Privacy Policy

1. Scope and who this Policy covers

This Privacy Policy explains how Two 15 Foundry, LLC dba KinKeeper (“KinKeeper,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal information in connection with kinkeeper.com, my.kinkeeper.com, our applications, products, tools, communications, and related services (collectively, the “Service”).

This Policy applies to website visitors, Account Holders, Protected Persons, Kin Circle members, people who use our tools or receive communications, organization administrators, and members or invitees of an organization Program. It does not govern a third party’s independent practices. A separate notice presented by a provider or during a particular enrollment may also apply.

2. People and roles in KinKeeper

The same person may have more than one role:

• Account Holder: an adult who creates or manages a KinKeeper account;
• Protected Person: the person whose financial activity, privacy, identity warning signs, or wellbeing is the subject of a feature;
• Kin Circle member: a trusted person invited to receive information or help according to permissions chosen in the Service;
• Payer or Sponsoring Organization: a person or organization that pays for access but does not receive private Service data merely because it pays; and
• Organization administrator or Program member: a person who configures, is invited to, or enrolls in a KinKeeper organization Program.

When one person acts for another, we may collect information and consent records for both the Acting Party and Protected Person. Certain features require the Protected Person’s direct consent or proof of other lawful authority.

3. Information we collect

The information we collect depends on the features you use and choices you make. It may include:

• Account and identity information: name, email address, phone number, postal address, date of birth, login identifiers, account preferences, and other information used to create, secure, or verify an account;
• Family and relationship information: names, contact details, relationship, time zone, permissions, invitations, and Kin Circle membership;
• Consent and authority records: the notice shown, choices made, date, time, method, document version, acting role, and evidence of authorization;
• Payment and subscription information: plan, price, billing status, transaction identifiers, and limited payment-method details from our payment provider. KinKeeper does not store full card numbers on its servers;
• Content you provide: notes, reminders, documents, images, messages, support requests, survey responses, and other information you choose to submit;
• Tool submissions and results: text, images, email addresses, answers, or other content submitted to a free tool, and the analysis or result generated. A tool-specific notice may describe narrower collection or temporary processing;
• Device, usage, and security data: IP address, browser, operating system, device and advertising identifiers where permitted, pages and features used, clicks, timestamps, referring URLs, approximate location derived from IP address, diagnostics, audit logs, and suspected fraud or abuse signals; and
• Cookies and similar technologies: information used to operate the site, remember preferences, measure performance, and understand acquisition and usage.

4. Financial connection data

If you use Money features, you choose which supported financial accounts to connect through Plaid. Depending on the accounts and features selected, KinKeeper may receive:

• financial institution and account names, account types, masked account identifiers, ownership or authorization information, and connection status;
• balances, transaction dates, amounts, descriptions, merchant and category information, pending status, and recurring transaction or subscription insights; and
• connection tokens, refresh status, errors, and other technical information needed to maintain the read-only connection.

Plaid may collect the credentials or authentication information required by your financial institution. KinKeeper does not receive or store your financial-institution username or password. KinKeeper’s connection is designed to retrieve supported data and cannot move money or control your account.

Plaid’s own collection and processing are governed by its End User Privacy Policy and notices shown in Plaid Link. The person who owns the connected financial account can disconnect it through KinKeeper. Disconnecting asks Plaid to revoke KinKeeper’s access and removes KinKeeper’s stored connection, account, transaction, recurring-payment, alert, and feedback data associated with that connection. KinKeeper may retain a limited tombstone, audit, billing, or compliance record as described in Section 13. Plaid and the financial institution may retain information independently under their policies.

5. Privacy and Identity data

To provide Privacy or Identity features, KinKeeper and its providers may process identifiers and sensitive personal information used to locate, match, monitor, remove, or respond to supported records. Depending on the feature, this may include name, aliases, age or date of birth, current and prior addresses, email addresses, phone numbers, relatives, and sensitive identifiers such as a Social Security number.

We may receive likely people-search or data-broker matches, fields associated with a listing, opt-out requests and authorization, submission status, removal results, and recheck history. Identity data may include supported breach, dark-web, Social Security number, or change-of-address warning signs; masked affected values; event metadata; and response, restoration, or insurance eligibility information where offered.

For the public Email Breach Check, the full email address you submit is sent to Have I Been Pwned to check known breach records. KinKeeper does not add that address to marketing from the lookup. For a public lookup, KinKeeper may briefly cache an encrypted result under an application-secret identifier that does not contain the email. If you add a monitored email to a KinKeeper account, the email and resulting scan history are retained with that account as described in Section 13.

We use sensitive identifiers only as reasonably needed to provide, secure, support, and comply with the requested feature. Full sensitive values are masked in ordinary product views where the feature permits. Provider-specific terms and privacy notices presented during activation may also apply.

6. Wellbeing and communications data

Wellbeing features may collect or generate schedules, time zones, reminders, call and text preferences, recipient consent, contact attempts, delivery and call status, acknowledgments, check-in responses, needs-help responses, retry and escalation history, and the Kin Circle recipients configured to receive updates.

When a call feature includes recording, we provide notice and collect consent as required. We may process call audio, transcripts, summaries, topics, automated call-tone labels, operational flags, and other outputs to deliver the feature, provide the chosen update, improve quality, investigate an issue, and secure the Service. Automated outputs may be inaccurate and are not medical, clinical, diagnostic, or health assessments.

Twilio provides voice and messaging infrastructure and processes communications content and metadata—such as phone numbers, routing, date, time, duration, delivery status, and errors—on our behalf. Twilio’s independent practices are described in its Privacy Notice.

7. Organization Programs

An organization may provide eligibility, contact, invitation, enrollment, sponsorship, and Program-administration information so it can offer KinKeeper as a benefit. We use that information to operate invitations, eligibility, sponsorship, billing, and aggregate Program reporting.

Paying for or sponsoring KinKeeper does not give an organization access to a member’s private Service data. Unless a person separately grants access through a supported Kin Circle or sharing feature, an organization does not receive individual transactions, privacy-removal records, identity warnings, wellbeing responses, call content, or Kin Circle communications. Organization administrators may receive only the administrative and aggregate information KinKeeper makes available, such as invitation, eligibility, enrollment, sponsorship, subscription or payment status (but not full payment-card details), overall adoption, and aggregate Program financial reporting.

The organization is independently responsible for its collection and use of information before it provides that information to KinKeeper. Its own privacy notice may also apply.

8. Where information comes from

We collect information:

• directly from you and from people who interact with the Service;
• from another person you authorize, a Kin Circle member, or an organization administering a Program;
• from financial institutions and data providers when you connect or activate a feature, including Plaid and supported privacy or identity providers;
• from communications, payment, authentication, hosting, analytics, support, security, and fraud-prevention providers;
• from public records, people-search sites, data brokers, breach sources, and other sources used by a feature; and
• automatically from your device and use of the Service.

9. How we use information

We use personal information to:

• provide, personalize, maintain, and support the Service and requested protections;
• create and secure accounts, verify authority, and maintain consent records;
• connect supported financial accounts, surface signals and insights, submit supported privacy requests, deliver identity warnings, and operate wellbeing communications;
• process payments, subscriptions, sponsorship, partner margin, and Program billing;
• send service, security, billing, legal, support, and consented marketing messages;
• measure performance, understand usage, conduct research, and improve or develop the Service. Identifiable sensitive, financial, call, or wellbeing-communication information is used for improvement only as permitted by law, provider terms, and any required consent; we use aggregated or de-identified information for general model improvement unless a person separately agrees;
• detect, investigate, prevent, and respond to fraud, abuse, security incidents, technical problems, and violations of our terms; and
• comply with law, enforce agreements, and protect people, rights, and property.

KinKeeper does not use Service data to make eligibility decisions about employment, housing, credit, insurance, or another legally significant opportunity.

10. How we disclose information

We may disclose information:

• At your direction: to a Kin Circle member, Acting Party, Protected Person, professional, or other person you choose, according to available permissions;
• To service providers: companies that support financial connections, communications, payments, privacy and identity features, authentication, hosting, customer communications, analytics, support, security, and fraud prevention. Current examples include Plaid, Have I Been Pwned, Twilio, Stripe, Customer.io, and Google Analytics. They process information under contractual or independent legal terms applicable to their role;
• To an organization: only the Program-administration and aggregate information described in Section 7, unless you separately authorize more;
• For legal and safety reasons: when we reasonably believe disclosure is required by law, legal process, or to protect a person, rights, property, or the Service; and
• In a business transaction: in connection with a financing, merger, acquisition, reorganization, or sale of assets, subject to appropriate protections.

We may disclose aggregated or de-identified information that cannot reasonably identify you. We do not sell personal information, and we do not share personal information for cross-context behavioral advertising.

11. Mobile information and messaging consent

We send recurring automated service texts and calls only after the consent required for the recipient and feature is recorded. Message frequency varies; message and data rates may apply. Consent to receive automated marketing texts or calls is not a condition of purchase. Reply STOP to an eligible text to opt out and HELP for help, or use available settings and support channels.

We do not share, sell, or otherwise provide your mobile phone number or messaging consent information to any third parties or affiliates for marketing or promotional purposes. We use your mobile phone number and messaging consent solely to operate and deliver the Service, including through our messaging provider (Twilio), which processes this information only on our behalf and not for its own marketing purposes.

See Notification Preferences for current program disclosures, sample messages, and available choices.

12. Cookies and analytics

We use cookies and similar technologies to operate the site, maintain security, remember preferences, understand acquisition and usage, and measure performance. Google Analytics and similar providers may set or read their own identifiers according to their notices. You can control cookies through browser settings and available device controls; disabling some technologies may affect functionality.

We do not currently use website cookies to sell personal information or share it for cross-context behavioral advertising.

13. Retention

We retain information for as long as reasonably needed to provide the Service, maintain an account or connection, honor your choices, resolve disputes, secure the Service, enforce agreements, and meet legal, tax, insurance, audit, and regulatory obligations.

Retention varies by information and feature. For example, consent and transaction records may be retained to demonstrate authorization or compliance; provider data may refresh or expire; and deletion of an account may not immediately remove backups or records we must retain. When information is no longer needed, we delete or de-identify it in accordance with our processes and applicable law.

Unclaimed public Privacy-scan records are generally scheduled for deletion after about 30 days. An encrypted public Email Breach Check result is ordinarily cached for about 15 minutes; monitored-email and scan history added to an account remains with the account under this Section. Primary raw transcripts from recorded wellbeing interactions are generally scheduled for deletion after approximately 60 days. Summaries, outcomes, automated call-tone labels, and continuity information may remain with the account until removed, the account is deleted, or the information is no longer needed; backups and required audit records may persist as described above.

14. Security

We use administrative, technical, and physical safeguards designed to protect personal information, including permission-based access, encryption in transit and at rest where appropriate, vendor controls, logging, and incident-response processes. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Learn more on our Security Practices page. If you believe your account or information has been compromised, contact us promptly.

15. Your privacy rights and choices

Depending on where you live and subject to applicable exceptions, you may have the right to request access to, correction or deletion of, or a portable copy of personal information; to learn about categories, sources, purposes, and recipients; to opt out of sale, sharing, targeted advertising, or certain profiling; to limit certain uses of sensitive personal information; and to appeal a denied request. You also have the right not to receive discriminatory treatment for exercising a privacy right.

KinKeeper does not sell personal information or share it for cross-context behavioral advertising, so there is no separate sale or sharing opt-out needed for our current practices. You may disconnect supported financial accounts, change Kin Circle and communication settings, unsubscribe from marketing email, and reply STOP to eligible texts.

To submit a privacy request, email support@kinkeeper.com with “Privacy request” in the subject. We will verify your identity and authority before completing a request. An authorized agent may submit a request where permitted, but we may require proof of authorization and direct verification. If we deny a request, you may appeal by replying to our decision. You may also have a right to contact your state attorney general.

Your request to KinKeeper does not automatically delete information independently held by Plaid, a financial institution, a data broker, a Kin Circle recipient, an organization, or another provider. Contact that party directly to exercise rights under its policy.

16. Children

The Service is not directed to anyone under 18, and we do not knowingly permit a minor to create an account. We do not knowingly collect personal information directly from a child under 13. If you believe a minor has provided information to us, contact us so we can review and delete it as required by law.

17. Where we operate

KinKeeper operates the Service in the United States and intends it for U.S. users unless expressly stated otherwise. Information may be processed and stored in the United States and in other locations where our service providers operate, subject to applicable law and contractual safeguards.

KinKeeper is a consumer family-support and financial-safety service, not a healthcare provider, medical-record system, clinical service, or emergency service. Do not use the Service to submit or store detailed medical or clinical records.

18. Changes to this Policy

We may update this Policy to reflect changes in law, technology, providers, products, or our practices. We will revise the date above and provide additional notice of material changes when appropriate. Where required, we will obtain consent before using previously collected information in a materially different way.

19. Contact us

Questions, concerns, or privacy requests may be sent to:

Please also review our Terms of Service, Notification Preferences, and Security Practices.