Cloze, Inc. Privacy Policy

Effective: April 26, 2018

Your privacy is important to us. This Privacy Policy sets forth Cloze, Inc.’s (“Cloze”, “we”, “us”, or “our”) privacy practices in connection with Cloze’s websites located at cloze.com, clz.es (“Site” or “Sites”), the Cloze mobile applications, the Cloze web browser extensions, and the Cloze chat bots (collectively, the “Services”). This Privacy Policy applies only to information collected by Cloze from users of our Services and visitors of our websites. This Privacy Policy does not apply to information collected by Cloze in other ways, including offline. Access to the Services is provided pursuant to the Terms of Service accessible on our Sites and Services. Capitalized terms used but not defined in this Privacy Policy, shall have the meaning set forth in the Terms of Service.

Summary

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.

Rather than a dense legalistic Privacy Policy we have tried to write a clear, open and transparent Privacy Policy that an average human can understand without retaining a lawyer. Here are a few highlights about the personal information we collect through our Services, how we use it, and your choices about its use:

  • 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.

We use cookies and other technologies to keep track of your use of our Services and to provide a personalized experience. Cookies are described and discussed below. We also use cookies to help us measure usage and improve the quality of our 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.

Important Information

We will update the “last updated” date to indicate the effective date of any changes to our Privacy Policy.

How to Reach Us if You Have a Question

By email to privacy@cloze.com.

Protecting Your Data and Ensuring Your Privacy at Cloze

The Cloze Services

What Is Personal Information?

What Information Do We Collect And When Do We Collect It?

Your Content

How Do We Use the Information We Collect?

What does Cloze do with your Content?

What Content gets shared when you join a Cloze Business Team?

What Information Do We Share With Third Parties?

User Communications

Links to Other Sites

What Steps Do We Take To Protect Your Information Online?

What Choices Do You Have Regarding the Use of Your Information?

Your Rights: Reviewing, Changing or Deleting Your Information

Retention of Your Information

Minors

Information for European Union and Swiss Users

Dispute Resolution

International Transfer

Lawful Bases for Processing

Information for California Residents

Changes to our Privacy Policy

Questions?

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.
  • Cookies: Like almost all websites today, Cloze uses cookies to determine whether you are logged in on your computer and to recognize repeat visitors. We send cookies to your computer in order to uniquely identify your browser and improve the quality of our Services. Cookies are small pieces of information that a website sends to your computer's hard drive while you are viewing a site. We may use both session cookies (which expire once you close your browser) and persistent cookies (which stay on your computer until you delete them). If you wish to restrict or block the cookies which are set by Cloze, or by any other website, you can do this through your browser settings. Please note, if you choose to disable cookies, some of our Services may not work properly or at all.
  • 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.

Your Content

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?

As with your Personal Information, we will treat your Content as confidential private data except for the uses and disclosures described in this Privacy Policy. Your Content is stored securely on our servers and will remain private to you, within your Cloze account, unless you choose to share or disclose it to another user or service, or as described below when you join a Cloze Business Team.

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:

Service Providers, Agents and Related Third Parties: We sometimes hire other companies to help us provide the Services to you. Examples include third-party payment processors, companies who send emails on our behalf, and providers who are working with us in connection with the operation of our Services. Such service providers are only provided with the information they need to perform their specific function, will only use your Personal Information to perform the services requested by us, and we make efforts to ensure they are subject to confidentiality restrictions consistent with this Privacy Policy.

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.

Third-party plugins: The Services integrate certain third-party plug-ins (such as a Facebook “like” button). Even if you do not click on these plug-ins, they may collect information about you, such as your IP address and the pages that you view. They also may set and/or access a cookie. These plugins are governed by the privacy policy of the company providing them.

Facebook Custom Audiences and Similar Programs: We may partner with Facebook and other social media partners to deliver advertisements to our users via the Facebook Custom Audiences program or similar third-party programs. In order to identify and reach our users on Facebook or another third-party service, we may share information such as an email address or phone number with Facebook or another third-party service. For more information about custom audience targeting and how to adjust your social media advertising preferences, please review the privacy policy of your social media provider.

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.

Legal Processes: We may also disclose your Personal Information if required to do so by law or when we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to comply with the law or legal processes or respond to lawful requests or legal authorities, including responding to lawful subpoenas, warrants or court orders; when we believe that disclosure is necessary to protect our rights or the rights, property or safety of others; to enforce or apply our Privacy Policy, our Terms of Service or our other policies or agreements.

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.

Analytics: We partner with certain third parties to collect the Other Information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use web logs or web beacons, and they may set and access cookies or use similar tracking technologies on your computer or other device. In particular, our Services use Google Analytics and Mixpanel. You may opt out of the use of cookies by Google Analytics here, and Mixpanel here.

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.

The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this privacy policy. If you prefer to prevent third parties from setting and accessing cookies on your computer or other device, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance by opting out here. If you are an individual of the EU or Switzerland, you may opt-out here. Although our Services currently do not respond to “do not track” browser headers, you can limit tracking through these third-party programs and by taking the other steps discussed above.

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.

Aggregated information: We may share aggregated demographic information about our user base with our partners. Such aggregated information does not identify individual users. We do not link this aggregate user data with personal information. Our Privacy Policy does not restrict or limit our collection and use of aggregate user data.

User Communications

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

Our Services may contain links to other sites. Any Personal Information you provide on the linked pages is provided directly to that third party and is subject to that third party’s privacy policy. Our Privacy Policy does not apply to such linked sites, and we are not responsible for the content or privacy and security practices and policies of these sites or any other sites that are linked to from our Services.

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 unsubscribe@cloze.com. 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 support@cloze.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 EU 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.

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.

Minors

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 support@cloze.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.

Information for European Union and Swiss Users

Cloze complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Information transferred from European Union and Switzerland to the United States, respectively. Cloze has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. You can learn more about the Privacy Shield program here, and to view our certification page, please visit here.

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 the Privacy Shield Principles for all onward transfers of Personal Information from the EU and Switzerland including the onward transfer liability provisions.

With respect to the Personal Information received or transferred pursuant to the 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 General Data Protection Regulation of the European Union. VeraSafe can be contacted, in addition to privacy@cloze.com, 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.

Dispute Resolution

In compliance with the EU-US and Swiss-US Privacy Shield Principles, Cloze commits to resolve complaints about your privacy and our collection or use of your Personal Information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Cloze at privacy@cloze.com.

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.

International Transfer

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.

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 privacy@cloze.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.

Changes to our Privacy Policy

Cloze may update this Privacy Policy from time to time. If we decide to change our Privacy Policy, we will post those changes on this page with an “effective date” indicating when the changes will take effect. We encourage you to review this Privacy Policy periodically. If you have questions or concerns regarding our Privacy Policy, please contact us at: privacy@cloze.com.

Questions?

Please contact us at privacy@cloze.com if you have any questions about our Privacy Policy.