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Data Subject Rights

Under the GDPR, there are obligations on organizations to respect and follow rights of data subjects. Here Closely explains your rights and how we will deal with any requests we may receive from you. More details about your rights you can find in the relevant section of the Closely Privacy Policy.

You have the following rights under the GDPR

Right to be informed (Art 12, Art 13, and Art 14 of the GDPR)
You have the right to be informed, for example, about the fact that your data has been processed, the purpose for which it was processed and the identity of the controller. The information must be clear, concise and transparent, and it must be provided to you in an easily accessible format. Closely always provides such information in the required manner. Please refer to the Closely Privacy Policy to find out more.

Right of access (Art 15 of the GDPR)
You are entitled to ask us for copies of the personal information that we hold about you. At the time of fulfilling your access request, we will provide the following information: (1) reasons why we need to process your data; (2) the types of data we process; (3) recipients or categories of recipient to whom your personal information have been or may be disclosed; (4) retention period for your data or criteria used to determine that period; (5) legal basis to process your data; (6) sources of your data, etc. In certain circumstances Closely may refuse to respond to your request if we consider that it is unfounded, excessive, or repetitive in nature.

Right to rectification (Art 16, Art 18, and Art 19 of the GDPR)
You are entitled to ask us to correct inaccurate information about you or update the information we hold if it is incomplete. If it happens that your personal information is inaccurate, we will correct it. If you consider that personal information we hold about you is incomplete and we do not agree with this, we may offer you the option of adding a supplementary statement explaining why you consider the information we hold is incomplete.

Right to erasure (‘right to be forgotten’) (Art 17 and Art 19 of the GDPR)
You have the right to request that we erase your personal information if: (1) we are storing your personal information for longer than is necessary or in breach of a legal obligation that requires its erasure; (2) you decide to withdraw your consent and you ask us to erase your personal information where there is no other legal ground for processing; (3) we have accepted an objection made by you to our processing of your personal information and you have further requested that we erase the personal information in question; or (4) we are processing or publishing your personal information without a legal basis for doing so. We will carefully consider a request for erasure. There are circumstances why it may not always be possible to agree to your erasure request and we have listed a number of grounds below where it may be necessary for us to retain your information, e.g., in order to comply with a legal obligation or for exercising legal rights or defending legal claims.

Right to restrict processing (Art 19 of the GDPR)
This means that you can limit the way that Closely uses your data. This is an alternative to requesting the erasure of your data. You have the right to restrict the processing of your personal data where you have a particular reason for wanting the restriction. This may be because you have issues with the content of the information we hold or how we have processed the data. In most cases any restriction will not be put in place indefinitely, but for a certain period of time. You have the right to request that we restrict the processing of your personal data in the following circumstances: (1) you challenge the accuracy of your personal data and you request that we verify its accuracy; (2) your data has been unlawfully processed but rather than request erasure, you wish to restrict processing; (3) we no longer need the personal data but the you need us to keep it in order to establish, exercise or defend a legal claim; or (4) you have objected to us processing your data, and we are considering whether our legitimate grounds override yours. The GDPR suggests a number of different methods that you could use to restrict data, such as: (1) temporarily move the data to another processing system; (2) make the data unavailable to others; or (3) temporarily remove published data from our system.

Right to data portability (Art 20 of the GDPR)
In certain circumstances, you have the right to request that personal information you have supplied to us be converted into a structured, commonly used and machine-readable format so that it can be transmitted to another provider. This right is primarily intended to stimulate competition in the commercial sector by making it easier for consumers to switch from one supplier to another.

Right to object (Art 21 of the GDPR)
You have the right to object to us using your personal data where it is being processed for: (1) direct marketing; (2) profiling whether linked to direct marketing; (3) our legitimate interest or those of a third party; (4) scientific/historical research/statistics where: this is likely to cause substantial damage or substantial or distress; or involves decision-making about you. If you object to us processing your personal data for any of the other reasons above, we will consider if we have compelling legitimate grounds for continued processing, and whether or not these grounds are sufficiently compelling to justify overriding your privacy rights.

Rights in relation to automated decision making and profiling (Art 22 of the GDPR)
You have the right to not be subject to a decision based solely on automated processing. Processing is “automated” where it is carried out without human intervention and where it produces legal effects or significantly affects you. Automated processing includes profiling. But there are some exceptions where automated decision-making is permitted. This is where the processing: (1) is based on your explicit consent; (2) is necessary for entering into or the performance of a contract with you; (3) it is required or authorized by law. Where an automated decision is made about you based on one of the reasons above, you are entitled to be: (1) informed that our processing activity involves automated decision making and to be informed about the logic involved and the likely consequences of the processing for you; (2) told what measures and safeguards processor/controller implemented to protect your privacy. Here, in Closely, you are not subject to a decision based solely on automated processing.

Exceptions of the Rights

Some of the abovementioned rights are not absolute and are subject to conditions and exemptions. In some cases the rights described above only apply if the processing activity is undertaken on specific legal grounds and/or in defined circumstances. Therefore all of these rights are unlikely to be engaged in all cases.

How to submit a request?

You can submit your request: (1) by contacting our Data Protection Officer via this form, or (2) by making a request to [email protected]. You may also exercise your right to object via a special Opt-Out Page.

Please note that all requests are being reviewed by our DPO; thus, if you submit a request via our support email, it may take some time to route it to the DPO. We recommend using the respective contact form to deliver your request to the DPO directly and reduce time for processing of your request.

How long does it take to process a request?

We will provide information on action taken on your request related to your rights within one month of receipt of the request for the longest. That period may be extended by two further months if we are overwhelmed by the number of requests. We will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.

Do I need to upload my documents?

No! In most cases, Closely does not need any of your documents to process your request. Moreover, by default, we kindly ask you not to upload any ID or other documents that may contain your personal data. Closely does not have any intention to process excessive data of yours. If we have any compelling doubts about your identity, our DPO will especially contact you and request additional information.

Who can submit a request for me?

You or any other person authorized by you (a friend, relative, your lawyer, etc.). However, this person must supply written authority from you to confirm that they are acting on your behalf; we will still require identification for you.