Last Updated: May 2018

1. Use of the Subscription Service by Closir and our Customers

The Closir Subscription Service

Our online Subscription Service allows any company that uses it (our customers and Closir itself) to create content for consumption by other users. The Subscription Service can also be used to help organise the company’s calendar and interact directly with other users, including requesting and planning meetings and calls. The information added to the Subscription Service, either by site visitors providing their contact information or when a Subscription Service user adds the information, is stored and managed on our service providers' servers. Closir provides the Subscription Service to our customers for their own business, investor/corporate relations and customer service needs, and we use it to meet Closir’s related needs.

Use by Closir

Information that we collect and manage using the Subscription Service for our own marketing belongs to us and is used, disclosed and protected according to this Privacy Policy. 

Use by Our Customers

Our customers use the Subscription Service to create content around their investor relations activities so other users can view their activities, identify potential interest, and request and manage interactions. Closir does not control the content of these pages or the types of information that our customers may choose to collect or manage using the Subscription Service. That information belongs to them and is used, disclosed and protected by them according to their privacy policies and is not subject to this Privacy Policy. Closir processes our customers' information as they direct and in accordance with our agreements with our customers, and we store it on our service providers' servers, but we do not have control over its collection or management. Our agreements with our customers prohibit us from using that information, except as necessary to provide and improve the Subscription Service, as permitted by this Privacy Policy, and as required by law. We have no direct relationship with individuals who provide Personal Information to our customers. Closir acknowledges that you have the right to access your Personal Information. Our customers control and are responsible for correcting, deleting or updating information they have collected from you using the Subscription Service. If requested to remove data we will respond within a reasonable timeframe. We may work with our customers to help them provide notice to their visitors about their data collection, processing and usage. Our agreements with our customers prohibit them from using the Subscription Service to collect, manage, or process Sensitive Information. We are not responsible for our customers' use of information they collect on the Subscription Service.

Closir collects information under the direction of its customers and has no direct relationship with the individuals whose Personal Information it processes. If you are a customer of one of our customers and would no longer like to be contacted by one of our customers who use our Subscription Service, please contact the customer that you interact with directly. We may transfer Personal Information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our customers.

Sensitive Information

This refers to credit or debit card numbers, personal financial account information, Social Security numbers, passport numbers, driver's license numbers or similar personal identifiers, racial or ethnic origin, physical or mental health condition or information, or other employment, financial or health information.

2. Information We Collect

When You Visit our Website

You are free to explore the Website without providing any Personal Information about yourself. When you visit the Website or register for the Subscription Service, we request that you provide Personal Information about yourself, and we collect Navigational Information.

When You Use our Mobile Application

We use mobile analytics software to allow us to better understand the functionality of our Mobile Apps on your mobile device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. In addition to information we collect on our Website, when you use our Mobile Apps we may also collect your city location, device model and version, device identifier (or “UDID”), OS version, and your Closir Subscription Service credentials.

We may link information we store within the analytics software to Personal Information you submit within the Mobile App. We do this to improve services we offer you and improve our marketing, analytics and site functionality.

Personal Information

This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business. Personal Information can also include information about you that is available on the internet, such as from LinkedIn, Twitter and Google, or publicly available information that we acquire from service providers.

Personal Information also includes Navigational Information or Payment Information where such information can directly or indirectly identify an individual. Navigational information refers to information about your computer and your visits to this website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see the "Navigation Information" section below. Personal information includes payment information we collect and process from you when you subscribe to the Subscription Service, including credit cards numbers and billing information, using third party PCI-compliant service providers. Except for this, we do not collect Sensitive Information from you.

Log Files

When you use our services our view content provided by us, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by Closir for the operation of the Subscription Service, to maintain quality of the Subscription Service, and to provide general statistics regarding use of the Closir Website. For these purposes, we do link this automatically-collected data to Personal Information such as name, email address, address, and phone number.

Information we collect from third parties

From time to time, we may receive Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities, and publicly available sources such as social media websites.

Information About Children

The Website is not intended for or targeted at children under 16, and we do not knowingly or intentionally collect information about children under 16 If you believe that we have collected information about a child under 16, please contact us at support@closir.com, so that we may delete the information.

3. How We Use Information We Collect

Compliance with Our Privacy Policy

We use the information we collect only in compliance with this Privacy Policy. Customers who subscribe to our Subscription Services are obligated through our agreements with them to comply with this Privacy Policy.

We Never Sell Personal Information

We will never sell your Personal Information to any third party.

Use of Personal Information

In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to:

  • improve your browsing experience by personalising the Website and to improve the Subscription Service;
  • send information or Closir content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business;
  • promote use of our services to you and share promotional and information content with you in accordance with your communication preferences;
  • provide other companies with statistical information about our users -- but this information will not be used to identify any individual user;
  • send information to you regarding changes to our Customer Terms and Conditions, Privacy Policy, or other legal agreements
  • meet legal requirements.

We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your Personal Information to the third party. We use the information collected through our Subscription Service by our customers for the following purposes:

  • to provide the Subscription Service (which may include the detection, prevention and resolution of security and technical issues);
  • to respond to customer support requests;
  • otherwise to fulfil the obligations under the Closir Terms and Conditions. 

ALegal basis for processing Personal Information (EEA only)

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

Use of Navigational Information

We use Navigational Information to operate and improve the Website and the Subscription Service. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalised information about Closir. 

Customer Testimonials and Comments

We post customer testimonials and comments on our Website, which may contain Personal Information. We obtain each customer's consent via email prior to posting the customer's name and testimonial.

Use of Credit Card Information

If you give us credit card information, we use it solely to check your financial qualifications and collect payment from you. We use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf.

Security of your Personal Information

We use a variety of security technologies and procedures to help protect your Personal Information from unauthorised access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorised access, use or disclosure. All Personal Information is protected using appropriate physical, technical and organisational measures.

External Website

Our Website provides links to other websites. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.

Public Forums

We offer publicly accessible messages and blogs. Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums, this information may be collected and used by others. We will correct or delete any information you have posted on the Website if you so request, as described in "Opting Out and Unsubscribing" below.

Retention of Personal Information

How long we keep information we collect about you depends on the type of information. as described in further detail below.  After such time, we will either delete or anonymise your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.

We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so (for example, as long as is required in order to contact you about the Subscription Service or our other services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements).

When we have no ongoing legitimate business need to process your Personal Information, we securely delete the information or anonymise it or, if this is not possible, then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information from the servers at an earlier date if you so request, as described in "To Unsubscribe from Our Communications" below.

If you provide information to our customers as part of their use of the Subscription Service, our customers decide how long to retain the personal information they collect from you. If a customer terminates its use of the Subscription Service, then we will provide customer with access to all information stored for the customer by the Subscription Service, including any Personal Information provided by you, for export by the customer according to our agreement with our customer. After termination, we may, unless legally prohibited, delete all customer information, including your Personal Information, from the Subscription Service.

If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your Closir account.  We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created. 

4. How we Share Information we Collect

Corporate Events

If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by Closir on the Website and the Subscription Service. In this event, you will be notified via email and/or a prominent notice on our Website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.

Compelled Disclosure

We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.

5. Cookies and Similar Technologies

Cookies

Closir and its partners use cookies or similar technologies (such as web beacons) to analyse trends, administer the Website, track users’ movements around the Website, and to gather demographic information about our user base as a whole.

Navigational Information Collected by Our Customers

Our customers can use the tools we provide, as well as tools provided by third parties, to collect Navigational Information when you visit their webpages on the Subscription Service. Closir does not control our customers' use of these tools, nor do we control the information they collect or how they use it. 

6. How to Access and Control Your Personal Data

Reviewing, Correcting and Removing Your Personal Information

You have the following data protection rights:

  • You can request access, correction, updates or deletion of your personal information.
  • You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
  • If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the US and Canada) are available here.)

To exercise any of these rights, please contact us at support@closir.com or by mail to Closir, Ltd., 14 London Terrace, Hackney Road, London E2 7SQ, United Kingdom, Attention: Privacy. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.

To Unsubscribe From Our Communications

You may unsubscribe from our marketing communications by clicking on the "unsubscribe" link located on the bottom of our e-mails, updating your communication preferences, or by sending us email us at support@closir.com or postal mail to Closir, Ltd., 14 London Terrace, Hackney Road, London E2 7SQ, United Kingdom, Attention: Privacy. Customers cannot opt out of receiving transactional emails related to their account with us or the Subscription Service. 

To Unsubscribe from Our Customers' Communications

Our customers are solely responsible for their own marketing emails and other communications; we cannot unsubscribe you from their communications. You can unsubscribe from our customers' marketing communications by clicking on the "unsubscribe" link located on the bottom of their emails, or by contacting them directly.

]Contact


Closir Ltd.
14 London Terrace
Hackney Road
London E2 7SQ
United Kingdom

Cookie Policy

Last Updated: January 2017

When accessing or using our Website, we may use one or more "cookies". "Cookies" are small text files, placed on a computer hard drive, which enable websites to remember your user preferences. Without cookies, we may not be able to provide certain services or features, and the Website will not work as efficiently as we would like. You can turn cookies off, but if you do this you may not be able to access some services on the Website.

Please note that, by accessing or using our Website, you agree to the use of cookies as described in this Policy.

What is a cookie?

Cookies are text-only strings of information that are downloaded to your computer or mobile device when you visit our Website or another website using our implemented web tool. Your web browser then sends these cookies back to the originating website on each subsequent visit, or to another website that recognizes those cookies. You can find more information about cookies at www.allaboutcookies.org.

Cookies are widely used in order to make websites work in an efficient way. The use of cookies allows you to navigate between pages efficiently. Cookies remember your preferences, and make the interaction between you and the website smoother and more efficient. Cookies are also used to help ensure that the adverts you see online are relevant to you and your interests.

Setting and storing cookies

Cookies may be set either by the website you are visiting ("first party cookies") or by third party websites who run content on the website you are viewing ("third party cookies"). They may be stored either for the duration of your visit to the Website or for repeat visits.

Different types of cookies

There are four main types of cookie:

  1. Strictly Necessary Cookies: These cookies are essential to enable you to login, navigate around and use the features of a website, or to provide a service requested by you, for example by remembering items you have placed in an online shopping basket. We do not need to obtain your consent in order to use these cookies.
  2. Functionality Cookies: These cookies allow the website to remember choices you make (such as your user name, language, or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by using a cookie to store information about the region in which you are currently located, remember changes you have made to text size, fonts, and other parts of web pages that you can customize, and provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect remains anonymous and they cannot track your browsing activity on other websites.
  3. Performance cookies: These cookies collect information about how you use a website, for example which pages you go to most often, and record difficulties you may experience while using the Website, for example error messages. All information collected by these cookies is aggregated and therefore anonymous. It is only used to improve the efficiency of the website.
  4. Targeting Cookies or advertising Cookies: These cookies are used to deliver advertisements tailored to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator's permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organization. For more information about online behavioral advertising cookies and online privacy, please see the guide produced by the internet advertising industry available at www.youronlinechoices.com.

How to manage your cookie settings

There are various ways in which you can manage and control your cookie settings. You should bear in mind that, by deleting or blocking cookies, some or all of the websites you visit (or features of them) may not work properly or as effectively.

  1. Turning off cookies via your web browser - Most modern web browsers will provide you with some general information about cookies, enable you to see what cookies you’ve got, allow you to delete them all or on an individual basis, and enable you block or allow cookies for all websites or individually selected websites. You can also normally turn off third party advertising cookies separately. Please note that if you adjust your cookie settings via your web browser then, unless you delete or block each cookie individually, the changes will apply to all websites that you visit – not just our websites. You will also need to adjust your cookies on a browser-by-browser basis.
  2. Turning off third party cookies - You can turn off the third party targeting/advertising cookies described in "How we use cookies" above by visiting the Network Advertising Initiative opt-out page.

You will also have the option of turning off third party targeting/advertising cookies each time you see an advertisement that has been personalized to you. Some advertising networks that partner with us may use cookies to better manage advertising campaigns, specifically to personalize advertising messages and to impose frequency caps. Networks that are active on the site are participating in "Your Ad Choices" program and allow immediate opt-out of interest-based advertising by clicking on the "Your Ad Choices Icon". For more information please visit: www.youradchoices.com.

Note that the third party listed above may need to set a cookie in order to remember that their targeting/advertising cookies should not be assigned to you in the future. If you change or delete your browser’s cookie file, or change or upgrade your browser or device, then you might need to opt out again.