Privacy Notice
Last updated: 27 September 2026
1. Who we are
CloseKin Play is provided by MyCloseKin LTD. MyCloseKin LTD is the data controller for the personal data described in this notice.
2. What we collect
We collect only what we need to run the service:
- Account details — the grown-up's email address and login credentials.
- Family profiles — first names or nicknames, age bands, and avatar choices for the people in your Family Space.
- Play progress — which adventures each pair has completed and which realms are unlocked.
- Support messages — if you contact us, the messages you send.
- Technical data — device identifiers, IP address, and basic usage/telemetry used for security and product improvement.
We never record, transcribe, or store the content of your conversations. The cards start the conversation — what you say to each other stays between you.
3. Why we use it and our legal basis
- To create and run your account and provide the service — performance of our contract with you.
- For security, fraud prevention, and product improvement — our legitimate interests.
- For customer support — performance of our contract and legitimate interests.
- For marketing, where you have opted in — consent (you can withdraw it at any time).
- To meet legal obligations — legal obligation.
4. Who we share it with
- Service providers who help us run the service (hosting, authentication, analytics, support tooling), under contracts that protect your data.
- Paddle, our Merchant of Record, who processes payments, manages subscriptions, handles tax compliance and invoicing. Paddle is the controller of the payment data it collects at checkout.
- Professional advisers (legal, accounting) where needed.
- Authorities, where required by law.
5. International transfers
Some of our service providers process data outside the UK/EEA. Where they do, we use appropriate safeguards such as adequacy decisions or standard contractual clauses.
6. How long we keep it
We keep your data for as long as your account is active and as needed to provide the service. When data is no longer needed — for example after you delete your account — we delete or anonymise it, except where the law requires us to keep it longer.
7. Your rights
Under UK GDPR you have the right to access, rectify, erase, restrict, and port your personal data, to object to processing, and to withdraw consent at any time. We respond to requests within one month. You also have the right to complain to the Information Commissioner's Office (ICO).
To exercise any of these rights, contact us using the support details in the app.
8. Security
We use appropriate technical and organisational measures to protect your data, including encryption in transit and access controls that limit who can see it.
9. Cookies
We use essential cookies and local storage to keep you signed in and remember your Family Space on your device. We do not use marketing cookies. You can clear these in your browser settings, though sign-in and saved progress on that device will be removed. See our full cookie assessment.
10. Children
Accounts are created and managed by adults. Children's profiles contain only a nickname, age band, and avatar, and children play together with a grown-up. We do not knowingly collect personal data directly from children.
