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Effective: September, 2020
Because Cloze integrates with a variety of content imported, with your authorization, from your email, notes, files, reminders, calendar, phone, messaging, contacts, social media and other services, we take precautions to ensure that your personal information is protected.
- We won’t sell your data.
- We won’t spam your email or social networks.
- We’ll be open and transparent as to how we will use your information within Cloze.
Information About You
We use your Personal Information to communicate with you, provide you with our Services, and to help us improve our Services. We collect your name and contact information as well as your Third Party Login Credentials for each Third Party Platform (as defined below), and if you purchase our Premium Services, we also collect your payment information through third party online payment services.
By using our Services, you indicate your consent for Cloze to send cookies to your computer or other device in order to uniquely identify your browser and improve the quality of our Services. You may turn off cookies in your browser however, in doing so, some or all of our Services may not work.
Your Privacy Choices
- You may review and correct your Personal Information and preferences.
- You may opt-out of marketing and promotional emails from us.
- You may opt-out of phone and postal marketing.
How to Reach Us if You Have a Question
By email to email@example.com.
Protecting Your Data and Ensuring Your Privacy at Cloze
The Cloze Services
Cloze organizes and provides efficient means to access and receive updates regarding your contacts that may have been previously dispersed over many different Third Party Platforms.
“Third Party Platforms” are software that integrate with our Services and that you have authorized to connect with Cloze. This may include email, calendar, messaging, file storage, phone services, note taking, reminders, social networking, and other cloud services such as Office 365, Gmail, Slack, Facebook, Dropbox, Evernote and other similar platforms from which you authorize us to import, search, and access, content.
What Is Personal Information?
“Personal Information” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, address, telephone number, mobile number or e-mail address, an identification number, location information, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. “Sensitive Personal Information” means racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union members, the processing of genetic, biometric data for purposes of uniquely identifying a natural person, and information concerning an individual’s health, sex life, or sexual orientation. We treat your Personal and Sensitive Personal Information as confidential.
“Other Information” is any information that is not Personal Information or Sensitive Personal Information. Personal Information does not include anonymized or “aggregate” information, or publicly available information that has not been combined with Personal Information or Sensitive Personal Information.
What Information Do We Collect And When Do We Collect It?
We may collect your Personal Information in the following circumstances:
- When you voluntarily provide it to us, such as when you register for an account by creating a username and password (“Cloze Login Credentials”), send us an email or post information or other content to our Site or Service;.
- When you choose to sign in to, or create a Cloze account, using a Third Party Platform login (for example, by choosing the “Sign in with Google” option on the Cloze website);
- When you connect a Third Party Platform with your Cloze account we may collect your credentials to that Third Party Platform if this is required in order to connect;
- If you apply for or purchase a Premium Service requiring billing or payment information on our Websites, we require that you provide certain additional Personal Information, including your address, phone number, and credit card number (“Payment Information”). This information is necessary to process your requests and to contact you.
- We may also collect Personal Information about you from your employer when your employer engages us to provide the Services to you. For example, we may obtain your name and email address from your employer.
When you utilize the Services, we also receive certain Other Information about you or your use of the Services. Such Other Information may be collected using various technologies, including:
- Logs: We track the data you see in Cloze and how you interact with it by automatically collecting certain information such as, the pages you visit or features you use within the Services, the date and time of your activities on the Services, the URLs from the websites you visit before and after navigating to the Services, your software and hardware attributes (including operating system type and version, App version, device type, and device identifiers, including IDFA and/or Advertising IDs), your browser type and version, and your general geographic location derived through your IP address (e.g., your city, state, or metropolitan region). To obtain such information, we may use web logs or applications that recognize your device and gather information about its online activity. We treat this information as Private Data if we combine it with or link it to any of the your Personal Information. Otherwise, it is used in aggregate form only. We use tracking data about individuals in an aggregated form to inform us about how Cloze is being used to help us provide a better user experience.
- Web beacons: The Services or the emails that you receive from us may use an application known as a “web beacon” (also known as a “clear gif” or “pixel tag”). A web beacon is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information. For example, it allows an email sender to determine whether a user has opened a particular email.
- Local storage: We may collect and store information (including Personal Information) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.
Cloze keeps Personal Information contained in your cookies and obtained through the other tracking technologies confidential. We do not set any cookies outside of the cloze.com and clz.es domains.
We also may partner with certain third parties to collect, analyze, and use some of the Personal and Other information described in this section. For example, we may allow third parties to set cookies or use web beacons on the Services or in email communications from Cloze. This information may be used for a variety of purposes, including analytics and online behavioral advertising.
When you authorize Cloze to access Third Party Platforms, we collect, store, and process “Content” on your behalf. Content are all communication records and documents (including your contacts, messages, files, call records, notes, meetings, email and other similar information) from Third Party Platforms that you have authorized Cloze to access, similar information you directly enter in Cloze (for example, when sending emails, creating new contacts, adding notes, setting reminders, etc.), as well as information Cloze discovers and provides to you (for example, public information about your contacts, when contacts of yours open emails you sent from Cloze, etc.). By its nature, Content will often contain Personal Information (for example, an email will contain the sender and recipient’s email addresses).
Cloze has no direct relationship with the individuals whose Personal Information is contained in your Content. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to you. We provide tools to allow you to export, delete, or update Content so you can comply with these requests.
How Do We Use the Information We Collect?
We use your Personal Information and Other Information collected through our Services for the following purposes:
- to enable you to share Content and communicate with other users;
- to provide our Services or information you request, and to process and complete any transactions;
- to respond to your emails, submissions, questions, comments, requests, and complaints and provide customer service;
- to monitor and analyze usage of the Services and trends, and to personalize and improve our Services and our users’ experiences on our Services, such as content, or features that match their profiles or interests, and to increase the functionality and user friendliness of our Services;
- to send you confirmations, updates, security alerts, and support and administrative messages and otherwise facilitate your use of, and our administration and operation of, our Services;
- to contact you about the Services in which you have expressed interest or that might be of interest to you; and
- for any other purpose for which the information was collected.
What does Cloze do with your Content?
We use a number of technologies to help you get the most out of the Service. Our systems automatically analyze your Content to power Cloze features and to continually improve the Service for you. This may include, for example:
- Making sure you find what you’re looking for when you search your Content;
- Showing you the most relevant contacts in any given situation;
- Suggesting actions based on previous communication or other Content;
- Suggesting updates to your contacts with new or additional information; and
- Linking Content to relevant contacts so you see everything related to them.
You may explicitly choose to share Content with other Cloze users or with Third Party Platforms.
When you share Content with another Cloze user, Cloze provides privacy controls to allow to you to choose what information to share (by default, Cloze will not share the following Content with your co-workers: home or personal addresses from your contacts or messages from friends and families). There are many privacy controls within Cloze that you can take advantage of to control what information gets shared and when. When you choose to share Content with other Cloze users, the shared Content becomes Private Data in their Cloze account as well as yours. However, there are no restrictions on these users from sharing that Private Data, through the Service or otherwise, with any third parties, or using that Private Data for any purpose. For example, if you share a note with another Cloze user, they could copy, paste, and email that note to a colleague – just as if you email someone, they could forward that email to someone else. Once you share Content with other users, there are no restrictions on those users from sharing that Content through the Services or otherwise with any third parties or using the Content for any purpose.
When you authorize a Third Party Platform to access Content from your Cloze account (for example, to make contacts in your Cloze account available on another device), please be aware that those platforms are not operated by Cloze and Cloze is not responsible for the content or practices of those platforms. The collection, use, and disclosure of your information will be subject to the privacy policies of the Third Party Platforms, and not this Policy.
What Content gets shared when you join a Cloze Business Team?
If you accept an invitation to join a Cloze Business Team, some of your Content, or aggregate information about your business-related Content, may be shared with other team members automatically, while other Content will only be shared if you choose to share it. Summary Information and some Contact Information may be shared automatically, while Communications Information will be shared only after you have been presented with the opportunity to approve or decline sharing.
- Summary Information: Summary information may be visible to other team members at any time, but the content of your communication and your contact information will not be visible. Some examples of summary information are counts of the number of calls, emails, and other communication you have exchanged with business (not personal) contacts, and when you last communicated with a business (not personal) contact.
- Contact Information: When you are assigned to follow-up with a business contact or you are added to a project or deal team, you will be notified, and business-related contact information (such as work email addresses – not home, personal, or private fields) may be shared with your team. You can separately control whether communication will be visible to other team members. Any contacts that you have flagged as personal or private will never have contact information shared with your team.
- Communications: Details of your communications with business contacts are only shared once you have been notified and have had a chance to either approve or deny sharing either in bulk or on a per message basis. Cloze provides many privacy controls to allow you to choose what content is shared and when. Any contacts that you have flagged as personal or private will never have their communication information shared with your team.
What Information Do We Share With Third Parties?
Cloze exists to make your professional network more actionable, not to sell your data. However, we share personal information as follows:
Requests to other Cloze users (and non-users): Some communications you initiate through Cloze (e.g., an invitation sent to a non-user or a task you assign to another Cloze user) will list your primary email address and name in the header of the message.
Contact Enrichment: In order to ensure your contacts are as complete and accurate as possible, we may search for public information about your contacts in Third-Party Platforms you have connected to your Cloze account. In addition, we may check for public information about your contacts from third party data providers. In order to do so, we share a subset of information from your contacts (such as your contact’s email address), but do not disclose any information about you to the data provider (the data provider does not know on whose behalf we are making the requests). In such cases, we require such third parties to agree to confidentiality restrictions and to meet privacy standards at least as stringent as ours in protecting your data for such purpose.
Your direct sharing of Personal Information through third-party websites and services: The Services may enable you to explicitly share Content with websites or online services operated by third parties. For example, the Services contain links to third-party websites that incorporate comment and social media features. The Services also contains a Facebook “like” button and a Twitter “follow” button. If you choose to use these features, you may disclose your personal information not just to those Third-Party Platforms, but also to their users and the public more generally. Because these Third-Party Platforms are not operated by Cloze, Cloze is not responsible for the content or practices of those platforms. The collection, use, and disclosure of your information will be subject to the privacy policies of the Third-Party Platforms, and not this Policy.
With Your Consent: We may share your Personal Information when you give us your consent to do so, including if we notify you on our Services that the information you provide will be shared in a particular manner and you provide such information.
Business Transfers: We might sell or buy business assets. We may share your Personal Information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition, or in any other situation where Personal Information may be disclosed or transferred as one of the business assets of us.
Online Interest-Based Advertising: The Services also enable third-party tracking mechanisms to collect your Other Information for use in online interest-based advertising. For example, third parties may use the fact that you visited our website or used our mobile app to target online ads to you. In addition, our third-party advertising networks might use information about your use of our website or app to help target advertisements based on your online activity in general. For information about interest-based advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website.
Please note that the opt-out will apply only to the specific browser or device from which you opt out, and therefore you will need to opt out separately on all of your browsers and devices. If you delete or reset your cookies or mobile identifiers, change browsers, or use a different device, any opt-out cookie or tool may no longer work and you will have to opt out again.
You may choose to provide us with another person's e-mail address so that person may be invited to create an account on our Service. By providing us with another person's e-mail address, you represent to us that you have obtained the consent of the person concerned as regards such disclosure to us of that e-mail address. We may disclose such information if required to do so in order to comply with legal process, as described above.
Links to Other Sites
What Steps Do We Take To Protect Your Information Online?
We use reasonable physical, technical, and administrative security measures to protect your Personal Information in an effort to prevent loss, misuse and unauthorized access, disclosure, alteration and destruction. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.
What Choices Do You Have Regarding the Use of Your Information?
You may withdraw your consent to process your Personal Information at any time. If you do so, you will be unable to use the Services.
You may “opt out” of receiving marketing or promotional communications from us by following the instructions in those communications or by emailing us at firstname.lastname@example.org. If you opt out, we may still send you non-promotional emails, such as emails about your Cloze account or our ongoing business relations.
Your Rights: Reviewing, Changing or Deleting Your Information
You may review, update, correct or delete the Personal Information in your account from within the Service itself or by contacting us at email@example.com. By deleting your data in your account, we may deactivate your account. You may request deletion of your data at any time. Your account will be closed after a period of inactivity of six months or such other period of time as we may choose from time to time. You also authorize us, on your behalf, and in accordance with your account preferences to delete information when not reasonably needed for the Services. If you have shared your Content with others and they have not deleted it, or it was copied or stored by other users, Cloze will not be obligated to delete such information.
If you are an EEA or Swiss individual, you have the right to object to processing and to data portability, in some circumstances, as well as the right to lodge a complaint with a supervisory authority. The EU Commission provides a list of supervisory authorities here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
The supervisory authority in Ireland is the Irish Data Protection Commissioner. The Irish Data Protection Commissioner may be contacted at firstname.lastname@example.org.
Retention of Your Information
We retain information for as long as reasonably necessary to deliver our Services to you or to fulfill the purposes described in this Policy. You may delete the Personal Information in your account as described above. Please note that, in limited circumstances, we may retain information for a longer period of time as required by law.
Our Services are not directed to individuals under the age of 13. We do not knowingly collect personal information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information, he or she should contact us at email@example.com. If we become aware that a child under 13 has provided us with Personal Information, we will take steps to delete such information from our files.
Cloze has further committed to refer unresolved privacy complaints under the 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, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.
Under certain conditions more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
The Services are operated from and hosted on servers located in the United States. Your information may be transferred around the world to countries in which we do business, including to affiliates, service providers or third parties, which may be located in jurisdictions that may not have the same level of data protection laws as those in your home country. By using the Services or by providing any personal information to us, you expressly consent to such transfer and processing.
Information for European Economic Area and Swiss Users
Whenever we share information of European Economic Area (“EEA”) or Swiss users outside the EEA or Switzerland we make sure an adequate transfer mechanism is in place.
In light of the Court of European Justice’s July 16, 2020 Decision in the case of Data Protection Commissioner v Facebook Ireland Ltd, Maximillian Schrems, invalidating the EU-US Privacy Shield Framework as a program satisfying the requirements of Article 45 of the General Data Protection Regulation of the European Union (“GDPR”), Cloze no longer relies on the EU-US Privacy Shield Framework for the lawful transfer of personal data from the EU or EEA to the US. Cloze utilizes the European Commission Standard Contractual Clauses ("SCC"s) for Controller to Processor transfers in accordance with the Commission Decision of 5 February 2010 on standard contractual clauses for the transfer of personal data to processors established in third countries under Directive 95/46/EC of the European Parliament and of the Council (notified under document C(2010) 593)(Text with EEA relevance)(2010/87/EU). You may access the applicable Standard Contractual Clauses in our Terms of Service.
Cloze is responsible for the processing of Personal Information it receives under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Cloze complies with applicable data protection laws, including the GDPR and any implementing legislation, as amended, superseded or replaced from time to time, and the SCCs, where applicable, entered into between Cloze and the data Controller for all onward transfers of Personal Information from the EEA and the United Kingdom. Cloze complies with the Swiss-US Privacy Shield Principles for all onward transfers of Personal Information from Switzerland.
With respect to the Personal Information received or transferred pursuant to the Swiss-US Privacy Shield Framework, Cloze is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Cloze may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
VeraSafe has been appointed as Cloze's representative in the European Union for data protection matters, pursuant to Article 27 of the GDPR. VeraSafe can be contacted, in addition to firstname.lastname@example.org, only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this Article 27 Representative Contact Form, or at VeraSafe Ireland Ltd., Unit 3D North Point House, North Point Business Park, New Mallow Road, Cork T23AT2P, Ireland.
Lawful Bases for Processing
We will only collect and process Personal Information about you where we have lawful bases. Our lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you, such as when you purchase a Premium Service) and our legitimate interests (such as to comply with applicable laws and enable or administer our business).
Information for California Residents
If you are a California resident under 18 years of age and a registered user of our Services, you may request that we remove content and information that you publicly post on our Services. To obtain removal of such content and information, please send us an email at email@example.com with a short description of the content or information you would like to have removed. Please note that such a request does not necessarily ensure complete or comprehensive removal of content posted by you, since the content and information may remain in our databases, may remain visible in a manner that does not identify you, or may have been re-posted by another user.
Third Party Platform Policies
Some Third Party Providers require we explicitly reference their terms.
Cloze's use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.