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CLOSELY PRIVACY POLICY

Effective Date: May 1, 2022

This privacy policy (the “Policy”) is an integral part of the Closely Terms of Use (the “Terms”). All the terms used herein are used with the same meanings as the Terms provide unless otherwise are directly set out hereby.

We are committed to protecting and respecting your privacy, so we take your privacy seriously and will use your personal data (the “data”) to provide the services only after obtaining your consent for the collection and processing of your data as follows. The Policy explains what data, when, where, and why we collect the data of yours, on what legal basis we process and how do we use it, the conditions under which we may disclose the data to others, your rights in respect of your personal information, as well as how we keep it secure.

Since we use cookies, please check our Cookie Policy, where we also describe the purpose and means we do it with. Whether you have any questions, please contact us at: [email protected]

1. CHANGES AND UPDATES TO POLICY

We may revise the Policy according to new developments or advances in legislation and the broader data protection landscape from time to time, so please check this page to ensure that you’re OK with any changes.

If we make any changes, a notification regarding changes may be rendered to you by publishing at https://closelyhq.com/pp.

2. YOUR DATA CONTROLLER AND DATA PROCESSORS; THIRD PARTIES AND DISCLOSE OF THE DATA

The first you should know is information about your data controller and processors. The data controller is an entity that determines the purposes and means of the processing of the data. The data processor is an entity that processes the data on behalf of the controller.

In this current case, your data controller toward the Client’s data (as specified below) is Esterson Limited., registered address: 75 Prodromou Avenue, Oneworld Parkview House, 4th floor, Nicosia 2063, Cyprus. Still, Closely processes Business and Shared Data as a processor on behalf of our Client. All processing activities performed on this basis are framed in a lawful and secure way, pursuant to Closely Data Processing Agreement. If you send us any request relating to such personal data, Closely will promptly redirect the request to our relevant Client.

Where there will be a necessity, we may also engage third-party services (providers) and may share the data with them. That will help us operate, provide, improve, integrate, customize, support, and market our service, the Website and Platform. We share the data, in particular, for purposes indicated in section 5 hereof. The types of third parties we share information with include, in particular: cloud storage providers; data analytics providers; measurement partners; marketing partners; payment processing providers; communication services providers, etc. By providing us with the services, those providers will also be your data processors.

Closely shares the Business and Shared Data with our Clients, for the purpose of providing our Services and Platform and allowing access to authentic, current, and up to date business contact information.

We may share the Business and Shared Data with our affiliates who may act for us for any of the purposes set out in this Privacy Policy, including our current and future parents, subsidiaries, and other companies under common control and ownership with Closely.

We may also use and disclose the data to enforce the Terms, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

If we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use Standard Contractual Clauses approved by the European Commission on June 4, 2021.

3. NOTE ABOUT CHILDREN

You are prohibited to use the Website and Platform where you are under 18 or age of legal majority in your country. We do not knowingly process personal data from persons under 18 years of age.

If a minor submits personal information to us and we learn that the personal information is the information of a child under the legal age range, we will attempt to delete the information as soon as possible. If you believe that we may have any personal information of a child under the legal age range, please contact us at [email protected].

4. DATA THAT WE PROCESS; DATA SOURCES

The data is any information relating to you. That alone or in cumulation with other information pieces allows the person who collected and processed such information to identify you as a person. Processing of the data means any action with your data, including, but not limited to, collecting, storing, transferring, etc.

We solely or with help of other data processors may process the following personal data:

  1. Business Data. Closely may obtain business data of businesspeople and companies, “Business Data” — name, business email address, business phone number, website, and social media account address, including LinkedIn URL-address, job title, seniority and role, company name, country/state of business, other publicly available business data from different sources:
    • Closely’s search technology scanning the web and gathers publicly available information;
    • Closely gets information from it’s reliable partners, other trusted companies and data providers;
    • Market research surveys and phone interviews conducted by our in-house research team;
  2. Shared Data. When using the Services and Platform, the Client may contribute Business Information about itself or other businesspeople and companies. The Shared Data may cover name, business email address, phone number, including business one, website, and social media account address, including LinkedIn URL-address, job title, seniority and role, company name, country/state of business, other data rendered by the Client to Closely.. Closely may also collect the Shared Data: when you submit information through the Platform, when you use the Services and Platform, when you provide information about your prospects, when you refer a friend;
  3. Client’s Data:
    • the data we receive when you use the Website and Platform: duration of a session; the history of the interaction of the Website and Platform; information about how you use the Website and Platform and the relevant statistic, surveys responses, data you provided our support team with, including, the language of your requests; email and content of your message other information you may voluntarily provide us with by sending us direct messages;
    • the data you provide to Closely via the account: the full name; business information (a company name and a job title); account photo; billing name, address; email address; LinkedIn ID; phone number; any other information you provide to us; information we receive about you from third parties;
    • the data we collect automatically: data about how you found us; devise and location data: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, country, region, city; your activity on the Website; cookies identifiers;
    • the data provided by third parties: number of your sessions; session duration; operating systems of your devices, device models; geography; first launches date; number of the website opens.
As the Business and Shared Data, Closely processes only the business-related information. Thus, any contacts that have an email address from services oriented to end-users (Gmail, Yahoo, etc.) are disregarded. Closely does not disclose clients who provide Closely with the Shared Data.

To avoid irrelevant Business and Shared Data, we maintain a list of excluded businesspersons and companies outside of the Business and Shared Data (the “Opt-out list”). This list includes (i) contacts to whom we have not been able to send an information notice and (ii) contacts who are public servants or otherwise public figures, in order to ensure that their data does not appear in the Business and Shared Data.

5. PURPOSES AND LEGAL BASSES OF DATA PROCESSING

We process the Business and Shared Data with the following purposes:

  1. to build our sales intelligence database to enable our Clients to generate and manage sales leads and launch ad or communicative campaigns in respect of businesses and high net worth individuals;
  2. to enable our Clients or their customers to serve relevant display ads on social and other services;
  3. to enable our Clients or their customers to enrich their existing customer relationship management records and receive timely updates of changes;
  4. to run our own marketing campaigns and promote our services.

We process the Client’s Data with the following purposes:

  1. to make the Website and Platform available for your access as well as provide you with the most relevant services with the Platform;
  2. to communicate with you regarding your use of the Website and Platform, update you on services, information, and products;
  3. to notify you of any crucial information or changes within the Website and Platform which may affect you;
  4. to analyze active users’ number, support users from different regions and provide proper work of various versions of the Website as well as to develop and optimize the Website and Platform;
  5. to keep the Website and Platform safe and secure, enforce the Terms and prevent and combat fraud;
  6. to generate statistical studies of market;
  7. to comply with our legal obligations.

Closely’s collection of Business and Shared Data are within both the Closely’s and Client’s (as the Client’s data processor/service provider) legitimate interests to organize and make available business contact information given the limited impact of this data on an individual’s private life and that this information, unlike personal business contact details, is widely disclosed. Closely has put in place safeguards to protect personal privacy and individual choice, including disclosures of its data processing activities, the use of consent or opt-outs wherever possible, and the implementation of a privacy hub accessible here.

We process the Client’s data under the following legal bases:

  1. performing of the contract (the Terms) with you: a) to make the Website available for your access as well as provide you with the most relevant services with the Website and Platform; b) provide you with technical support; c) to communicate with you regarding your use of the Website and Platform, update you on services, information, and products; d) to notify you of any crucial information or changes within the Website and Platform which may affect you;
  2. our legitimate interest: a) to send to you marketing communications; b) to analyze active users’ number, support users from different regions and provide proper work of various versions of the Website and Platform as well as to develop and optimize the Website and Platform; c) to keep the Website and Platform safe and secure, enforce the Terms and prevent and combat fraud; and d) to comply with our legal obligations.

Please note, when the data is collected for marketing purposes you will be additionally asked for such processing. Furthermore, you will at any time have the possibility to withdraw your consent free of charge by the clicking on a separate “Unsubscribe button” in the email sent or via this link.

6. DURATION AND LOCATION OF PROCESSING

Closely will retain the personal Data for a period of time consistent with the original purposes for which it was collected. We will retain your information:

  1. for as long as we have an ongoing relationship with you and as needed to provide you Services;
  2. as necessary to comply with our legal obligations;
  3. as necessary to resolve disputes or to protect ourselves from potential future disputes; or
  4. as necessary to enforce our agreements.

Retention periods will be determined considering the amount, nature, and sensitivity of the data and the purposes for which it was collected. After the retention period ends, we will delete personal information. Where we are unable to do so, we will ensure that appropriate measures are put in place to prevent any further use of your information.

You are entitled to restrict us to process your data by sending to us a data erasure request or a notice of prohibition to process your data. Please be warned that such action prohibits us to process your data and/or makes us delete your data so you will lose your access to the Website and Platform.

Our servers are based in the USA, so your data will generally be processed and hosted outside the EU. Thus, place of the data collection is the USA.

7. YOUR DATA SUBJECT’S RIGHTS

Being a data subject, you have the following rights:

  • a right to request us to access to your data: you can ask us what personal information of yours is being processed as well as for the clarifications on the information described above, i.e. purpose of collecting and processing, period of processing, third parties that have access to information. To exercise the right please contact us at [email protected];
  • a right to request us to rectify your personal information: you can ask all the inaccurate personal information concerning you being corrected. You can also complete the personal information if you feel there is a need to do so. To exercise the right please contact us at [email protected];
  • a right to request us to erase personal information: you can request us to erase such data if its processing is no longer necessary in relation to the purposes for which it was collected as well as if there are no legal grounds for the processing. In most cases we will erase it unless otherwise will be required by legislation. To exercise the right please contact us at [email protected];
  • a right to request us to restrict the processing of your data: for example if you contest the accuracy of your data being processed or in case we will not be interested to process your personal information any longer, but you will want us to do this on different reasons, for example, to bring some claim for somebody and instead of the erasure of information its processing will be just restricted. To exercise the right please contact us at [email protected];
  • a right to withdraw your consent for the collection and processing of your data by us at any time, without affecting the lawfulness of processing based on consent before its withdrawal. To exercise the right please contact us at [email protected];
  • a right to lodge a complaint with supervisory authority; and
  • a right to data portability. To exercise the right please contact us at [email protected]

We will provide information on action taken on your request related to your rights specified above 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.

Closely provides notice to all data subjects from EEA as required by the GDPR (Articles 13 and 14), as appropriate, and honors the rights of data subjects provided in Articles 12-23 of the GDPR, including the right to be forgotten.

Please find the detailed manual how to opt-out here or send us an email to [email protected]

8. PROTECTION OF DATA

We take technical and organizational measures to ensure the information is processed in a manner that ensures appropriate security of information, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage. For example, we use verified contractors that might have access to the data as specified in section 4 hereof with which the relevant data processing terms are signed.

9. NOTICE TO CALIFORNIA RESIDENTS

California Civil Code Section 1798.83, also known as the “Shine The Light” law, grants our users who are California residents some rights. This section 10 applies solely to California consumers. This section also provides additional details about how we process personal data of California consumers and the rights available to them under the California Consumer Privacy Act (“CCPA”).

We do not sell your data so no opt-out choice is necessary. It means that we do not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate in any way your data to another company for monetary or other valuable consideration.

You have the right to request, twice in a 12-month period, the following information about the data we have collected about you during the past 12 months:

  • the categories and specific pieces of data we have collected about you;
  • the categories of sources from which we collected it;
  • the business or commercial purpose for which we collected the data;
  • the categories of third parties with whom we shared the data; and
  • the categories of data about you that we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information for a business purpose.

Closely did not sell (disclosure for benefit) any your data within the last 12 months (2020-2021). If anything changes in the following 12 months, we will update this section up to February 1, 2023.

You have the right to request that we delete the data we have collected from you. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment.

To submit an access or deletion request, contact us at [email protected] To help protect your privacy and maintain security, we take steps to verify your identity before granting you access to your data or complying with your request. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

California residents may opt out of the “sale” of their personal information. California law broadly defines what constitutes a “sale” — including in the definition making available a wide variety of information in exchange for “valuable consideration.” Depending what information we have about you, and whether we have included any of it in our marketing products and services, we may have sold (as defined by California law) certain categories of information about you in the last 12 months, as described in the “Categories of Personal Information We Collect and Disclose” section above. We do not knowingly collect personal information from minors under 18 years of age in California unless we have received legal consent to do so. If you would like to opt out, you may do so as outlined on the following page: Do Not Sell My Personal Information

10. NOTICE TO NEVADA RESIDENTS

Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law). If you are a Nevada resident, you may submit a request to opt out of sales under Nevada law by filling out this “opt-out” form. Opting out will ensure that the provided information and associated information will not be shared or made available in our products and services. Please note we may take reasonable steps to verify your identity and the authenticity of the request.

11. NOTICE TO UK RESIDENTS

UK Representative. First of all, please be acknowledged that you may contact our UK Data Protection Representative anytime you have any questions about how we process your personal data or comply with the DPA. If you have any complaints, you are also welcomed to reach him out by sending an email to [email protected]

12. REACH US OUT

We will be glad to hear something from you. If you have any questions regarding this Policy, please contact us at [email protected]

For any questions regarding your personal data please feel free to contact our Data Protection Officer at [email protected]lyhq.com.