ClosedWon® Inc. allows you to claim your profile, edit it, and hide or disclose data in your profile.
Effective Date: 11 September 2020
1.1. Additional Limits on Use of Google User Data: Google OAuth Limited Use Requirements
ClosedWon® use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
We collect data from your electronic messages (email and calendar), and we never share that data with our advertising partners. ClosedWon will not use this Gmail data for serving advertisements.
We use restricted scope data to provide or improve user-facing features that are prominent from the requesting app’s user interface.
1.2 We transfer restricted scope data to others only if that transfer is
(a) necessary to provide or improve user-facing features that are prominent from the requesting app’s user interface,
(b) to comply with applicable laws, or
(c) a part of a merger, acquisition or sale of assets of the developer. All other transfers or sales of user data are completely prohibited.
1.3 Access and reading restricted scope user data
We will not allow humans to access and read the restricted scope user data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for ClosedWon’s internal operations and even then only when the data has been aggregated and anonymized.
There are four limited exceptions to this rule:
(a) the developer obtains a user’s consent to read specific messages (for example, for tech support),
(b) it’s necessary for security purposes (for example, investigating abuse),
(c) to comply with applicable laws, and
(d) the developer aggregates and anonymizes the data and only uses it for internal operations (for example, reporting aggregate statistics in an internal dashboard).
2. COLLECTION AND USE OF INFORMATION
We may collect Personal Information from you (whether you act as the contact person for a business or in your own individual capacity) when you:
(1) when you provide such information directly to us,
(2) passively through technology such as “cookies.”, and/or
(3) when we obtain information about you from third parties or our indexing systems.
Personal Information does not include information that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person.
The personal information we collect may include:
Social media URL
2.1 Site Visitors
To browse our Site, you are not required to provide any Personal Information. However, we may gather information from cookies and similar technologies, as described below, for the purposes of monitoring and improving our Site.
2.2 Site Users
To gain full access to our Site and Services, you must register for a ClosedWon® account. When you register for an account, we collect Personal Information such as the following:
Your name, company name, language preference, email address, phone number, and profile picture to set up your account
Your IP address, device, and location used to access ClosedWon®, which will be linked to your account for fraud detection/prevention purposes
2.3 User-Provided Information
We will receive and store any information you knowingly provide to us. We collect the personal information you submit to us, for example by completing the sign-up form on www.closedwon.ai. In that case, we may communicate with you, for example by calling you at the phone number you provide, sending you promotional email offers, or emailing you about your use of the Services. In keeping with standard online privacy practices, users should not include highly sensitive information (such as social security numbers and financial information) in any emails so that such data does not transfer to our servers, even if only temporarily. If you do not want to receive communications from us, please indicate your preference by sending an email to firstname.lastname@example.org.
2.4 Information Automatically Collected
Whenever you interact with our Site or Services, we automatically receive and record information on our server logs from your browser or device. These may include your IP (Internet Protocol) address, “cookie” information, the type of browser you are using, the type of device you are using, and the page or feature you requested.
Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address, along with the time of the visit and page visit, may be identified and logged automatically in our server log files whenever a user accesses the Site. IP addresses for are used for purposes such as calculating usage levels, diagnosing server problems and administering the Services. Your IP address may also show your approximate geographical location.
Cookies are a feature of web browser software that allows web servers to recognize the computer used to access a website. We use cookie data to analyze trends, administer the Site, track users’ movements around the site and to gather demographic information about our user base as a whole. Cookies also allow our servers to remember your account information for future visits and to provide personalized streamlined information across related pages on our Site. We may also collect information about your online activity after you leave our Site through cookies. Information is stored to streamline your online activities and make your online experience more personalized. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may limit your ability to use our Site and Services.
2.5 Information Collected From Third Party Analytics Services and Indexing Systems
ClosedWon® uses third-party analytics services to better understand user engagement with the Site. When a user browses or uses the Site and/or Services, these third party analytics services may collect the user’s IP address, browser type and approximate geographical location. They may also use web logs or web beacons and may be able to set and access cookies on your device.
2.6 Minors and Children’s Privacy
Our sites and services are directed to the general public, and protecting the privacy of young children is especially important. We do not knowingly collect or solicit Personal Information from children under the age of 13. If you are under 13, please do not attempt to register for the Services or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child who is under 13, we will delete that information as quickly as possible.
2.7 Use of Information
We may also use Personal Information and other information collected through the Site or Services to operate, maintain, enhance and provide all features of the Service. We may use this information to contact you in the future to tell you about services we believe will be of interest to you.
We may use and disclose information that is not Personal Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine non-Personal Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
3. SHARING AND DISCLOSURE OF INFORMATION
Service Providers: We work with third party service providers to perform tasks on our behalf and need to share your information with them, in some cases these include the Personal Information you have provided to us, in order to make the Services available to you. Some examples are those that provide services such as website hosting, data analysis, payment processing, order fulfilment, information technology and related infrastructure provision, customer service, email delivery, auditing and other services. ClosedWon® maintains contracts with these third parties to restrict their access, use and disclosure of Personal Information.
Business Transfers: If we are involved in a reorganisation, merger, acquisition or sale of our assets, bankruptcy, or other similar events, any information in our possession may be transferred to our successor or assigned.
4. OPTING OUT
When you visit our Site and/or register for ClosedWon®, you may opt-in/opt-out to certain web features such as cookies and email marketing. We may occasionally email you with information about offers or new services. You can opt-out of these email marketing communications at any time via an unsubscribe link included in such communications, or by sending an email to the address provided in the Contact Us section. If we are processing your Personal Information based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time by sending an email to the address provided in the Contact Us section.
If you are registered with ClosedWon®, you will continue to receive administrative email communications regarding the Service.
5. PROTECTION OF INFORMATION
ClosedWon® will use very diligent efforts to protect the privacy of your account and other Personal Information we hold in our records. Unfortunately, we cannot guarantee complete security. We maintain reasonable administrative, technical, and physical procedures to protect information stored in our servers, which are located primarily in the United States. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
6. JURISDICTIONAL DISCLOSURES
Sites and Services are controlled and operated by us from the United States.
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Site and Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.
In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
For California Residents, please see Section 9. For any Personal Information that may be transferred from the European Economic Area, please see Section 10.
7. ACCESS TO INFORMATION
If you have a ClosedWon® account, you can access your account information by signing into ClosedWon® account. If you want to update your Personal Information you can contact us as specified below.
8. EU-U.S. & SWISS-US PRIVACY SHIELD
ClosedWon® is responsible for the processing of the Personal Information it receives, under the Privacy Shield Framework, and for any data transferred to a third party provider. We comply with the Privacy Shield Principles for all onward transfers of Personal Information, including onward transfer liability provisions. We maintain reasonable and appropriate security measures to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration or destruction, taking into account the nature of the Personal Information and the risks inherent in processing that Personal Information.
You have certain rights to access, correct, amend, or delete Personal Information where it is inaccurate, or has been processed in violation of the Privacy Shield Principles, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated.
ClosedWon® has further committed to refer unresolved complaints to JAMS (www.jamsadr.com). JAMS services are provided at no cost. We encourage you to contact ClosedWon® regarding your concern or complaint before reaching out to JAMS. To file a complaint under JAMS, please refer to the following link: www.jamsadr.com/eu-us-privacy-shield.
Following the dispute resolution process, you may refer the matter to the U.S. Federal Trade Commission, which has Privacy Shield investigatory and enforcement powers over ClosedWon®. Under certain circumstances, you may also be able to invoke binding arbitration to address complaints about ClosedWon® with the Privacy Shield Principles.
9. CALIFORNIA PRIVACY RIGHTS
California law permits California residents to request and obtain from us once a year a list of third parties to whom we have disclosed your personal information (if any) for direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those third parties, free of charge. See the Contact Us section to send a request.
ClosedWon® does not share Personal Information with third parties for their own direct marketing purposes without your prior consent.
Accordingly, you can prevent disclosure of your Personal Information to third parties for their direct marketing purposes by withholding consent.
10. COMMITMENT TO GDPR
The General Data Protection Regulation (“GDPR”), effective as of 25 May 2018, strengthens data protection for European Union (“EU”) individuals’ personal data. The GDPR ensures to govern the processing and storage of EU individuals’ data based on privacy by design and taking a risk-based approach. Closedwon® is well aware of its role in ensuring the security and protection of the personal data that we process.
We aim to show transparency by providing a compliant and consistent approach to data protection. We are dedicated to adhering fully to GDPR and have implemented strong privacy protections that reflect the new legislation. Further sections of this document offer more details regarding our commitment to GDPR.
10.1 Your Responsibility
We expect our Customers to abide by applicable rules and regulations, including the GDPR. Compliance is a shared responsibility with our Customers (data controllers) and us (data processors). It is the Customer’s responsibility to collect, process and transmit data in compliance with applicable laws, including the GDPR. It is our responsibility to comply with the terms of our data processing agreement with the data controller, specifying how it can process personal data on the data controller’s behalf. ClosedWon® offers a Data Processing Agreement to Customers outlining the terms of the agreement with regard to the Processing of Personal Data.
10.2 Complying with GDPR
ClosedWon® only processes professional data, regardless of geographical location, such as name and employer.
We respect your privacy and therefore we have expanded individuals’ rights by enabling Customers to request their personal data. These are as follows:
Right to Access: You may request access to your Personal Data and obtain a copy of your Personal Data processed by ClosedWon.
Right to Rectification: You may request to amend, update or complete any missing data we process about you. We may rectify, replenish or remove incomplete or inaccurate information at any time at our own discretion.
Right to Erasure: You may withdraw your consent for our processing of your Personal Data. If there is no overriding legitimate interest in continuing the processing of your Personal Data and your Personal Data is no longer necessary for the purpose for which it was originally collected, your data will be erased.
Right to Data Portability: You have the right to receive the Personal Data in a structured, commonly used and machine-readable format.
In the event of a breach, ClosedWon® will notify our Customers within 72 hours of first having become aware of the breach, where feasible.
12. CONTACT US