Privacy notice

Who we are

MYCLOSEKIN LTD is the data controller for the personal information processed through CloseKin. That means we decide what is collected and why, and we are responsible for looking after it.

• MYCLOSEKIN LTD, registered in England and Wales, company number 17426377.
• Registered address: 53 Sweeters Field Road, GU6 8UD, United Kingdom.
• Data protection contact: hello@myclosekin.app. Please put "Privacy" in the subject line and we will reply within one month.

What information we collect

• Parents: email address, the display name and cartoon face you choose.
• Young people: email address, display name and cartoon face. The email is used to sign in and to link the two accounts.
• App content: your answers to our conversation prompts, your mood check-ins, saved Memory Jar items, which questions you have completed, and how you respond to an unlocked answer (an appreciation, a short follow-up question and reply, or a star on your own answer).
• Responses are only ever visible to the two people in your connection. A star on your own answer is an explicit choice to make that answer eligible for a future Remembering feature; it points at the original answer rather than copying it, so removing or changing the answer changes or removes the star too.
• Pilot feedback: if you answer the short pilot feedback questions, your set-choice answers. No written comments are collected.
• Service records: the date consent and the 13+ confirmation were given, your notification preferences, and any help or access request you send us.
• Basic technical information needed to run and secure the service, such as sign-in times and error reports.
• We do not collect location, contacts, photos, phone numbers, messages, browsing history or screen time.

Why we use it, and our lawful basis

UK GDPR asks us to name a lawful basis for each purpose. Here they are, purpose by purpose.

• Running the connection between a parent and a young person, showing the daily question and storing your answers — contract: this is the service you asked for.
• Reminder, unlock and weekly summary emails, and phone notifications — consent. You can turn these off in Preferences at any time.
• Keeping a record that guardian confirmation and the 13+ confirmation were given — legal obligation and our legitimate interests in holding compliance evidence.
• Keeping the service working and secure, fixing faults, and answering your help or access requests — our legitimate interests in running a safe, reliable service.
• Sharing information where there is a serious risk to someone's safety — vital interests, or a legal obligation where one applies.

Mood check-ins and answers (health-related information)

Mood check-ins, and some of what people write in their answers, can reveal how someone is feeling mentally. Under UK GDPR that counts as special category (health) information, so it gets extra protection.

• The legal condition we rely on for health-related information is under legal review.
• Answers to connection questions stay sealed until you have both answered. Mood check-ins are shared with the other person in your connection as soon as they are logged and may appear in your shared wellbeing trend.
• CloseKin does not interpret moods, continuously monitor them, generate risk scores or automatically send alerts based on them.
• If you leave a connection, you lose access to it straight away. The other person may still be able to see answers and moods that were already shared.
• We never use it for profiling, scoring, advertising or any automated decision-making, and we do not read it as part of normal operation.
• You can stop sharing at any time by leaving the connection or deleting your account.

Consent, and how the 13+ rule works

CloseKin is for young people aged 13 and over, so parental consent is not the only basis we rely on — and we do not treat it as a blanket permission for everything.

• The young person agrees for themselves: they confirm their age and accept how answers are shared before they join.
• The parent or legal guardian confirms that they are the guardian, that the young person is 13 or over, and consents to us processing both email addresses to link the accounts.
• Running the service itself rests on contract. Optional extras such as emails and notifications rest on consent, which either person can withdraw for their own account.
• We do not knowingly create accounts for children under 13. If we learn an account belongs to someone younger, we close it and delete its data.

Your rights

You can exercise any of these free of charge, and we will answer within one month.

• Access — ask for a copy of the personal information we hold about you.
• Correction — ask us to fix anything inaccurate. You can change your name, face and preferences yourself in Profile.
• Erasure — delete your account and data from Profile → Delete account, or ask us to do it for you.
• Restriction — ask us to pause using your information while a concern is looked into.
• Objection — object to processing we base on legitimate interests.
• Portability — ask for the information you gave us, or that you created in the app, in a machine-readable file, where the processing rests on consent or contract.
• Withdraw consent — turn off emails and notifications in Preferences. You can also stop sharing by leaving the connection or deleting your account.
• To use any of these, email hello@myclosekin.app from the address on your account.

Complaining to the ICO

• If you are unhappy with how we handle your information, please tell us first at hello@myclosekin.app — we would like the chance to put it right.
• You can also complain to the Information Commissioner's Office, the UK regulator: ico.org.uk/make-a-complaint, or 0303 123 1113.
• Complaining to the ICO does not cost anything and does not affect your account.

Who processes data for us, and where

We use a small number of suppliers to run CloseKin. They act on our instructions only, under written data-processing terms, and may not use your information for their own purposes.

• Cloud hosting, application and database provider — stores your account, connection and answers. Hosting location, encryption and backup arrangements are as provided by our suppliers, subject to verification.
• Email delivery provider — sends invites, sign-in links, reminders and unlock alerts. Answer content is never included in an email.
• Push notification delivery — sends the optional phone nudges, which contain no answer content. Delivery passes through your browser or phone maker's push service.
• Error reporting — technical fault reports (no answer content) are collected by our hosting provider so we can fix problems.
• Some of these providers may process information outside the UK. We are verifying each supplier's processing locations and transfer safeguards and will list them here once confirmed.
• We never sell your information, and we do not share it with advertisers. We share it otherwise only where the law requires it, or where someone is at serious risk of harm.

Cookies and similar technologies

• CloseKin uses only what it needs to work: a sign-in session stored on your device so you stay signed in, and small local entries for things like your preferences and banners you have dismissed.
• We do not use analytics cookies, advertising cookies or profiling pixels. Typefaces are served by CloseKin itself; the only third-party request is the error-reporting service listed above.
• Because there is nothing optional to accept, there is no cookie banner to click through. Clearing your browser storage signs you out.

How long we keep things

• While your account is open, we keep your account details, answers and check-ins so the two of you can look back at them.
• We keep personal information only for as long as necessary for the purposes we hold it for, taking account of legal, safeguarding, security and operational requirements. MYCLOSEKIN LTD is establishing a formal retention schedule.
• You can ask us to delete your information at any time by emailing hello@myclosekin.app, or delete your account from Profile.

Your privacy when you're 13 or over

This part is for the young person using CloseKin. It's your information, and these are your choices — you do not have to go through your parent to use them.

• Your answer is sealed the moment you send it. Nobody, including your parent, can read it until you have both answered.
• You never have to answer a question. Skipping one is always allowed and nothing happens if you do.
• Reminder emails and phone nudges are off unless you turn them on, and you can turn them off whenever you like.
• You can ask us what we hold about you, ask us to correct it, or ask us to delete it — email hello@myclosekin.app yourself.
• You can leave the connection, or delete your account, from Profile. If you leave, you lose access straight away, but your parent may still see answers and moods that were already shared.
• There's a shorter version of all this written just for you — see "Privacy, in plain words" below.

Changes to this notice

• This notice was last updated on 18 September 2026.
• If we make a significant change, we will email the address on your account and update the date above.