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Privacy Policy

This Privacy Policy explains how [Company Legal Name] (“we,” “us,” or “our”) collects, uses, shares, and protects personal information in connection with the CLOSR platform and related services (the “Service”). By using the Service, you acknowledge that you have read and understood this Policy.

1. Scope & Our Role

This Policy applies to personal information processed through the Service, our website, and related communications.

1.1 When We Are a Controller

We act as a data controller for information collected directly from our customers, prospects, website visitors, and account administrators — for example, billing details, account registration data, and marketing communications.

1.2 When We Are a Processor

For data uploaded into the Service by our customers (such as their contacts, leads, deal records, and communications with end customers), we act as a data processor. The customer is the controller of that data and is responsible for its lawful collection and use. Our processing of that data is governed by our agreement with the customer and, where applicable, a Data Processing Agreement.

2. Information We Collect

2.1 Account & Profile Information

Name, email address, phone number, job title, company name, profile picture, password, and similar identifiers.

2.2 Billing & Payment Information

Billing address, tax identifiers, and partial payment card details (full payment card numbers are handled by our payment processor and are not stored on our systems).

2.3 Customer Data

Information you upload, import, or generate within the Service, including contacts, leads, accounts, deal records, notes, tasks, files, and communications with your own customers and prospects.

2.4 Usage & Device Information

Log data, IP address, browser type, operating system, device identifiers, referring URLs, pages viewed, features used, timestamps, and similar technical information.

2.5 Communications

Records of your interactions with our support team, surveys, feedback, and other communications you send to us.

2.6 Marketing & Cookie Data

Information collected via cookies and similar technologies for analytics, personalization, and marketing (see Section 13).

3. How We Collect Information

  • Directly from you when you register, configure your account, contact us, or use the Service;
  • Automatically through cookies, log files, and analytics tools when you interact with the Service or our website;
  • From third parties such as integration partners, payment processors, identity providers (e.g., for single sign-on), and publicly available sources, where permitted by law.

4. How We Use Information

We use personal information to:

  • Provide, operate, and maintain the Service;
  • Authenticate users and secure accounts;
  • Process payments and manage subscriptions;
  • Provide customer support and respond to inquiries;
  • Personalize the user experience and improve usability;
  • Develop, test, and improve features, including AI Features (see Section 7);
  • Send service-related communications, security alerts, and administrative messages;
  • Send marketing communications (where permitted and subject to your preferences);
  • Detect, prevent, and investigate fraud, abuse, and security incidents;
  • Comply with legal obligations and enforce our Terms.

5. Legal Bases for Processing

Where applicable law requires a legal basis for processing personal information, we rely on the following:

PurposeLegal Basis
Providing the Service to youPerformance of a contract
Billing and paymentPerformance of a contract / legal obligation
Service improvement, analytics, securityLegitimate interests
Marketing communicationsConsent or legitimate interests (per applicable law)
Compliance with legal obligationsLegal obligation

6. How We Share Information

We do not sell personal information. We share information only as described below:

  • Service providers / sub-processors: Hosting providers, payment processors, analytics providers, communication tools, and AI providers that help us deliver the Service, bound by confidentiality and data protection obligations;
  • Integration partners: Third-Party Services you choose to connect, only as needed to deliver the integration you enabled (see Section 8);
  • Within your organization: Account administrators may have visibility into User activity, settings, and Customer Data;
  • Legal & safety: Where required by law, court order, or to protect the rights, safety, and property of our users, the public, or us;
  • Business transfers: In connection with a merger, acquisition, financing, or sale of assets, subject to standard confidentiality protections.

A current list of our sub-processors is available upon request.

7. AI Features & Data Processing

Certain features of the Service use artificial intelligence and machine learning (“AI Features”), such as lead scoring, email drafting, conversation summaries, and sales forecasting.

  • No training on your data without consent: We do not use Customer Data to train shared or foundation AI models that benefit other customers unless you expressly opt in;
  • Limited processing: When you use an AI Feature, the relevant Customer Data may be sent to AI service providers solely to generate the requested output;
  • Provider safeguards: Our AI providers are contractually required to protect your data, limit its use to providing the AI service, and not retain it for training their own models beyond what is needed for service delivery;
  • Human oversight: AI output may be inaccurate or incomplete. You should review AI-generated content before acting on it, particularly for consequential decisions.

8. Third-Party Integrations

You may connect the Service to third-party applications such as email providers, calendars, communication tools, marketing platforms, and analytics services. When you enable an integration:

  • You authorize the exchange of data between the Service and the third-party application;
  • The third party's collection and use of data is governed by its own privacy policy, not ours;
  • You can disconnect integrations at any time through your account settings, though previously transferred data may remain with the third party.

We are not responsible for the privacy practices of any Third-Party Service. We recommend reviewing the privacy policies of any integration you enable.

9. International Data Transfers

We and our service providers may process personal information in countries other than the country in which it was collected. Where required by law, we implement appropriate safeguards for international transfers, such as standard contractual clauses, adequacy decisions, or equivalent legal mechanisms.

10. Data Retention

We retain personal information for as long as needed to provide the Service, comply with legal obligations, resolve disputes, and enforce our agreements. Specifically:

  • Customer Data is retained for the duration of your subscription and made available for export for a limited period (typically 30 days) after termination, after which it is deleted or anonymized;
  • Account and billing records may be retained as required by tax, accounting, or other legal obligations;
  • Log and usage data is typically retained for a limited period for security, analytics, and operational purposes.

11. Security

We implement administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, and destruction. Measures may include encryption in transit and at rest, access controls, network segmentation, monitoring, regular security testing, and employee training.

No system is completely secure. You are responsible for safeguarding your account credentials and using strong, unique passwords.

12. Your Rights & Choices

Depending on your location and applicable law, you may have the following rights regarding your personal information:

  • Access to the personal information we hold about you;
  • Correction of inaccurate or incomplete information;
  • Deletion of personal information, subject to legal exceptions;
  • Restriction or objection to certain processing activities;
  • Data portability in a structured, commonly used format;
  • Withdrawal of consent, where processing is based on consent;
  • Opt-out of marketing communications at any time via the unsubscribe link or account settings;
  • Complaint to a data protection authority, if you believe your rights have been violated.

To exercise your rights, contact us at privacy@yourcompany.com. If your personal information was provided to us by a customer using the Service (e.g., you are a contact in a customer's CRM), please direct your request to that customer; we will assist them as required.

13. Cookies & Tracking Technologies

We use cookies, web beacons, and similar technologies to operate the Service, remember your preferences, analyze usage, and support marketing. Categories include:

  • Strictly necessary cookies required for the Service to function (e.g., authentication);
  • Functional cookies that remember your settings and preferences;
  • Analytics cookies that help us understand how the Service is used;
  • Marketing cookies used to measure and personalize advertising, where applicable.

You can manage cookies through your browser settings or, where available, through the cookie preferences tool on our website. Disabling certain cookies may affect the functionality of the Service.

14. Children's Privacy

The Service is not intended for individuals under the age of 16, and we do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will take appropriate steps to delete it.

15. Changes to This Policy

We may update this Policy from time to time. Material changes will be communicated by email or through the Service before they take effect, where reasonably practicable. The “Last Updated” date at the top reflects the most recent revision. Your continued use of the Service after updates take effect constitutes acceptance of the revised Policy.

16. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our handling of personal information, please contact us at:

[Company Legal Name]
Attn: Privacy Team
[Street Address]
[City, Region, Postal Code, Country]
Email: privacy@yourcompany.com

If we have appointed a Data Protection Officer or EU/UK representative, their contact details will be listed here: [Insert DPO / Representative details if applicable].

© 2026 CLOSR. All rights reserved.
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