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CLOSELY PRIVACY POLICY

Effective Date: July 1, 2021

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

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 is Esterson Limited., registered address: 75 Prodromou Avenue, Oneworld Parkview House, 4th floor, Nicosia 2063, Cyprus.

Where there will be a necessity, we may also engage third-party services 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.

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 in 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

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 data processors may collect the following data about you:

  • 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; 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.

5. PURPOSES AND LEGAL BASSES OF DATA PROCESSING

We process your information with the following purposes:

  • to make the Website and Platform available for your access as well as provide you with the most relevant services with the Platform;
  • to communicate with you regarding your use of the Website and Platform, update you on services, information, and products;
  • to notify you of any crucial information or changes within the Website and Platform which may affect you;
  • 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;
  • to keep the Website and Platform safe and secure, enforce the Terms and prevent and combat fraud;
  • to generate statistical studies of market;
  • to comply with our legal obligations.

We process your data under the following legal bases:

  • 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;
  • 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.

6. DURATION AND LOCATION OF PROCESSING

Your data will be processed within the term of your use of the Website and Platform and up to termination of such use (or the Terms); we shall terminate the processing of your personal information unless the special retention period for the storage of such data is set by the relevant legislation then.

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 your 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.

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.

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.

10. 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]

11. 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]