Privacy policy
Last updated: 19 October 2026
Close By helps families keep an eye on someone who lives alone. That means handling information that matters a great deal to people, so we collect as little as we can, keep it on our own server, and never sell it or use it for advertising.
1. Who we are
Close By is provided by [LEGAL NAME, e.g. "Your Name trading as Close By" or "Close By Ltd, company no. 12345678"], [POSTAL ADDRESS] ("we", "us"). We are the data controller for the personal information described here, under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
Contact us about privacy at [CONTACT EMAIL]. [ICO registration number, once registered: ZA123456]
2. What Close By is, and isn't
Close By is a wellbeing check-in service. It is not a medical device, it does not diagnose or monitor any medical condition, and it does not contact the emergency services. If someone is in danger, call 999.
3. Who this policy covers
- Wearers: people who wear an Apple Watch with Close By installed.
- Family members: people who use the Close By iPhone app to receive alerts about a wearer.
- Visitors to this website.
4. Information that stays on the Apple Watch
With the wearer's permission, the watch app reads the following from Apple Health and the watch's motion sensors:
- heart rate
- step count and active energy
- falls detected by the watch
- sleep
- wrist movement
This information is used on the watch only, to decide whether to ask "Are you OK?". It is never sent to our server or to anyone else, and we never write anything to Apple Health. The wearer can turn this access off at any time in the Health settings on their iPhone or watch, although Close By will then be less able to notice that something might be wrong.
5. Information we hold on our server
| What | About whom | Why |
|---|---|---|
| A Sign in with Apple identifier (a random code from Apple, not your Apple ID email) | Wearers and family | To recognise your account when you sign in |
| Your first name or the name you enter | Wearers and family | So alerts and the app can say who is who |
| Phone number, if you give one | Wearers and family | So family can call the wearer, and so we can send family members text-message alerts |
| Time zone and check-in settings (waking hours, how long to wait for an answer, which alerts you want) | Wearers and family | To run check-ins at sensible times |
| Which family members are linked to which wearer, and in what order they are alerted | Wearers and family | To know who to tell |
| Watch status about every 30 minutes: battery level, whether it is charging, whether it seems to be on the wrist, and when it last checked in | Wearers | To notice if the watch stops working or the battery is low |
| Check-in history: when each check-in happened, the reason for it (for example a possible fall, unusual heart rate, no movement, no contact from the watch, or a family request), how and when it was answered, and who said "I'm on it" | Wearers and family | To run the check-in, alert the right people, and show family what happened |
| Device push tokens | Wearers and family | To send notifications to your watch or iPhone |
| Sign-in sessions (stored in scrambled form) and the time each was last used | Wearers and family | To keep you signed in securely |
| Short-lived invite codes | Wearers | To link a family member to a watch |
| Technical server logs (time, the request made, error details) | Anyone using the apps | To keep the service running and secure |
The reason for a check-in can reveal something about a person's health, such as a possible fall or an unusually low heart rate. We treat it as health information and give it the extra protection the law requires.
We do not collect your email address, contacts, precise location, photos, or any information for advertising. We do not use analytics or tracking tools in the apps.
6. Who can see your information
- Linked family members see the wearer's name, phone number (if given), check-in history, watch status and settings, and the names and phone numbers of the other family members linked to the same wearer. This is the purpose of Close By: a wearer chooses who to link by sharing an invite code.
- Our service providers, only as needed to run the service:
- Apple, for Sign in with Apple and to deliver notifications (Apple Push Notification service). Notifications include the wearer's name and a short message such as "didn't answer a check-in".
- Twilio, to send text-message alerts to family members who have a phone number and text alerts switched on. Twilio receives the recipient's phone number and the message, which includes the wearer's name.
- Cloudflare, which carries the encrypted connection between the apps and our server, and hosts this website.
- Others, only if the law requires it, or to protect someone's life in an emergency.
We never sell personal information, and never share it for advertising or marketing.
7. Where your information is kept
Our server and database run on hardware we manage in [the United Kingdom]. Twilio and Cloudflare may process information in the United States and other countries. Where information leaves the UK we rely on UK adequacy regulations (such as the UK-US data bridge) or the UK International Data Transfer Addendum to protect it.
8. Our legal reasons for using your information
- To provide the service you asked for (contract): running your account, check-ins, alerts and settings.
- Your explicit consent, for health information: the wearer gives this when they set up Close By and allow access to Apple Health, and can withdraw it at any time by turning off Health access or deleting their account.
- Protecting someone's vital interests: in rare cases, alerting family when a wearer may be in danger and cannot respond.
- Our legitimate interests: keeping the service secure and working, and dealing with problems.
9. How long we keep it
- Account details, settings and check-in history are kept while the account exists, and deleted when the account is deleted.
- Invite codes expire after a short time and are deleted when used.
- Device tokens are deleted when Apple tells us they are no longer valid.
- Server logs are kept for up to [30 days].
- Backups are kept for up to [30 days], so deleted information disappears from backups within that time.
10. How we protect it
All connections to our server are encrypted. The server is not reachable directly from the internet. Sign-in is through Apple, and the sign-in tokens we issue are stored only in scrambled (hashed) form. Each person can only see the wearers they are linked to. On your devices, your sign-in is kept in Apple's secure Keychain.
11. Your rights
You can ask us to:
- give you a copy of your information;
- correct anything that is wrong;
- delete your information and your account;
- restrict or object to how we use it;
- send your information to you or another provider in a common format;
- stop using health information, by withdrawing your consent.
To use any of these rights, email [CONTACT EMAIL]. We will reply within one month. You can change check-in and alert settings in the app yourself at any time.
Deleting your account removes your account, settings and phone number. Deleting a wearer's account also deletes their check-in history and unlinks every family member. Deleting a family member's account removes them from the wearer's list. See how to delete your account.
If you are unhappy with how we have handled your information, please tell us first. You also have the right to complain to the Information Commissioner's Office (ICO) at ico.org.uk/make-a-complaint or on 0303 123 1113.
12. Setting up Close By for someone else
Often a relative sets up the watch for the person who will wear it. If you do this, please explain Close By to them, show them this policy, and make sure they are happy to use it. If someone is unable to agree for themselves, only set it up where you are legally able to make that decision for them, such as under a lasting power of attorney for health and welfare.
13. Children
Close By is meant for adults. It is not designed for children under 18, and we do not knowingly collect information about them.
14. This website
This website does not use cookies, analytics or tracking, and does not load anything from other sites. Cloudflare, which hosts it, processes basic technical information such as your IP address to deliver the pages and protect against abuse.
15. Changes to this policy
If we make important changes we will update the date at the top of this page and tell you in the app before they take effect.