenagers
- Older adults
- Vulnerable individuals
- Individuals requiring assisted safeguarding oversight
- Organisationally protected users
Because these services involve higher safeguarding sensitivity, Guardian Jem applies enhanced privacy expectations.
Children’s Privacy
Where Guardian Jem services involve children, additional protections apply.
We recognise that children’s personal information requires a higher level of care and protection.
Guardian Jem:
- Applies data minimisation principles
- Limits unnecessary data collection
- Restricts inappropriate processing
- Applies appropriate security protections
- Designs safeguarding functionality around authorised oversight
- Seeks lawful authority where required
Children’s personal information is not knowingly collected outside legitimate safeguarding or authorised service use.
Parental & Authorised Responsibility
Where children or dependent individuals are connected to Guardian Jem services, the responsible adult, guardian, organisation, or authorised party must have lawful authority to provide that information.
Examples include:
- A parent setting up a family account
- A guardian managing a connected profile
- A school or childcare provider using authorised safeguarding services
- A care provider managing an approved safeguarding environment
Guardian Jem may require verification or authority confirmation where appropriate.
Vulnerable Individuals
Guardian Jem services may be used to support safeguarding involving vulnerable adults or individuals requiring additional care or oversight.
Where this applies:
- Processing must remain lawful
- Privacy protections are strengthened
- Access is controlled
- Safeguarding-related necessity is considered carefully
- Sensitive processing is limited to legitimate service purposes
Guardian Jem does not support inappropriate surveillance or unlawful monitoring.
Accessibility & Inclusive Access
Guardian Jem aims to make privacy information and services reasonably accessible.
We recognise that users may have differing accessibility needs.
Where possible, we aim to support:
- Clear and readable privacy information
- Accessible website experiences
- Alternative support contact routes
- Screen reader compatibility where applicable
- Inclusive communication approaches
Users requiring assistance may contact us for support.
Age-Appropriate Protections
Where services are intended to support younger users, Guardian Jem seeks to align privacy protections with age-appropriate safeguarding expectations.
This includes applying proportionate privacy-by-design principles where relevant to service functionality.
Misuse Prevention
Guardian Jem services must not be used for unlawful monitoring, abusive surveillance, coercive control, stalking, or unauthorised tracking.
Where misuse is identified, Guardian Jem reserves the right to investigate, restrict, suspend, or terminate access.
12 | Business & Organisational Accounts
Business & Organisational Services
Guardian Jem may provide services to businesses, schools, childcare providers, care providers, hospitality operators, venues, and other organisations using managed safeguarding environments.
Where organisational services are used, additional administrative, operational, and contractual privacy arrangements may apply.
Controller & Processor Responsibilities
Depending on how Guardian Jem services are used, privacy responsibilities may differ.
In some circumstances:
- Guardian Jem acts as a Data Controller, meaning we decide how and why personal information is processed.
- An organisation acts as a Data Controller, meaning they determine the purpose and lawful basis for processing.
- Guardian Jem acts as a Data Processor, processing information on behalf of the organisation under agreed contractual terms.
The applicable role depends on the service arrangement.
Organisation Responsibilities
Organisations using Guardian Jem services are responsible for ensuring they have lawful authority to provide personal information for authorised service use.
This includes responsibility for:
- Lawful data collection
- Appropriate notices to affected individuals
- Internal safeguarding governance
- Access control management
- Authorised administrative oversight
- Compliance with applicable legal obligations
Guardian Jem is not responsible for unlawful data submissions made by organisational customers.
Employee, User & Managed Account Privacy
Where Guardian Jem services are provided through an organisation, certain personal information may be visible to authorised organisational administrators where required for legitimate safeguarding or operational management.
Users operating within organisational environments should understand that some account activity may be visible within the authorised service structure.
Business Support & Operational Communications
Guardian Jem may process business contact information for legitimate commercial and operational purposes.
This may include:
- Service onboarding
- Account support
- Contract administration
- Billing communications
- Technical support
- Service notices
- Business relationship management
- Compliance-related communications
Business Contracts & Additional Terms
Business and organisational customers may also be subject to:
- Commercial agreements
- Service terms
- Data processing agreements
- Implementation terms
- Security obligations
- Contractual privacy commitments
Where those agreements apply, they supplement this Privacy Policy.
Business Safeguarding Governance
Guardian Jem services are intended to support lawful safeguarding and responsible oversight.
Organisational customers must ensure Guardian Jem is used:
- Lawfully
- Ethically
- In accordance with safeguarding obligations
- In accordance with internal governance
- Without misuse or unlawful surveillance
Guardian Jem reserves the right to investigate misuse and take appropriate action.
13 | Policy Updates, Contact Information & Complaints
Changes to This Privacy Policy
Guardian Jem may update this Privacy Policy from time to time to reflect:
- Changes to our services
- New product functionality
- Legal or regulatory developments
- Security improvements
- Operational changes
- Business restructuring or growth
Where changes materially affect how personal information is handled, appropriate notice will be provided where required.
The latest version will always be available through our website or relevant service channels.
Contact Us
If you have questions about this Privacy Policy, your personal information, or how Guardian Jem handles data, please contact us.
Guardian Jem Limited
Company Number: 16996297
United Kingdom
Email: hello@guardianjem.com
We will aim to respond within applicable legal timeframes where privacy rights requests are involved.
Privacy Rights Request
If you wish to exercise your privacy rights, including requests relating to:
- Access
- Correction
- Deletion
- Restriction
- Objection
- Data portability
- Withdrawal of consent
please contact us using the details above.
Guardian Jem may request information necessary to verify identity before processing certain requests.
Complaints
If you have concerns about how Guardian Jem handles personal information, we encourage you to contact us first so we can try to resolve the issue promptly and fairly.
You also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO).
Information Commissioner’s Office (ICO)
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
United Kingdom
Website: https://www.ico.org.uk
Effective Date
Effective Date: May 2026
Last Updated: May 2026
To Be Reviewed: Annually
Our Commitment
Guardian Jem is committed to handling personal information responsibly, lawfully, and with safeguarding-led care.
Because Guardian Jem supports environments where trust matters, privacy and data protection remain central to how we design and operate our services.
Guardian Jem Limited
Company No: 16996297
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