CloseKin Therapy

Privacy notice

Last updated: 30 September 2026

CloseKin Therapy is a between-session communication and connection tool for young people aged 13 and over, their parent/carer and an approved therapist or clinician.

Who we are

  • MYCLOSEKIN LTD (company number 17426377) is the data controller for personal information processed through CloseKin Therapy.
  • Registered office: 53 Sweeters Field Road, GU6 8UD.
  • Privacy and data protection contact: hello@myclosekin.app
  • CloseKin Therapy is designed to help therapists support structured therapeutic work between sessions without giving the therapist access to private conversations between a young person and their parent/carer.

An important privacy principle

  • CloseKin Therapy separates private family conversation content from therapy engagement information.
  • Your therapist can see limited information about the activities they have assigned and whether the family has engaged with them.
  • Your therapist cannot read the private answers exchanged between the young person and parent/carer.
  • This means a therapist may know that an activity was completed, but not what the young person or parent/carer privately wrote to one another.

Account information

  • We may hold:
  • email address
  • display name
  • chosen avatar
  • whether the account belongs to a young person, parent/carer or practitioner
  • account identifiers
  • authentication and security information; and
  • relevant age and guardian confirmations.

Family connection information

  • We may hold information needed to:
  • connect a young person and parent/carer
  • connect a family with an approved therapist
  • identify when a connection was created
  • identify whether a therapy link is active or has ended; and
  • record when a connection is ended, revoked or transferred.
  • Ending the therapy link stops new therapy engagement information being shared with that therapist.

Therapy activity information

  • When a therapist assigns a Connection Activity, CloseKin Therapy may hold:
  • the activity assigned
  • the therapeutic focus selected by the therapist
  • an optional therapeutic goal
  • whether that goal has been shared with the family
  • release and due dates/times
  • whether the young person participated
  • whether the parent/carer participated
  • whether the activity was completed
  • completion date/time
  • a selected barrier to completion, where provided
  • whether the family indicated that they talked another way
  • each participant’s selected usefulness response; and
  • relevant dates needed to support review at the next therapy session.

What your therapist can see

  • For a family currently linked to them, the therapist may see:
  • the Connection Activity they assigned
  • the therapeutic focus
  • an optional therapeutic goal and whether it was shared
  • release and due information
  • whether the young person participated
  • whether the parent/carer participated
  • whether the activity was completed
  • when it was completed
  • a controlled barrier response, where one was selected
  • whether the family indicated that they talked another way
  • each participant’s controlled usefulness response; and
  • relevant activity and review dates.
  • This information is designed to help the therapist review between-session engagement without giving them access to the family’s private conversation.

What your therapist cannot see

  • Your therapist cannot see:
  • the private answer text written by the young person
  • the private answer text written by the parent/carer
  • private follow-up conversations
  • private parent-young person conversation content
  • content saved to “Remember this about me”
  • Memory Jar content
  • individual mood entries
  • family-level mood scores
  • private free-text responses; or
  • an automated risk, compliance or relationship score.
  • CloseKin Therapy does not automatically analyse private family answers to diagnose, assess or score the young person, parent/carer or family relationship.

Private conversation answers

  • CloseKin stores the answers a parent/carer and young person choose to give to conversation prompts where this is necessary for the family experience to work.
  • These answers remain within the private parent-young person connection.
  • They are not made available to the therapist through the therapist dashboard.
  • Where the product uses a sealed-answer feature, one person’s answer remains sealed until the other participant has answered in accordance with the activity design.

Mood information

  • Where mood check-ins are available, individual mood information remains private within the family experience.
  • Therapists do not receive:
  • individual young-person mood scores
  • individual parent/carer mood scores
  • family mood scores; or
  • family mood trend reporting.
  • Mood information is not used to create an automated clinical assessment or diagnosis.

Practitioner information

  • For therapists and clinicians, we may hold:
  • name
  • email address
  • organisation or practice information, where provided
  • professional account information
  • linked family information
  • activities assigned
  • therapeutic focuses and goals entered by the practitioner
  • activity release and review information; and
  • limited engagement information relating to their linked families.

Caseload analytics

  • CloseKin Therapy may provide practitioners with appropriately aggregated service or caseload information to help them understand use of the service.
  • Where analytics could create a risk of identifying a particular family, CloseKin applies a minimum reporting threshold.
  • Permitted sensitive aggregated caseload or service analytics are not displayed unless at least five families contribute to the result.
  • Caseload analytics do not give therapists access to private family answers, individual mood information or private family conversations.

Why we use information and our lawful basis

  • We use personal information only where we have an appropriate legal basis.
  • This may include:
  • Providing CloseKin Therapy and operating accounts Lawful basis: contract.
  • Connecting the appropriate parent/carer, young person and therapist and delivering therapist-assigned activities Lawful basis: contract.
  • Sending optional reminder, unlock or summary communications Lawful basis: consent where applicable. These can be switched off where the service provides that option.
  • Maintaining security, preventing misuse, fixing faults and providing support Lawful basis: legitimate interests.
  • Maintaining appropriate age, guardian and consent records Lawful basis: legal obligation and/or legitimate interests where applicable.
  • Responding to a serious safeguarding situation where disclosure is necessary Lawful basis may include vital interests and/or legal obligation depending on the circumstances.

Special-category information

  • Some information entered into CloseKin Therapy may reveal information about a person’s physical or mental health and may therefore constitute special-category personal data under UK data-protection law.
  • This may include some:
  • mood information
  • private conversation answers; and
  • other information voluntarily provided within a family interaction.
  • Before the Phase 1 pilot begins, MYCLOSEKIN LTD must determine and document the applicable Article 9 condition and, if explicit consent is relied upon, implement an explicit-consent process. The present consent screen must not be treated as explicit consent for special-category information.
  • Private family content is not:
  • used for advertising
  • sold
  • used to create marketing profiles
  • used for automated diagnosis
  • used for automated clinical decision-making
  • routinely read by MYCLOSEKIN LTD staff; or
  • made available to the therapist through the therapist dashboard.
  • Where processing depends on explicit consent, consent can be withdrawn. Where the relevant information is necessary for a core feature to operate, withdrawing consent may mean that the person can no longer use that particular feature or may need to leave the connection or delete their account.

Young people aged 13 and over

  • CloseKin Therapy is designed for young people aged 13 and over.
  • We do not treat parental consent as a blanket legal basis for everything a young person does within CloseKin Therapy.
  • Young people have privacy and data-protection rights in their own right.
  • A young person can:
  • choose whether to answer a conversation prompt
  • choose what they write
  • make a privacy request themselves
  • ask what information we hold about them
  • ask for inaccurate information to be corrected
  • turn optional reminders off where available
  • leave a connection; and
  • request deletion of their account subject to any information we are legally required to retain.
  • Young people do not have to ask their parent/carer to make a privacy request on their behalf.

Your data-protection rights

  • Depending on the circumstances, you may have the right to:
  • access your personal information
  • correct inaccurate information
  • request deletion
  • restrict certain processing
  • object to certain processing
  • receive certain information in a portable format; and
  • withdraw consent where processing relies on consent.
  • To exercise a privacy right, contact:
  • hello@myclosekin.app
  • We normally respond to valid requests within the period required by data-protection law.

Who processes information for us

  • MYCLOSEKIN LTD uses carefully selected service providers to operate CloseKin Therapy.
  • These may include providers supporting:
  • cloud hosting and databases
  • authentication
  • email delivery
  • notifications
  • security
  • infrastructure; and
  • technical support.
  • Some providers may process information in the UK, EEA or other countries.
  • Where personal information is transferred internationally and a legal safeguard is required, we use an appropriate UK data-protection transfer mechanism.
  • We do not sell personal information.
  • We do not use children’s personal information for behavioural advertising.
  • We do not use third-party advertising trackers.

Therapists and their own professional records

  • A therapist, clinician or therapy organisation may separately hold information about a family as part of their own clinical or professional records.
  • Those records are separate from the private family information held within CloseKin.
  • The therapist or organisation is responsible for explaining how they use information within their own clinical service and their own privacy notice may apply.
  • Using CloseKin Therapy does not give a therapist access to the private parent-young person conversation.

Cookies and similar technologies

  • CloseKin Therapy uses technologies necessary for the service to function.
  • These may include:
  • authentication/session information
  • security information
  • preferences; and
  • local device storage necessary for service functionality.
  • We do not currently use behavioural advertising cookies or third-party marketing trackers.

How long we keep information

  • Live account information Kept while the account remains open and for as long as needed to provide the service.
  • Deleted accounts When an account is deleted, personal information is removed from the live CloseKin system subject to any information we are required or permitted to retain. Residual copies may remain temporarily in automatic backups until those backups expire.
  • Inactive accounts Inactive accounts may be reviewed and, where appropriate, deleted after an appropriate warning.
  • Compliance, consent and safeguarding records Limited records may be retained where reasonably necessary to demonstrate consent, age confirmation, safeguarding action or legal compliance. These records do not need to contain private conversation answers.
  • Support and privacy requests Relevant records may be retained for a reasonable period to demonstrate how the request was handled.
  • Our detailed retention arrangements are reviewed as the service develops.
  • A formal Therapy data-retention schedule must be approved before the Phase 1 pilot begins; this notice does not invent periods that have not yet been approved.

When therapy ends

  • When a therapist stops working with a family, the Therapy link can be ended.
  • Once the link has ended, the former therapist can no longer access either new or historical Therapy engagement information through that link.
  • Ending the link does not give the therapist access to private family conversations; private answers remain private.
  • The family may be able to continue using an appropriate CloseKin family service independently, depending on the product arrangements in place.

Safeguarding

  • CloseKin Therapy supports communication and therapeutic work between sessions.
  • It is not a crisis-monitoring service.
  • Private family answers are not continuously monitored by MYCLOSEKIN LTD or by the therapist through CloseKin Therapy.
  • CloseKin should therefore never be relied upon to alert a therapist or MYCLOSEKIN LTD to an emergency.
  • Where MYCLOSEKIN LTD becomes aware of information indicating a serious and immediate safeguarding concern, information may be used or disclosed where this is necessary and lawful to protect someone.
  • If someone is in immediate danger, use the appropriate emergency service rather than relying on CloseKin.

Complaints

  • If you are concerned about how MYCLOSEKIN LTD has handled personal information, please contact:
  • hello@myclosekin.app
  • We would like the opportunity to investigate and resolve your concern.
  • You also have the right to complain to the UK Information Commissioner’s Office.

Changes to this notice

  • We may update this Privacy Notice as CloseKin Therapy develops or where legal or regulatory requirements change.
  • The “Last updated” date will show when the notice was most recently changed.
  • Where a change is significant, we will provide an appropriate notification.

Contact

  • MYCLOSEKIN LTD Company number: 17426377 Registered office: 53 Sweeters Field Road, GU6 8UD Email: hello@myclosekin.app
  • CloseKin Therapy is a between-session communication and connection tool. It is not a crisis-monitoring service and is not a substitute for emergency, medical or mental-health services.

CloseKin is a conversation space for families aged 13 and over. It is not a monitoring tool, not a crisis service, and not a substitute for professional help. In an emergency, call 999.

Questions? hello@myclosekin.app