Minor Recipients and Guardians Policy
How Y.O.D.O. handles Recipients who are under 18 and the role of a parent or legal guardian.
Version 2.1.0Last Updated
Company: Y.O.D.O. Ltd (Company No. 15736034)
Registered Office: 42 Mayfair Gardens, Southampton, SO15 2TW, United Kingdom
ICO Registration: ZC015883 (Data Protection Lead: Mrs Theodosia Kouraki)
EU Representative under Article 27 EU GDPR: Christina-Eloiza Kouraki, Marasli 29, Athens 10676, Greece, email eloizakouraki@yahoo.gr.
Contact: info@yodo.ltd
This policy explains how Y.O.D.O. handles Recipients who are under 18 ("Minor Recipients") and the role of a parent or legal guardian ("Guardian").
This policy should be read with our Terms and Conditions, our Privacy Policy, and the ICO's Age Appropriate Design Code (the Children's Code). If there is any conflict, the Terms and Conditions apply.
1. Scope
1.1 Y.O.D.O. is designed for adults. Account Holders and Delegates must be 18 or over.
1.2 A person under 18 can be included only as a Recipient.
1.3 The ICO's Age Appropriate Design Code applies to the parts of the Service likely to be accessed by children, principally the Recipient access flow when a Minor Recipient retrieves a delivered Message. We design those flows to the Code's standards by default.
2. Principles
2.1 We prioritise safeguarding, privacy, and fraud prevention.
2.2 We apply data minimisation and collect only what is needed to apply these safeguards.
2.3 We do not profile children, do not target them with marketing, and do not use their data for any analytics or product testing beyond what is necessary to operate the Recipient access flow.
3. Adding a Minor Recipient (Account Holder responsibilities)
3.1 If you add a Minor as a Recipient, you confirm you have a lawful basis to share their details with us. For example, as a parent, legal guardian, or person with parental responsibility for the Minor Recipient, you may share their details on that basis. If you are unsure whether you have the right to share a Minor's details, seek legal advice before proceeding.
3.2 You are responsible for the content you create. Y.O.D.O. does not review Messages for suitability for minors.
4. How Minor Recipient access works
4.1 Delivered Messages are available for a limited period from the delivery trigger, as set out in our Terms.
4.2 If the Recipient is under 18 at the start of the access window, we may require a Guardian to complete additional steps before access is granted, which can include:
- identity verification (via our verification provider), and
- evidence of parental responsibility or legal authority where appropriate (for example a birth certificate, adoption order, or court order). We will confirm what is required when you contact us.
4.3 If the required steps are not completed within the access window, the Message may be deleted in line with our retention rules.
4.4 If a Recipient or Guardian contacts us within the access window and access is delayed due to our systems or our verification provider, we may extend the access window for a reasonable period.
4.5 If a Minor Recipient turns 18 during the access window, they may contact us to request direct access. We will verify their identity and, if satisfied, grant access without requiring Guardian involvement.
4.6 If you are unable to complete Guardian verification due to circumstances outside your control (for example a verification provider outage or lost documents), contact Support and we will try to find a suitable alternative approach, subject to our security and fraud prevention requirements.
4.7 If the Account Holder was the child's only parent or guardian. Where the Account Holder who passes away was the Minor Recipient's sole parent or legal guardian, Messages addressed to the child are kept securely and remain unreleased until a new legal guardian has been formally appointed (for example through a guardian named in the Account Holder's will, or by a court). Once appointed, the new guardian may contact us to verify their identity and authority, after which the standard Guardian access steps in 4.2 apply. We will pause the access window during this period where reasonably necessary so that Messages are not lost while formal guardianship is being arranged. If you are concerned about this scenario when adding a child Recipient, we encourage you to name a chosen guardian in your will and to record their details in your Y.O.D.O. account notes.
5. Data we use (high level)
We may process:
- the Minor's contact details and date of birth (only to apply these safeguards), and
- Guardian verification outcomes and authority evidence where required.
Details are in our Privacy Policy.
6. Verification
6.1 Account Holders and Delegates must complete phone and email verification for account security.
6.2 Recipients may access delivered Messages without creating an account, but identity verification may still be required before access is granted.
7. Concerns and support
7.1 Immediate risk
If you believe a Minor is at immediate risk, contact emergency services.
7.2 If you suspect misuse or misdelivery involving a Minor Recipient, contact us at info@yodo.ltd with the subject line "Minor Recipient Concern". We aim to acknowledge concerns involving minors within 2 Business Days. If a concern involves immediate risk, always contact emergency services first.
8. Updates
We may update this policy from time to time and will update the "Last Updated" date.
EEA Minor Recipients
If a Minor Recipient is in the European Economic Area, EU GDPR applies to our processing of their personal data alongside UK GDPR. EEA Guardians may exercise the same rights described in this policy and may also raise concerns with their local data protection authority. The Hellenic Data Protection Authority (HDPA) is named in our Privacy Policy as our expected primary EU supervisory contact, given our appointed EU representative is established in Greece.
Important safety reminder
Do not send one-time codes, identity documents, death certificates, passwords, or payment details via email or messaging apps. If you need to provide documents, we will direct you to the secure in-app flow.
Questions about Minor Recipients?
If you have questions about how Y.O.D.O. handles Messages for Recipients under 18, please contact us. We are happy to explain the process.