Cloze, Inc. Privacy Policy

 

Last Updated: January 27, 2014

 

This Privacy Policy sets forth Cloze, Inc.'s ("Cloze", "we", "us" or "our") privacy practices and procedures in connection with Cloze's websites located at cloze.com, circulate.it and all related sub-domains, tools and services ("Website", "Websites", "Site" or "Sites"). Access to the Websites is provided pursuant to the Terms of Service accessible on our Websites.  Capitalized terms used but not defined in this Privacy Policy, shall have the meaning set forth in the Terms of Service. This Privacy Policy applies solely to information collected by or in connection with this Site.  This policy does not apply to the practices of companies that Cloze does not administer, or to individuals that Cloze does not employ.

 

Summary

Because Cloze both integrates with a variety of content imported, with your authorization, from your social networks and your email applications, 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:

 

      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

 

Your privacy is important to us. This Privacy Policy explains our online information practices and the choices you can make about the way the information obtained through this and other Cloze Websites is collected and used. This Privacy Policy applies only to personal information collected by Cloze from users of our Websites. This Privacy Policy does not apply to information collected by Cloze in other ways, including offline. Our Websites contains links to other websites operated by third parties. Cloze is not responsible for the online information practices or policies of such third party websites, and this Privacy Policy does not apply to those websites.

 

Scope

These highlights provide key points about the personal information we collect through our Services, how we use it, and your choices about its use:

           

Personal Information

We use 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 ourselves or through a third party online payment service.

 

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.

 

 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 

      By using our Websites, you indicate your consent for Cloze to send cookies to your computer in order to uniquely identify your browser and improve the quality of our Services; however, you may turn off cookies in your browser though, in doing so, some or all of our Services may not work.

 

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

 

The Websites and the Cloze Mobile Apps, and all services provided by Cloze via the Websites and/or Mobile Apps, now and as they become available (collectively, the "Services").  As part of the 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 social networking and email services such as Facebook, LinkedIn, Google, Twitter and other similar platforms, from which you authorize us to import your contacts and email.  Cloze's Services enable you to access, organize and receive updates about those with whom you have professional relationships, including publicly available information about your professional contacts. After your Cloze account has been setup, you may use the Services to receive updates automatically each time new information is discovered about your contacts' data from a Third Party Platform or by another Cloze user with whom you've shared contacts.

 

What Is Personal Information?

 

"Personal information" means information that specifically identifies an individual (such as a name, address, telephone number, mobile number or e-mail address) or other information about that individual that is directly linked to personal information.  Personal information does not include "aggregate" information, which is data we collect about the use of our Site and our Services. Personal information does not include public web 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. 

 

What Personal Information Do We Collect?

 

We collect personal information you voluntarily provide to us, such as when you register for an account and create a profile, send us an email or post information or other content to our Site, or when other users provide information about you.

In order to use some features of the Websites, we may ask you to complete a registration form and create a user name and password ("Cloze Login Credentials").  During any such registration, you are required to give truthful contact information (such as name and email address) in accordance with our Terms of Service.  We use this information to contact you about the Services on our Websites in which you have expressed interest.  We also use it to create your user profile (your "Public Profile").  Your Public Profile contains personal information such as your first name, last name, organization, title, location, and a profile picture if available. A subset of your Public Profile information may be searched and viewed by other users of the Service.  Except for your name and organization, you may be able to remove some personal information from your Public Profile. 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.

 

Your data that you import in connection with the Services such as files, social networking data, and email archives that you choose to provide to us in order to create and update your Cloze account may contain personal information.  By default we will treat your data as confidential ("Private Data") except as described in this Privacy Policy. Your data will remain Private Data until you share or disclose it to another user. 

 

For instance, when you add a user as a Cloze Connection you will be able to view the Contact Profiles and Cloze Score for each of such user's contacts as well as other aggregate data as Cloze makes it available. You may also request that a Cloze Connection share additional information about a contact through the Services.  Likewise, you may choose to share additional information about your contacts with your Cloze Connections.  You may share such information as phone numbers, email addresses, social networks the contact belongs to and other information.   By sharing data with your Cloze Connections the data becomes Shared Data.

 

Your data that remains Private Data even if you've chosen to share contact records from your Cloze Account is comprised of:

      Contents of your imported email archives including, without limitation, subject, body and attachments;

      Contact record notes;

      Cloze Login Credentials;

      Third Party Login Credentials; and

      Your Payment Information.

 

Please note that, once you provide Shared Data with other users, there are no restrictions on these users from sharing that Shared Data, through the Site or otherwise, with any third parties or using that Shared Data for any purpose.

 

We track the data you see in Cloze and how you interact with it by automatically collecting certain information when you use our Site and our Services, such as your Internet Protocol (IP) address, your operating system, the browser type, the address of a referring site and your activity on our Site. 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 anonymous and aggregated form to inform us about how Cloze is being used to help us provide a better user experience.

 

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).  By using our Services, you hereby consent to Cloze automatically collecting certain information through the use of "cookies."  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. The Help function within your browser should tell you how. For information on how to delete cookies on the browser of your mobile phone you will need to refer to your handset manual. If you choose to disable cookies, some Services may not work properly or at all.

 

Cloze keeps personal information contained in your cookies confidential.  We do not set any cookies outside of the cloze.com domain.  We do not plan to participate in any personalized advertising or retargeting services. 

 

 

How Do We Use the Personal Information We Collect?

 

We use personal information collected through our Site and our Services for the purposes described in this Privacy Policy or elsewhere on our Site. For example, we may use personal information we collect:

 

      to create, organize, and update your contact records in your Cloze account;

      to enable you to share your information 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 Site usage and trends, and to personalize and improve our Site and our users' experiences on our Site, such as content, or features that match their profiles or interests, and to increase our Site's functionality and user friendliness;

      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 Site; and

      for any other purpose for which the information was collected.

 

We do not sell, share, rent, or otherwise provide personal information to third parties without your consent except where it is necessary to carry out your instructions (to process your payment information, for example) or except as described in this Privacy Policy or as required by law.

 

What does Cloze do with the information you upload or connect?

 

By default your data that you import into Cloze in connection with your use of our Services is Private Data.  Private Data is maintained as confidential by Cloze except as described in this Privacy Policy and is stored securely on our servers.  After importing your data, we will process your data so that it is usable within the Cloze Services.  For instance, Cloze will calculate a "Cloze Score" for each contact record in your Cloze account based on factors determined from your data.  Your Cloze Scores may be viewed by your Cloze Connections. Your data and your Third Party Platforms may be periodically processed by Cloze as part of our routine operations to update your contact records in your Cloze account and Cloze Scores.  We may also use basic information, such as name, organization, title, and geographic location from your contact records in your Cloze account to create a "Contact Profile" for you and your contacts to allow other users to find and connect with you and your contacts.  Contact Profile information can be searched and viewed by other users of the Service. You may opt-out from the creation of Contact Profiles from your data through the Settings page on the Websites  Whenever you enter data, we will make clear whether it is Private Data or Shared Data.  We may share your data with third parties as permitted in this Privacy Policy and as provided in our Terms of Service.

 

This Site is 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.

 

What Personal Information Do We Share With Third Parties?

 

Cloze exists to make your professional network more actionable, not to sell your data.

 

In order to search for public information about your contacts on the Internet, we may use your Third Party Login Credentials and/or Public Profile information to search for information about your contacts on Third Party Platforms.  In addition we may check for public information about your contacts from third party data providers by using the contact records in your Cloze account. 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. We may use your contact records in your Cloze account to the extent it is Shared Data to check whether public information is available regarding those contact records and confirm that they are accurate, and to correct such information if not. We will not share your contact records in your Cloze account with third parties other than to use data interchange look-up services as discussed above.

 

We share personal information as follows:

      In your Public Profile information as part of a Service to search for other users;

      to provide the Services to update your Cloze account and Cloze Scores;

      with service providers who are working with us in connection with the operation of our Site or our Services, so long as such service providers are subject to confidentiality restrictions consistent with this Privacy Policy;

      when you give us your consent to do so, including if we notify you on our Site that the information you provide will be shared in a particular manner and you provide such information;

      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;

      to enforce or apply our Privacy Policy, our Terms of Service or our other policies or agreements;

      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;

      information you share on the Websites, such as when you transmit or post a message to another user through the Services; and

      If you apply for or purchase a product or Premium Service requiring financial information on our Websites; we may share your financial information with a third party payment processing service provider to process payment or we may direct you to provide that information directly to such third party.

 

In addition to the above, we promise that we will not share any of your Private Data, without your consent or except as described in this Privacy Policy, the Terms of Service or as required by law.

We are not responsible for the actions of service providers or other third parties, nor are we responsible for any additional information you provide directly to any third parties. 

 

User Communications

 

Many communications you initiate through Cloze (e.g., an invitation sent to a non-User) will list your primary email address and name in the header of the message. Messages you initiate may also provide basic information about your network. Other communications that you initiate through the Websites, like a request for an introduction, will list your name as the initiator, but will not include your personal email address or contact information. Your Contact Profile will be shared with another user if both of you have indicated that you would like to establish contact with each other. Cloze may also share your Contact Profile with other users who we predict that you have a pre-existing relationship.

 

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 Websites. 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. All invitees are provided with the option not to receive further invitations. 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 Site 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 Site.

 

What Steps Do We Take To Protect Your Information Online?

 

We take 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.

 

Cloze is hosted by Amazon Web Services (AWS), who employ their own security measures.  AWS employs industry-recognized certifications and audits: PCI DSS Level 1, ISO 27001, FISMA Moderate, HIPAA, and SAS 70 Type II. Their services and data centers have multiple layers of operational and physical security to ensure the integrity and safety of your data. You can read more about AWS security here.

 

Cloze employees follow security procedures to access our servers and are bound by contractual obligations to safeguard our users' Private data at all times and to comply with our Privacy Policy.

 

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

 

You may "opt out" of receiving marketing or promotional emails from us by following the instructions in those emails 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.

 

Choice/Opt-out

 

We provide you the opportunity to "opt-out" of having your personal information used for certain purposes, when we ask for this information. If you no longer wish to receive our newsletter and promotional communications, if any, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by emailing us at support@cloze.com.

 

Changing or Deleting Your Information

 

You may review, update, correct or delete the personal information in your account by contacting us at updates@cloze.com.  By deleting your data in your account, then we may deactivate your account. You may request deletion of your data at any time, unless you have shared your data with others and they have not deleted it, or it was copied or stored by other users while displayed by you to others through the Services.  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 data 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.

 

Legal Disclaimer

 

We reserve the right to disclose your Personal Information as required by law and when we believe that disclosure is necessary to protect our rights or the rights, property or safety of others; to comply with a judicial proceeding, court order, or legal process served on us or the Websites; or in connection with an actual or proposed corporate transaction or insolvency proceeding involving all or part of the business or asset to which the information pertains.

 

Minors

 

Our Services are not directed to persons under 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 without their consent, 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.

 

 

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, and update the Privacy Policy modification date at the top of this page.  If you have questions or concerns regarding our Privacy Policy, please contact us at: support@cloze.com.

 

Questions?

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

 

Copyright © 2014 Cloze, Inc. All Rights Reserved.