1.1. Data Controllers

Our Privacy Policy applies to any Member or visiting nonmember. If you live in the U.S. or if you live outside the U.S., Closers controls your information. The personal information provided to or gathered by Closers is controlled by Closers, 1334 Brittmoore Rd, Houston, TX 77043\. If you have any concern about providing information to us or having such information displayed on the Closers services or otherwise used in any manner permitted in this Privacy Policy and the User Agreement (together also referred to as Closers’ Terms of Service), you should not become a Member of Closers, visit our websites, apps or otherwise use our Services. We collect your personal information in the following ways:

1.2. Registration

When you create an account with us, you provide us with information (including your name, email address, and password) that we use to offer you a personalized, relevant experience on Closers. To create an account on Closers, you must provide us with at least your name, email address and a password. You can choose to provide further information about yourself during the registration process. We use this information to provide you with more customized services like language-specific profile pages, updates, content, and more relevant material. You understand that, by creating an account, Closers will be able to identify you by your Closers profile, and you allow Closers to use this information in accordance with this Privacy Policy. We may also ask for your credit card details if you purchase certain Closers services.

1.3. Profile Information

You can add professional details – like your title, company name, industry, and phone number – to your profile. After you create an account, you may choose to provide additional information on your Closers profile, such as title, company name, industry, and phone number. With your approval, we may also connect third party services to your account. Providing such additional information enables you to derive more benefit from Closers.

1.4. Other Services That Sync with Closers

We collect information when you sync non-Closers content with your account. We use this information to improve your experience. You can remove synced information whenever you'd like. Closers makes other tools available to sync information with Closers, and may also develop additional features that allow Members to use their Closers account in conjunction with other third-party services. For example, Closers’ applications allow you to sync your sales activity from your customer relationship management (CRM) software into Closers as points. Any information that you upload or sync with Closers is covered by the User Agreement and this Privacy Policy. You can remove your information at your convenience using the features Closers makes available or in accordance with Section 3\. You can remove synced information at any time.

1.5. Customer Service

When you contact our Customer Support, we collect information to respond to your questions and better serve you. When you contact our customer support services, we collect information that helps us categorize your question, respond to it, and, if applicable, investigate any breach of our User Agreement or this Privacy Policy. We also use this information to track potential problems and trends and customize our support responses to better serve you.

1.6. Using the Closers Sites and Applications

We collect information when you visit Closers and use our mobile applications. We collect information when you use (whether as a Member or a Visitor) the Closers website applications (for example, Closers for iPhone or Android), Closers platform technology or other Services. If you are logged in on closersapp.com or another Service or a Closers cookie on your device identifies you, your usage information and the log data described in Section 1.9 of this policy, such as your IP address, will be associated with your account. Even if you’re not logged into a Service, we log information about devices used to access our Services, including IP address.

1.7. Cookies

We may use cookies to help personalize your Closers experience. We may use cookies and similar technologies, including mobile application identifiers, to help us recognize you across different Services, improve your Closers experience, increase security, and measure use and effectiveness of our Services. You can control cookies through your browser settings and other tools. By visiting Closers, you consent to the placement of cookies and beacons in your browser and HTML-based emails in accordance with this Privacy Policy and Closers’ Cookie Policy.

1.8. Log Files, IP Addresses, and Information About Your Computer and Mobile Device

At times we may collect information from the devices and networks that you use to access Closers. This information helps us improve and secure our Services. When you visit or leave Closers sites or apps (whether as a Member or Visitor) by clicking a hyperlink or when you view a plugin on a third-party site, we automatically receive the URL of the site from which you came or the one to which you are directed. We also receive the internet protocol (“IP”) address of your computer or the proxy server that you use to access the web, your computer operating system details, your type of web browser, your mobile device (including your mobile device identifier provided by your mobile device operating system), your mobile operating system (if you are accessing Closers using a mobile device), and the name of your ISP or your mobile carrier. We may also receive location data passed to us from third-party services or GPS-enabled devices that you have set up, which we use to show you local information on our mobile or web applications. Most mobile devices allow you to prevent real time location data being sent to Closers, and of course Closers will honor your settings.

2.1. Consent to Closers Processing Information About You

When you join Closers, you acknowledge that information you provide on your profile can be seen by other Members and used by us as described in this Privacy Policy and our User Agreement. The personal information you provide to us may reveal or allow others in your Organization to identify aspects of your life that are not expressly stated on your profile (for example, your picture or your name may reveal your gender). By providing personal information to us when you create or update your account and profile, you are expressly and voluntarily accepting the terms and conditions of Closers’ User Agreement and freely accepting and agreeing to our processing of your personal information in ways set out by this Privacy Policy. Supplying to us any information deemed “sensitive” by applicable law is entirely voluntary on your part. You have the right to withdraw or modify your consent to Closers’ collection and processing of the information you provide at any time, in accordance with the terms of this Privacy Policy and the User Agreement, by changing your account settings or your profile on Closers, or by closing your respective account.

2.2. Closers Communications

2.3. User Communications

At times communications that you initiate through Closers may list your name and profile photo in the header of the message. Messages you initiate may also provide the recipient with aggregate information about you.

2.4. Customized Content

We use information that you provide to us to customize your experience and the experiences of others on Closers.

2.5. Third Parties

2.6. Polls and Surveys

Polls and Surveys may be conducted by Closers. We may use third parties to deliver incentives to you to participate in surveys or polls. If the delivery of incentives requires your contact information, you may be asked to provide personal information to the third party fulfilling the incentive offer, which will be used only for the purpose of delivering incentives and verifying your contact information. It is up to you whether you provide this information, or whether you desire to take advantage of an incentive. Your consent to use any personally identifiable information for the purposes set forth in the poll or survey will be explicitly requested by the party conducting it.

2.7. Search

You can search for Members on Closers. We use personal information from Closers, including Member profiles and Member created content to inform and refine our search service.

2.8. Industries

Closers allows you to join groups called Industries. If you participate in an Industry on Closers, or share content, you should be aware that any information you choose to disclose using these services can be read, collected, and used by other Members. Closers is not responsible for the information you choose to submit in these forums.

2.9. Testimonials and Advertisements Placed through Closers Ads

If you provide any testimonials about our goods or services, with your permission we may post those testimonials you place in connection with our promotion of these services to third parties. Testimonials and advertisements may include your name and other personal information that you have provided.

2.10. Compliance with Legal Process and Other Disclosures

2.11. Disclosures to Others as the Result of a Change in Control or Sale of Closers

We may also disclose your personal information to a third party as part of a sale of the assets of Closers, a subsidiary, or division, or as the result of a change in control of the company or one of its affiliates, or in preparation for any of these events. Any third party to which Closers transfers or sells Closers assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy.

2.12. Service Providers

We may employ third party companies and individuals to facilitate our Services (e.g. maintenance, analysis, audit, marketing and development). These third parties have limited access to your information only to perform these tasks on our behalf and are obligated to Closers not to disclose or use it for other purposes. A list of our service providers can be viewed in section 4.6 of our User Agreement.

3.1. Rights to Access, Correct, or Delete Your Information, and Closing Your Account

3.2. Data Retention

We retain the personal information you provide while your account is in existence or as needed to provide you services. Closers may retain your personal information even after you have closed your account if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between Members, prevent fraud and abuse, or enforce this Privacy Policy and our User Agreement. We may retain personal information, for a limited period of time, if requested by law enforcement. Closers may retain user usage information of our Services for up to 5 years after it was created to provide support-related reporting and trend analysis in order to understand and improve our Services. However, we delete closed account data consistent with Section 3.1. We may store data of users from third party sources under the condition that it is permitted by the users and the holder of such information. Closers Services will ask for the user's consent before storing such data on a Closers account. At any time users have the ability to remove such data from their account.

3.3. Your Obligations

As a Member, you have certain obligations to other Members. Some of these obligations are imposed by applicable law and regulations and others have become commonplace in communities of like-minded Members such as Closers:

• You must, at all times, abide by the terms and conditions of the current Privacy Policy, User Agreement, and other policies of Closers. This includes respecting all intellectual property rights that may belong to third parties, such as trademarks or copyrights.
• You must not upload or otherwise disseminate any information that may infringe on the rights of others or which may be deemed to be injurious, violent, offensive, racist, or xenophobic, or which may otherwise violate the purpose and spirit of Closers and its community of Members.
• You must keep your username and password confidential and not share it with others.

Any violation of these guidelines or those detailed in our User Agreement or elsewhere may lead to the restriction, suspension, or termination of your account at the sole discretion of Closers.

3.4. General Data Protection Regulation (GDPR)

The General Data Protection Regulation (GDPR) is a European privacy regulation which replaces the EU Data Protection Directive called Directive 95/46/EC. The GDPR aims to strengthen the security and protection of personal data in the EU and harmonize EU data protection law. We are big fans of GDPR here at Closers because we think it gives individuals important rights over their data. Closers is committed to always operating in the best interests of our customers and this includes compliance with GDPR. Closers' policy regarding GDPR compliances can he viewed at ourData Protection & GDPR

3.5. California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act (CCPA) is a U.S. law enacted in the State of California effective beginning January 1, 2020\. In general, the CCPA expands the privacy rights of California citizens and requires certain companies to comply with a range of data protection requirements including:

• The consumer’s right to receive a copy of the specific personal information collected about them during the 12 months prior to their request;
• The consumer’s right to know a business’s data collection practices, including the categories of personal information it has collected, the source of the information, the business’s use of the information, and to whom the business disclosed the information it has collected about the consumer;
• The consumer’s right to have such personal information deleted (with exceptions);
• The consumer’s right to know the business’ data sale practices and to request that their personal information not be sold to third parties;
• A prohibition on businesses on discrimination for exercising a consumer right; and
• An obligation on businesses to notify a consumer of their rights.

Closers customers that produce and store personal information are considered "Businesses" under the CCPA. Businesses have the predominant responsibility for ensuring that their personal data processing is compliant with relevant data protection law, including the CCPA. Closers is considered a "Service Provider" under the CCPA and shall collect, access, maintain, use, process and transfer customer personal information and their end-users solely for the purpose of performing our obligations under Closers' existing agreement(s); and, for no commercial purpose other than the execution of such obligations and development of Closers' Services. Closers is committed to always operating in the best interests of our customers and this also includes compliance with the CCPA. As such, Closers addresses data protection requirements throughout this Privacy Policy, ourUser Agreement,Security,Data Protection,Cookie Policyas well as data portability and deletion features in the Closers web app. Also, as described in section 2.5, Closers does not sell customer personal information, meaning that we also do not rent, disclose, release, transfer, make available or otherwise communicate that personal information to a third party for monetary or other valuable consideration.

4.1. Minimum Age

As described in Section 2.3 of the User Agreement, persons must be of Minimum Age to use Closers. The minimum age is sixteen.

4.2. Security

We have implemented security safeguards designed to protect the personal information that you provide in accordance with industry leading security practices such as 2048 bit industry standard SSL, encrypted passwords, and token based authentication for the API (used by the Closers mobile apps to access the data). To protect any data you store on our servers, we also regularly monitor our system for possible vulnerabilities and attacks, and application data is automatically backed up as part of the deployment process on secure, access controlled, and redundant storage. For more information on Closers security, view ourSecurity.

4.3. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. If we make significant changes in the way we treat your personal information, or to the Privacy Policy, we will provide notice to you on the Services or by some other means, such as email. Please review the changes carefully. If you agree to the changes, simply continue to use our Services. If you object to any of the changes to our terms and you no longer wish to use Closers, you may close your account(s). Unless stated otherwise, our current Privacy Policy applies to all information that Closers has about you and your account. Using Closers after a notice of changes has been communicated to you or published on our Services shall constitute consent to the changed terms or practices.