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Legal Changelog

Previous versions of our legal policies can be found below.

August 2026

  • Privacy Policy updated to v1.4. Thirs Party Processor table removing eSignature from Google Workspace row, adding in that Tally now will send testimonial release forms to clients as well as removing MailerLite as the email service provider and adding in Omnisend. In addition, add WP Forms to the table as the contact form and data processor for the website contact form. Provacy Policy Section 1.7 Marketing and Post-Purchase Emails has been updated to reflect the change in ESP (Email Service Provider) from MailerLite to Omnisend. QUIC.cloud has been added to the Processor Table as part of LiteSpeed Cache.
  • Client Terms of Service updated to v1.8, Section 4.2 Acceptance of Services. Google eSignature has been removed and replaced with Tally.
  • Anti-Spam Policy updated to v1.2. Sections 10.2 How to Join our Mailing List, 10.4 Unsubscribing and 10.5 No Selling or Sharing Email Addresses have been updated to reflect the change in the Email Service Provider and changed from MailerLite to Omnisend.
  • New Document: Quick Tech Check Product Terms created, covering the Access Call process for Zoom and Google Chat/Voxer bookings, credential and access handling, the statutory 14-day cancellation right, and scope for bespoke fixes. View Quick Tech Check Product Terms
  • Services Disclaimer updated to add Quick Tech Check, distinguishing it as an implemented-fix service rather than an audit, diagnostic, or consultation, with a new scope limitations subsection. Client Terms of Service updated to include Quick Tech Check under non-transferable session bookings. View Services Disclaimer. View Client Terms.

July 2026

  • Refund and Cancellation Policy updated to v1.2. Section 5.10 added covering cancellation by Gem Roberts – Systems Strategist outside of Force Majeure circumstances. Distinguishes between cancellation with advance notice and same-day cancellation. Same-day cancellation includes a personalised complimentary product as a goodwill gesture where the client chooses to reschedule. Both scenarios handled with client-led rescheduling and no fixed window imposed.
  • Client Terms of Service updated to v1.6. Section 4.8 updated to include a minimum notice requirement for additional attendee requests. Payment must be confirmed no later than 2 hours before the session start time. Where payment is not confirmed in time, the additional attendee is not permitted to join as well as Section 4.10 updated to clarify that session recording operates on a contractual basis rather than GDPR consent. Clarifying sentence added confirming that the right to withdraw consent does not apply post-session, and that all recordings are permanently deleted after 21 days in line with the Data Retention Policy.
  • Refund and Cancellation Policy updated to v1.3. Section 5.6 updated to clarify that for session-based products, the 21-day goodwill resolution window runs from the session date or the date the deliverable was first shared, whichever is later.
  • Client Terms of Service updated to v1.7. Section 4.5 updated to include a confirmation that clients electing to use Voxer for project communication have read and accepted Voxer’s own Privacy Policy.
  • Accessibility Statement updated to v1.1. Section 7.4 updated to include the alternative format request process, required information from the requester, and a 14-day response commitment.
  • Privacy Policy updated to v1.3. WeTransfer added to the third-party processor table as an alternative file delivery method where Google Drive is not suitable for the recipient. WeTransfer is EU-based and servers are located in the Netherlands.
  • Testimonial Release Form updated to v1.1. New Section 2 added requiring the client to disclose how the service was received, covering the full range from full price paid through to exchange for review, beta access, goodwill gesture, and affiliate relationship. Added for FTC compliance and UK advertising standards. Existing sections renumbered accordingly.
  • Services Disclaimer updated to v1.3. Section 6.5 expanded to include a plain-language explanation of how AI assistance is used in service delivery, what data is and is not submitted to AI tools, an honest acknowledgement that accidental submissions may occasionally occur and how these are handled, and a link to the full AI Usage Policy.

June 2026

  • Privacy Policy updated to reflect the new complaint handling rights under the Data (Use and Access) Act 2025, effective 19 June 2026. Clients now have a statutory right to complain directly to use, within a 30-day acknowledgement obligation. View Privacy Policy.
  • Cookie Policy updated to reflect current plugin stack including Mouseflow, Poptin, Google Tag Manager and LiteSpeed cache. View Cookie Policy.
  • Client Terms of Service updated to reflect session recording retention terms, non transferable booking policy, geographical scope and payment terms. View Client Terms.
  • Data Retention and Deletion Policy updated to include complaint handling procedure and recording deletion timeline. View Data Retention Policy.
  • All documents updated to reflect ICO registration number ZB293438
  • Anti-Spam Policy updated to clarify that all subscribers are added to our mailing list via explicit consent only, given through the checkout or opt-in form at the point of purchase. We do not add anyone to our list without this consent. View Anti-Spam Policy.
  • Privacy Policy processor table updated to include Wordfence, Poptin, Site Kit, Elementor, LiteSpeed Cache, UpdraftPlus, Hostinger, and Google Chat. Ionos replaced with Hostinger as website hosting provider throughout all documents. View Privacy Policy.
  • WeTransfer added as an alternative file delivery method for session recordings where Google Drive access is not possible
  • New Document: Internal Security Practices Guide created covering Malwarebytes, session recordings, client files, credential security, remote access, and liability note
  • Client Terms of Service updated to strengthen client responsibilities including security obligations, device and file hygiene, and liability for threats transferred during sessions. Session delivery clarified to reflect Zoom as the live call platform and Boom for async video. Project communication responsibilities added including 24-hour response time during active projects and official communication channels confirmed as email and Google Chat. Late arrival and no-show policy strengthened with 10-minute window. Platform limitations clause added covering unresolvable issues. General session terms note added directing clients to product-specific terms for refund and cancellation detail. Geographic scope updated to reference the UK Sanctions List rather than named territories. View Client Terms.
  • Refund and Cancellation Policy resolution process added as a clear three-step escalation path from support@ through to formal complaint through to ICO. Processing fees section updated to include transparency clause allowing clients to request a fee breakdown before a refund is processed. Scope limitations expanded to cover Power Hour and Diagnostic Consultation alongside audits. General session terms note added directing clients to product-specific terms. View Refund and Cancellation Policy.
  • Privacy Policy — processor table updated to reflect Zoom, Google Chat, and Voxer (pending compliance verification). Payment section updated to include bank transfer alongside Stripe with Stripe privacy policy link. Google Workspace eSignature GDPR compliance note added. Session recordings section updated to reference Zoom and Boom accurately. Intake form credentials warning added. Third-party transfer assurance reworded to reflect accurate position. Geographic scope updated to reference UK Sanctions List. View Privacy Policy.
  • New Document: AI Usage Policy created (Version 1.1) setting out how AI tools are used within Gem Roberts — Systems Strategist. Covers permitted use cases including content creation, workflow automation, technical problem-solving, and drafting of post-session reports and summaries. Includes data handling commitments specific to AI use, training opt-out position, a dedicated clause on the removal of personally identifiable information prior to submission to any AI tool, and a human limitation clause acknowledging that whilst all AI outputs are reviewed before delivery, human review is subject to inherent limitations and errors or omissions may remain despite reasonable care. View AI Usage Policy
  • New Document: DUAA Compliance Statement created (Version 1.0) as a standalone public-facing page at gemroberts.co.uk/legal/duaa-compliance-statement. Sets out how Gem Roberts – Systems Strategist complies with the Data (Use and Access) Act 2025 (effective 19 June 2026), including the statutory right to complain directly to us and the 30-day acknowledgement obligation. Cross-references the specific sections across four existing legal documents where the obligation is reflected: Privacy Policy (Sections 1.10 and 1.11), Client Terms of Service (Section 4.19), Data Retention and Deletion Policy (Section 5), and Refund and Cancellation Policy (Sections 1 and 1.5). Includes ICO escalation details and ICO registration confirmation. View DUAA Compliance Statement.
  • New Document: Internal SOP — Accidental Client Data Submission to AI Tools created (Version 1.0). Internal use only. Sets out the seven-step response process for occasions where personally identifiable client information is accidentally submitted to an AI tool without first being removed or anonymised. Covers how to identify what was submitted, how to check the tool’s data handling position including specific steps for Claude, how to assess concern level, an incident log table, client notification thresholds, accurate ICO notification guidance by data type, and process review. Includes a client communication template for use in genuine breach scenarios involving credentials or financial data
  • Client Terms of Service updated to v1.3. Entire Agreement clause added (Section 4.23) confirming that the written terms, signed scope confirmation, and product page constitute the full agreement between the parties. Supersedes all prior verbal and written communications not expressly incorporated into a signed document.
  • Client Terms of Service updated to v1.4. Severability clause added (Section 4.24) confirming that if any individual clause is found invalid or unenforceable, the remainder of the terms continue in full force and effect.

  • Client Terms of Service updated to v1.5. General terms section strengthened with four additions: Defined Terms section added as new Section 1 (all subsequent sections renumbered accordingly), providing formal definitions for Agreement, Client, Deliverable, Services, Working Days, and the parties. Waiver clause added confirming that discretionary concessions do not create precedent or modify terms. Variation clause added confirming that no mid-engagement change to agreed terms is effective unless in writing by both parties. Limitation of Liability clause added capping total liability to the fees paid for the specific service in question, with statutory rights preserved for consumers.

  • Privacy Policy updated to v1.2. Fathom Notetaker added to the third-party processor table (Section 1.5). Fathom joins Zoom calls to generate AI transcriptions and notes during live client sessions and processes personal data shared during those sessions. Added in response to UK GDPR processor disclosure requirements. Note: Fathom was acquired by QuestionPro — processor table entry to be reviewed in August 2026 following acquisition to confirm no material change to data handling terms.

  • Cookie Policy updated to v1.2. Essential cookies table (Section 2.3) updated to replace Ionos with Hostinger as the correct website hosting provider. Ionos reference was a legacy inaccuracy from a previous hosting arrangement.