1. Introduction

At myclosure, we are committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store, and protect your information in compliance with the UK General Data Protection Regulation (UK GDPR) and EU General Data Protection Regulation (EU GDPR).

myclosure is an emotional wellbeing and recovery platform focused on breakup recovery and personal growth. Our platform provides personalised recovery programmes, journaling, mood tracking, anonymous feedback requests, confidence challenges, no-contact tracking, dating guidance, and AI-assisted coaching to support users through emotional recovery and self-development.

Data Controller: myclosure Ltd, United Kingdom

Contact: privacy@myclosure.life

2. Lawful Basis for Processing

Article 6 (General Personal Data)

We process your personal data under the following lawful bases:

• Contract (Article 6(1)(b)) — processing necessary to deliver the service you have subscribed to, including account management, recovery plans, coaching, and payment processing.
• Legitimate Interests (Article 6(1)(f)) — security monitoring, fraud prevention, rate limiting, service improvement, and platform protection.
• Consent (Article 6(1)(a)) — optional marketing communications; you may withdraw consent at any time.
• Legal Obligation (Article 6(1)(c)) — compliance with applicable legal and regulatory requirements.
• Vital Interests (Article 6(1)(d)) — where necessary to protect the life or safety of a user or another individual.

Article 9 (Special Category Data – Mental Health)

Your journal entries, mood data, conversation history, recovery information, and other emotional wellbeing data may constitute special category health data under Article 9 UK GDPR.

We process this information on the basis of your explicit consent under Article 9(2)(a). We obtain this consent through a dedicated consent mechanism during onboarding before any health-related information is processed.

You may withdraw your consent at any time by deleting your account or contacting us. Withdrawal of consent may affect our ability to provide certain features and services.

3. Information We Collect

3.1 Account Information

• Email address and encrypted password for secure login
• Name, subscription tier (Reflect, Clarity, Closure+), and account preferences
• Payment details processed securely by Stripe; we never store card information

3.2 Personal Development Data (Special Category – Health)

• Journal entries and personal reflections
• Mood tracking and emotional wellbeing check-ins
• Recovery plan progress and activity completion history
• Confidence challenge participation and reflections
• No-contact tracking streaks and progress data
• Conversation history with platform coaching features

3.3 Your Next Chapter Data

• Dating intentions and personal relationship goals
• Emotional patterns in dating contexts
• Personalised relationship insights

3.4 Feedback Data

• Anonymous feedback requests sent to contacts you specify
• Recipient phone numbers used solely for one-time SMS delivery and deleted immediately after successful transmission
• Anonymous feedback responses and ratings
• Optional personal messages included in feedback requests

3.5 Technical Information

• Usage data relating to platform features
• Browser type and device information
• Anonymised IP address information
• Temporary session data required for authentication and security

4. How We Use Your Information

4.1 Core Platform Services

Lawful Basis: Contract

We use your information to:

• Manage your account
• Deliver subscription services
• Provide personalised recovery programmes
• Facilitate coaching and self-reflection features
• Process payments
• Deliver feedback requests via SMS and email

4.2 AI-Powered Features

Lawful Basis: Explicit Consent for Health Data; Contract for Service Delivery

OpenAI GPT models are used for:

• Journal sentiment analysis
• Emotional insights and pattern recognition
• Coaching conversation responses
• Relationship and recovery guidance

Where possible, personal identifiers are removed before processing. Data is not retained by OpenAI after processing.

4.3 Recovery Plans

Lawful Basis: Contract

Recovery plans are generated using behavioural analysis and rule-based systems. Framework selection and activity recommendations are determined using information derived from your platform activity, mood data, and recovery progress.

4.4 Automated Decision-Making

Article 22 Disclosure

myclosure uses automated analysis to recommend therapeutic frameworks, personalise recovery plans, and tailor content to your individual recovery journey.

These recommendations influence which activities, programmes, and wellbeing resources are presented to you.

This processing does not produce legal effects or similarly significant decisions.

You have the right to:

• Request human review of automated recommendations
• Express your point of view regarding recommendations generated by automated systems
• Object to automated processing
• Override or modify recommendations within the platform where available

Where a review is requested, a member of the myclosure team will assess the recommendation and provide a response.

4.5 Crisis Detection and Safety

Lawful Basis: Vital Interests – Article 6(1)(d) and Article 9(2)(c)

myclosure includes automated safety screening designed to identify language that may indicate severe emotional distress or risk of harm.

When detected, the platform may surface relevant crisis support resources, including:

• Samaritans — 116 123
• SHOUT — text 85258
• Emergency Services — 999

These safety measures are intended to support user wellbeing and cannot be disabled.

myclosure is not an emergency service and cannot guarantee the identification of all situations involving emotional distress, self-harm, or risk. If you believe you or another person is in immediate danger, contact emergency services or an appropriate crisis support service immediately.

Safety-related data is anonymised within 24 hours and deleted after 12 months.

4.6 Marketing Communications

Lawful Basis: Consent

Marketing communications are only sent where you have provided consent.

You may withdraw consent at any time through the app or by contacting 

privacy@myclosure.life

5. Data Retention

Payment data is managed by Stripe. We retain subscription status and billing history only where necessary.

Users may delete their account at any time. Individual entries may also be deleted separately. Data export functionality is available upon request before deletion.

6. Data Security

We implement industry-standard security measures including:

• AES-256 encryption for stored data
• TLS 1.3 encryption for data transmission
• bcrypt password hashing
• Parameterised database queries
• Secure session management
• PCI-compliant payment processing through Stripe
• Privacy-preserving rate limiting and security controls

While no method of transmission or storage is completely secure, we take reasonable steps to protect your information against unauthorised access, disclosure, alteration, or destruction.

7. Data Sharing and Third Parties

We do not sell, rent, or share personal data with third parties for advertising or commercial marketing purposes.

7.1 Essential Service Providers

All service providers are subject to contractual data protection obligations and may only process personal data on our documented instructions.

7.2 Legal Requirements

We may disclose personal data where required by law or where necessary to protect the safety, rights, or property of users, myclosure, or others.

8. International Transfers

Some of our service providers are located outside the United Kingdom and European Economic Area, including in the United States.

Where personal data is transferred internationally, we implement appropriate safeguards in accordance with UK GDPR and EU GDPR. These safeguards may include:

• The UK International Data Transfer Agreement (IDTA)
• The UK Addendum to the EU Standard Contractual Clauses
• European Commission Standard Contractual Clauses
• Other lawful transfer mechanisms recognised under applicable law

We regularly assess our processors and transfer arrangements to ensure an appropriate level of protection for personal data.

9. Cookies

myclosure uses only technologies that are necessary for the operation, security, and delivery of the platform.

These may include:

• Authentication and session cookies
• Security and CSRF protection cookies
• Load-balancing and infrastructure cookies
• Strictly necessary service-provider technologies

We do not use advertising cookies, behavioural tracking cookies, or third-party advertising technologies.

Where non-essential cookies or tracking technologies are introduced in the future, we will obtain consent where required by law.

10. Your Rights Under UK GDPR

You have the right to:

• Access your personal data
• Correct inaccurate information
• Request deletion of your personal data
• Restrict processing
• Receive your data in a portable format
• Object to processing based on legitimate interests
• Withdraw consent at any time
• Request review of automated recommendations

To exercise your rights:

privacy@myclosure.life

or use the privacy controls available within the platform.

We will respond within one calendar month unless an extension is permitted under applicable law.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO).

11. Children’s Privacy

myclosure is intended for adults aged 18 and over.

We do not knowingly collect personal information from individuals under 18 years of age. If we become aware that information relating to a person under 18 has been collected, we will delete it without undue delay.

myclosure is a self-guided emotional wellbeing platform and is not a medical device, healthcare provider, emergency service, or regulated mental health treatment provider.

The platform does not provide medical advice, diagnosis, treatment, psychotherapy, or clinical mental health care.

12. Changes to This Policy

We may update this Privacy Policy from time to time.

Where changes are material, we will provide notice through email, in-app notification, or other appropriate means before the changes take effect.

Where consent is required for new processing activities, we will obtain it before processing begins.

13. Regulatory Complaints

You have the right to lodge a complaint with the Information Commissioner’s Office (ICO) if you believe we have not handled your personal data in accordance with applicable law.

We encourage you to contact us first so we can attempt to resolve your concerns.

myclosure Ltd is registered with the Information Commissioner’s Office (ICO).

https://ico.org.uk

Telephone: 0303 123 1113

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

14. Contact

Privacy enquiries and data protection requests:

privacy@myclosure.life

myclosure Ltd
United Kingdom

We respond to data protection requests within one calendar month unless an extension is permitted under applicable law.