Privacy Policy

Who we are

Cairn is operated by My Cairn Limited (“we”, “us”, “our”), a company registered in England and Wales (company number 17456986), with registered office at 124-128 City Road, London, EC1V 2NX.

We are the data controller for the personal information described in this policy. We are registered with the Information Commissioner’s Office (ICO), registration number ZC248308. If you have any questions about this policy or how we handle your data, contact us at privacy@mycairn.co.uk.

What data we collect

Information you give us

• Account details: your email address and password (stored only in scrambled, hashed form), and whether you use two-step login
• About you: your name, date of birth and home address, which we use to identify you, including at handover
• Your sign-up answers: roughly what you have (for example how many pensions or policies), how your family would find it today, and the first name and relationship of the person who would need to find everything. These are kept with your account
• Your records: the details you choose to add about your accounts, savings, pensions, investments, property, mortgages, loans, insurance policies (for example insurer, policy number, cover and renewal date) and possessions
• Legacy information: where your will and powers of attorney are kept, your funeral wishes, letters and life story notes, and gifts you want to leave
• Documents: PDFs you upload or email to your private Cairn address
• Trusted contacts: the people you name (see “Information about other people”)
• Payment details: your name, email and billing address are collected by Stripe when you pay. We never see or store your card number
• Messages: what you send us, for example a support request or a request for your data

You are in control of what you add. Some of it, especially insurance documents for life, critical illness, income protection or health cover, may contain information about your health. We treat that as special category data (see “Our legal basis”).

Information we collect automatically

• App usage: which screens and buttons you use while signed in. We log behaviour only, never the content of your records. A short-lived session identifier groups this activity; it is held only in memory and is not stored on your device
• Device and browser: your device type, operating system and browser
• Errors and diagnostics: if something goes wrong, or as you move through sign-up and payment, we record what happened (for example the page, the step and a scrubbed error message, with no form contents, names, emails or amounts) and a reference shown on the error screen. If you are signed in, this is linked to your account so we can help you
• Sign-in and security logs: when you signed in, and from which IP address
• Website analytics: anonymous visit counts (Plausible, no cookies), and, only if you accept analytics, how visitors use our public pages (PostHog). See our Cookie Policy

How we use your data

• Provide Cairn: storing your records and documents so you can keep them in one place, and handing them over to the people you chose when the time comes
• Sign you in and keep your account secure, including bot checks, rate limits and investigating misuse
• Read documents with AI, if you ask us to: pulling out policy details and answering your questions about a policy
• Reminders and prompts: using your own records to flag things that may need a look, such as an insurance renewal you asked to be reminded about
• Take payments and manage your membership, refunds and disputes
• Talk to you: essential emails about your account, security and billing and, only if you have opted in, occasional news about Cairn. You can unsubscribe at any time in Your account or from any of those emails
• Fix problems and improve Cairn, using error reports, usage data and anonymised statistics
• Meet our legal obligations, for example keeping payment records for tax

We do not sell your personal data, use it for advertising, or share it with banks, insurers or other financial companies. Cairn does not give financial advice.

Our legal basis

• Contract: storing and handing over your records, your account, payments, reminders you set and essential emails are needed to provide the service you signed up for
• Explicit consent: AI reading of your documents. Because those documents may contain health information, we only send them to our AI provider after you tick a box giving your explicit consent (UK GDPR Article 9(2)(a)). You can withdraw it at any time in Your account; this stops any new documents being sent. You never have to use AI: you can type everything in yourself. If you choose to store health-related documents or details without AI, we hold them because you have explicitly asked us to keep them as part of your record
• Consent: marketing emails, and optional website analytics (PostHog), which only run if you accept them and stop when you change your choice
• Legitimate interests: in-app usage analytics, error reports and security logs, to run, secure and improve Cairn, in each case only where this doesn’t override your rights. We have written down how we weighed this, and you can ask us for a copy. You can object (see “Your rights”)
• Legal obligation: records we must keep by law

Who we share your data with

We use a small number of companies to run Cairn. They handle your data only to provide their service to us, under a written agreement that requires them to keep it secure and confidential. Each company’s name links to its own privacy policy.

We will update this list before we start using a new company to handle your data. Last updated: 19 October 2026.

We only share your data with anyone else when you have asked us to (for example the handover to your trusted contacts described in our Terms), or when the law requires it (for example a court order). Our fonts are served from our own website, so loading a page doesn’t send your details to a font provider.

Where your data is stored

Your Cairn account, records and documents are stored in the UK, in Supabase’s London data centre, with encrypted backups in Amazon’s London data centre.

Some of the companies above are based in, or process data in, the USA or the EU. The EU is recognised under UK law as protecting personal data to the same standard as the UK. When data goes to the USA, it is protected either by the UK–US data bridge, for companies certified under it, or by the UK’s approved contract terms for international transfers.

How long we keep your data

While you’re a member, we keep your data for as long as your account is open. You can ask for a copy of your data, or delete your account, at any time from Your account.

Things you delete inside your account are kept for 30 days in case you deleted something by mistake. Contact us within that time and we can restore it. After 30 days they are deleted for good, including any document file.

If you delete your account, we delete your records and documents straight away. Backup copies, which are encrypted and kept in the UK, are deleted automatically within 7 days.

If your membership ends and you don’t renew, we keep your account for 1 year so you can come back and pick up where you left off. We’ll email you at least 30 days before we delete it. After that, we delete it in the same way. If we have been told that you have died, or there is an open complaint or dispute, we pause this until it is resolved.

What we have to keep: some records must be kept by law after an account is deleted, for example payment records, which we keep for 6 years for tax purposes. We also keep a minimal record that your account was deleted, and a record of any time our staff accessed your account to help you, so we can show we acted properly. We keep these for 6 years. They contain no financial details from your account. Stripe keeps its own payment records as a regulated payment company.

Unfinished sign-ups: if you start signing up but never enter the code we email you, we delete the login after 7 days. If you enter the code but never pay, we delete it after 30 days.

Error and diagnostic records are kept for 90 days, then deleted.

Sign-in and security logs (for example when you signed in, and from which IP address) are kept for up to 12 months to protect your account, then deleted.

Emails sent to a Cairn address that doesn’t belong to an account: we keep the sender and subject for 30 days, to deal with problems and abuse, then delete them.

Messages from people without an account, including reports that a member has died, are kept while we deal with them and for as long as we may need them to answer questions about what happened, and we review them at least once a year.

We may keep anonymised statistics, which can’t identify you, indefinitely. When an account is deleted we keep an anonymous summary, for example how long you were a member and roughly how many accounts or policies you had added. It contains no name, email or account ID and can’t be linked back to you.

Information about other people

Trusted contacts. If a member names you as a trusted contact, we hold the details they give us (your name, email address, relationship, date of birth and address) as part of their account, so we can contact you and check your identity at handover. We may email you your access code if the member asks us to. Your details are deleted when the member removes you or deletes their account. You can contact us at any time to ask what we hold about you or to be removed.

Other people in your records. Your records and documents may mention other people, for example a beneficiary on a policy. Only add what you need, and only where you are entitled to share it.

Reporting a death. If you tell us that a member has died, we use the details you give us (and those about the member) to check the report, contact the member first, and carry out the handover described in our Terms.

Cairn is for keeping your own records. It is not designed for managing someone else’s affairs.

Your rights

Under UK data protection law you have the right to access, correct, delete, restrict, object to, and port your personal data, and to withdraw any consent you have given. To use any of these rights, contact us at privacy@mycairn.co.uk, or use Your account in the app. We may need to check it’s really you first. We will respond within one month.

We analyse how signed-in members use the app (behaviour only, never the content of your records) on the basis of our legitimate interest in running and improving Cairn. You can object to this at any time by contacting us, and we will stop analysing your usage.

Complaints. If you are unhappy with how we have handled your personal data, please tell us first at privacy@mycairn.co.uk. We will acknowledge your complaint within 30 days (usually within 2 working days), look into it, keep you updated and tell you the outcome without undue delay. See our Complaints page. You also have the right to complain to the Information Commissioner’s Office (ICO) at ico.org.uk or 0303 123 1113.

Security

All data is encrypted in transit (HTTPS) and at rest. Access to your data is protected by Row-Level Security, so no member can access another member’s records, and staff can only view an account for a short time, for a specific support request, with every access logged. We strongly recommend a unique, strong password and two-step login.

Children

Cairn is not intended for anyone under the age of 18. We do not knowingly collect data from children.

Changes to this policy

We will email you before any material change to this policy takes effect.