Privacy Policy

Last Updated June 1, 2018

This Privacy Policy describes Clozer Technologies Inc.’s (“Clozer”) practices regarding the collection, use and disclosure of the information we collect from and about you when you use Clozer’s websites, blogs, and web-based or mobile applications (the “Service”). We take our obligations regarding your privacy seriously and have made our best efforts to draft this Privacy Policy in a manner that is clear and easy for you to understand. By accessing or using the Service, you agree to this Privacy Policy and our Terms of Service.

Our Collection and Use of Information

Clozer collects a variety of information that you provide directly to us. We process your information when necessary to provide you with the Services that you have requested when accepting our Terms of Service, or where we have obtained your prior consent, or where we have a legitimate interest to do so. For example, we may have a legitimate interest to process your information for security, testing, maintenance, and enhancement purposes of the Services we provide to you, or for analytics, research, and reporting purposes. Without your information, we cannot provide you with the Services you have requested or you may be limited in your use of the Services.

Information You Provide to Us

We collect personal information, such as your name and email address, when you register for an account on the Service. You may also provide us with optional information such as your address, avatar, etc. Your user name, email address and any optional personal information that you elect to associate with your account is referred to herein as your “Personal Information.” We use your Personal Information as part of the Service to provide you a customized and personalized experience.

If you are a user of our paid service, we will utilize a third party credit card payment processing company to collect payment information, including your credit card number, billing address and phone number. We will share this payment information with the third party processing company as detailed below in “How We Share Your Information: With Third Party Data Processors”.

We may use your email address to send you Service related notices (including any notices required by law, in lieu of communication by postal mail). If you opt-in, we may also use your email address to send you company and product announcements and information, including third party products or services, that you may be interested in (the “Marketing Messages”). You may opt-out of receiving Marketing Messages at any time by following the instructions provided in the Marketing Message. Through your account settings, you may also opt-out of receiving certain types of Service related notices that are not deemed by Clozer to be integral to your use of the Service.

Even if you are not a registered user of our Service, if you email us we may retain a record of such email communication, including your email address, the content of your email, and our response.

If you choose to use our invitation service to invite a friend to the Service, we will ask you for that person’s contact information, which may include their email address or their social network identity, and automatically send an invitation. Clozer stores the information you provide to send the invitation to allow us to register your friend if your invitation is accepted and to track the success of our invitation service.

Your Content

Your use of the Service will involve you uploading or inputting various content into the Service; including but not limited to sales information such as people, companies, activities, deals, and goals and associated information, email logs, phone call logs, comments, text, files, and attachments (together, the “Content”).

You control how your Content is shared with third party applications or other users of the Service via your settings on the Service.

Clozer may view your Content only as necessary (i) to maintain, provide and improve the Service; (ii) to resolve a support request from you; (iii) if we have a good faith belief, or have received a complaint alleging, that such Content is in violation of our Terms of Service; (iv) as reasonably necessary to allow Clozer to comply with or avoid the violation of applicable law or regulation; or (v) to comply with a valid legal subpoena or law enforcement request. We may also analyze the Content in aggregate and on an anonymized basis, in order to better understand the manner in which our Service is being used and to improve the Service.

Information We Collect Automatically

We use technologies like cookies and pixel tags to provide, monitor, analyze, promote and improve the Service. For example, a cookie is used to remember your login information when you return to the Service and to improve our understanding of how you interact with the Service. You can block cookies on your web browser; however please be aware that some features of the Service may not function properly if the ability to accept cookies is disabled.

Log Files
When you use the Service, our servers automatically record certain information in server logs. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, mobile carrier, and other such information. Log files help us to monitor, analyze, improve and maintain the Service and to diagnose and fix any Service related issues.

Device Identifiers
When you access the Service using a mobile device, we collect specific device information contained in your mobile device’s “device identifier.” This device identifier includes information such as the type of device you are using, its operating system, and mobile network information, which may include your mobile phone number. We may associate this device identifier with your Service account and will use data associated with your device identifier to customize our Service to your device and to analyze any device-related issues.

Location Information
We may collect and process information about the location of the device from which you are accessing the Service. Location data may convey information about how you browse the Service and may be used in conjunction with personally identifiable information. You can enable or disable location based services associated with the Service; however please be aware that some features of the Service may not function properly if location services are turned off.

How We Transfer and Store Your Information

Your information is transferred from your browser or mobile device to our servers, and by the Service from server to server, using industry standard networking and encryption technology such as TLS/SSL. All of our data processing and storage servers are physically located within the United States of America (“U.S.”). Your Profile Information and Content is stored in an encrypted database while at rest. We do not store your credit card payment information.

We will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

How We Share Your Information

We may share the information we collect from you with third parties as detailed below. We do not share your Content or Personal Information (including personally identifiable information) with any other 3rd party advertisers, marketers, or data aggregators.

As Directed By You

We will display your Personal Information on your profile page and elsewhere on the Service in accordance with the preferences you set in your account. You can review and revise your Personal Information at any time.

We will display your Content within the Service as directed by you.

If you elect to use a third party application to access the Service, then we may share or disclose your account and Personal Information and your Content with that third party application as directed by you. Please remember that we are not responsible for the privacy practices of such third parties so you should make sure you trust the application and that it has a privacy policy acceptable to you.

With Third Party Data Processors

We may utilize third party data processors to assist us in delivering our Service. For example, we may use such third parties to help host our Service, send out email updates, or process payments. These third parties may have access to your information for the limited purpose of providing the service we have contracted with them to provide. They are required to have a privacy policy and security standards in place that are at least as protective of your information as is this Privacy Policy.

With Law Enforcement or In Order to Protect Our Rights

We may disclose your information (including personally identifiable information) if required to do so by law or subpoena. We may also disclose your information to our legal counsel, governmental authorities or law enforcement if we believe that it is reasonably necessary to do so in order to comply with a law or regulation; to protect the safety of any person; to address fraud, security or technical issues; or to protect Clozer’s rights or property.

In an Aggregate and Non-Personally Identifiable Manner

We may disclose aggregate non-personally identifiable information (such as aggregate and anonymous usage data, platform types, etc.) about the overall use of our Service publicly or with interested third parties to help them understand, or to help us improve, the Service.

In Connection With a Sale or Change of Control

If the ownership of all or substantially all of our business changes, we may transfer your information to the new owner so that the Service can continue to operate. In such case, your information would remain subject to the promises and commitments contained in this Privacy Policy until such time as this Privacy Policy is updated or amended by the acquiring party upon notice to you.

Privacy Shield

Clozer complies with the EU-U.S. Privacy Shield Framework and the Swiss–U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (“EU”) and Switzerland to the U.S., respectively. Clozer has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access and Recourse, Enforcement and Liability. If there is any conflict between the terms in our Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, Clozer commits to resolve complaints about your privacy and our collection or use of your personal information. EU or Swiss citizens with inquiries or complaints regarding this Privacy Policy should first contact Clozer at: privacy@clozer.ai. Clozer has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU Privacy Shield, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Clozer, please visit the BBB EU Privacy Shield web site at www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel. Clozer is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with respect to its compliance with the provisions of the EU-U.S. and Swiss-U.S. Privacy Shield.

International Data Transfer

We may transfer information that we collect about you to third party data processors across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the EU or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of such information to the U.S. and the use and disclosure of information about you, including Personal Information, as described in this Privacy Policy. Clozer will take reasonable and appropriate steps necessary to ensure that any third party data processor is processing information we entrust to them in a manner that is consistent with the EU-U.S. and Swiss-U.S. Privacy Shield Principles. Clozer is potentially liable in cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-U.S. and Swiss-U.S. Privacy Shield, respectively.

How We Protect Your Information

The security of your information is very important to us. We use commercially reasonable and industry-standard physical, managerial, and technical safeguards to preserve the integrity and security of your information, including encryption for sensitive information in transport and at rest.

In the case of a data breach to your information we will without undue delay, and when feasible not later than 72 hours after having become aware of it, notify you of the scope and severity of the breach and use commercially reasonable efforts to resolve any such breach in an expedient manner.

If you have any questions or want more details about security on our Service, please read our Security Information or contact us at support@clozer.ai.

Risks Inherent in Sharing Information

Although we allow you control over where you share your Content and what information is included in your Personal Information and take reasonable steps to maintain the security of the information associated with your account, please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other users with whom you share your Content and we are not responsible for third party circumvention of any privacy settings or security measures on the Service.

Your Choices About Your Information

You may, of course, decline to submit certain personally identifiable information through the Service, in which case Clozer may not be able to provide certain services to you. You may update or correct your Personal Information at any time by logging in to your account.

You may download a copy of your Content and Personal Information at any time from your settings on the Service.

You may delete your Service account at any time. At such time we will remove and stop processing your Personal Information and use commercially reasonable efforts to remove any other personally identifiable information from the Service.

Any information you submit in comments to our blogs are public and not confidential, and Clozer may use it for any purpose (including in testimonials or other Clozer marketing materials). Any such public information may be read, collected, and used by others, including third party search engines, who view those blogs so take care in what type of information you submit.

Child Privacy

Our Service is not directed to persons under the age of eighteen (18). Clozer does not knowingly collect or solicit Personal Information from anyone under the age of 18 or knowingly allow such persons to register for an account on the Service. If we become aware that we have collected Personal Information from a person under the age of 18 without verification of parental consent, we take steps to remove that information. If you believe that we might have any information from or about a person under 18, please contact us at support@clozer.ai.

We are not responsible for the practices employed by other websites linked to or from the Service, nor the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy is no longer in effect and your activities on that third party website is subject to such third party website’s own rules and policies.

Changes to Our Privacy Policy

If we change our Privacy Policy, we will post those changes on this page, and if possible, send you an email notification, to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

For questions about these or any Clozer terms or policies, email us at support@clozer.ai.