Last Updated: January 2017

General

Closir Ltd. (hereinafter "Closir" or "the Company" or "we") is the owner of the website www.closir.com (the "Site") and the app associated therewith (the "App"; and together with the Site, collectively, the "Service"). Closir is committed to protecting your privacy and we understand you want to keep your information private, safe and discrete. This Privacy Policy is designed to help you decide whether to use the Service and in what manner, and it describes how we collect, store and use information on individuals who use the Service.

Consent to use Information

This Policy is a legally binding agreement between you ("you" or "user") and us. By visiting, accessing or using the Website or App, or providing information to us in any other format, you agree to and accept the terms of this Privacy Policy, as amended from time to time, and you consent to the collection and use of information in the manner set out in this Policy. We encourage you to review this Policy carefully and to periodically refer to it so that you understand it and its subsequent changes if any. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, PLEASE STOP USING THE SERVICE IMMEDIATELY AND WHERE RELEVANT UNINSTALL. IN ADDITION TO THIS PRIVACY POLICY, PLEASE REVIEW OUR TERMS AND CONDITIONS AND COOKIE POLICY WHICH ARE INCORPORATED HEREIN BY REFERENCE, TOGETHER WITH SUCH OTHER POLICIES OF WHICH YOU MAY BE NOTIFIED OF BY US FROM TIME TO TIME.

What Information Does Closir Collect?

We collect two types of data and information from you:

(1) Non-Personal Information - Closir retains some non-personally identifiable information ("Non-Personal Information"), such as your approximate geo-location, your web request, browser type, browser language, web pages you visit before or after visiting our Website or using the App, URLs, platform type, click numbers, landing pages, viewed pages and the order of those pages and time spent on pages. This information is collected and retained for security reasons and so that we can audit and statistically track usage, audit our affiliates, and calculate payments to third parties. Non-Personal Information is collected, inter alia, through the use of cookies, so when accessing or using the Website, we may use one or more cookies and clear gifs (aka, Web Beacons). Cookies are small text files, placed on a user's device, which enable a website to remember user preferences, and Web Beacons are small pieces of code placed on a website to monitor the behavior and collect data about the visitors viewing a web page. Detailed information about cookies and how we use them on the Website and other websites implementing our web tools may be found in our Cookie Policy, which also describes how you can turn off cookies or control them.

(2) Personal Information - "Personal Information" is information that may be of a private or sensitive nature, including your name, gender, phone number, e-mail address or mailing address, and IP address. Some of the Personal Information is collected from you when you create an account ("Account") on the Service (which may be required in order to access certain services or programs via the Service) and submit your information. You are also able to create an Account using your credentials with a designated third party website or service ("Third Party Account"), such as Facebook® or Google®. Doing so will enable you to link your Account and your Third Party Account. If you choose this option, a Third Party Account pop-up box will appear which you will need to approve in order to proceed, and which will describe the types of information that we will obtain from, and the types of activities that we may perform in connection with your Third Party Account. Such information includes your Personal Information stored on this Third Party Account, such as user name, email address, profile picture, gender, birthday and preferences.

We treat any Non-Personal Information which is specifically connected or linked to any Personal Information as Personal Information.

Mandatory and Optional Information

In order to access our Services, users may be asked to fill in a form, providing some personal information to the Company. Answers to questions on Personal Information are not mandatory unless the fields are marked with an asterisk. Provision of the information requested in the optional fields of the registration form is not mandatory in order to receive the services and information that we provide through the Site (unless otherwise indicated in the registration form). However, failure to complete mandatory fields or providing incorrect Personal Information may prevent us from fully providing the requested information or services

What is the Purpose of Collecting this Information?

We collect the information outlined above in order to provide you with a better service. Non-Personal Information is collected for research and statistical purposes, to enable us to develop, customize and improve the Service, based on your preferences, usage and interactions with the Service, to process your requests for information, and to provide you with the most relevant services and offers.

Your Personal Information is collected to enable us to provide you with features, capabilities, offers and marketing materials we or our marketing partners think you may be interested in. In addition to the above, your Personal Information allows us to provide you with technical assistance and support.

Who Else Receives this Information?

We may share or transfer information, including Personal Information, internally within our group of affiliated companies.

We also share Personal and Non-Personal Information with third parties, when this is required in order to provide, maintain or improve our services and operation. This is the case with third party advertisements and affiliates; we share your information with third parties for the purpose of providing you with advertisements and offers we or third parties think you may be interested in.

We share your Personal and Non-Personal Information with (i) third parties which provide services to the Company in order to allow or enable us to provide you with our services, including email services providers and data verifiers; (ii) third parties who provide the Company services in relation to the operation of the Website; (iii) any auditors, contractors or other advisers auditing any of the Company's business processes; and (iv) any potential purchasers or investors in the Company.

Any processing performed by any of our third party service providers ("Recipients") will, where required by law, be governed by a data processing agreement in the form required by law, preserving any and all of your statutory data protection rights and obligating the Recipients to respect the Personal Information and handle it in accordance with the relevant laws. The Recipients are required to maintain the confidentiality of such information and to use your Personal Information only in the course of providing the aforementioned services and only for the purposes that Closir dictates.

We may also share your Personal Information and other information in special cases if we have a good reason to believe that it is necessary to: (i) comply with law, regulation, subpoena or court order; (ii) detect, prevent or otherwise address fraud, security, violation of our policies or technical issues; (iii) enforce the provisions of this Privacy Policy or any other agreements between you and Closir, including investigation of potential violations thereof; or (iv) protect against harm to the rights, property or safety of the Company, its partners, its affiliates, users or the public.

Direct Marketing

We may share your email address and phone number with our marketing partners and may periodically use it ourselves for the purpose of providing you with marketing offers. At any time, you may request to discontinue receiving these offers by following the on-page instructions at info@closir.com If you unsubscribe we will remove your email address from our marketing distribution lists and from any future lists we may share with our marketing partners. However, you may need to separately unsubscribe from marketing offers sent by our marketing partners. In addition, Closir may sometimes offer contests, sweepstakes, promotions, editorial features, or other activities or offerings that are sponsored or co-sponsored by or presented with identified third parties. By virtue of your participation in such activities or offerings, your IP address and the personally identifiable information that you voluntarily submit may be provided to both the Services and the third parties.

Use of Information

The collection and processing of Personal Information is aimed at providing you with services offered by the Website, to send you marketing offers on products or services we think may be relevant to you, and to fulfill other purposes as provided in this privacy policy. The Company will store this data as long as we believe it to be necessary and appropriate in order to provide and manage our services.

Right of Access, Rectification, Cancellation and Objection

You have the right to access, correct, update or object to the use of your Personal Information by making a written request to Closir.com using our Contact Us page. Your requests will be dealt with in a prompt and professional manner.

Security and Confidentiality

The Company treats your Personal Information in strict confidentiality, and the server in which this data is to be stored includes the necessary industry-standard security measures to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access. However, we cannot completely guarantee the security of your information, which might be accessed, disclosed, modified, or destroyed, and it should be emphasized that you share this information at your own risk. In addition:

  • We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input.
  • We reveal only the last four digits of your credit card numbers when confirming an order. Of course, we transmit the entire credit card number to the appropriate credit card company during order processing.
  • It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when finished using a shared computer.

Accessing, Correcting, and Deleting Your Personal Information

We will take reasonable steps to accurately record the Personal Information that you provide to us and any subsequent updates.

We encourage you to review, update, and correct the personal information that we maintain about you, and you may request that we delete personal information about you that is inaccurate, incomplete, or irrelevant for legitimate purposes, or are being processed in a way which infringes any applicable legal requirements, by contacting us as set out in the "How to Contact Us" section below. At our election, instead of deleting such information, we may retain it with your comment or correction noted in our records. By contacting us, you may also object to our further use of your personal information if you have compelling legitimate grounds (this may involve closing your account). We may ask you to verify your identity and to provide other details before we are able to provide you with any information, correct any inaccuracies, or delete any information. Your right to review, update, correct, and delete your personal information may be limited, subject to the law or your jurisdiction: (i) if your requests are abusive or unreasonably excessive, (ii) where the rights or safety of another person or persons would be encroached upon, or (iii) if the information or material you request relates to existing or anticipated legal proceedings between you and us, or providing access to you would prejudice negotiations between us or an investigation of possible unlawful activity. Your right to review, update, correct and delete your information is subject to our records retention policies and applicable law, including any statutory retention requirements.

Links to Other Websites

This Privacy Policy applies only to the Service, and to our web tools which are integrated or implemented in other third party websites. The Policy does not apply to third party websites, linked to our Website. Third party websites or services may have their own privacy policies and we advise you to read them carefully. Inclusion of a link to a third party website or service is not a recommendation of such a website or service. Third party sites may contain information or services that are illegal or that some people may find inappropriate or offensive. Before using third party sites and services or before making a purchase, we recommend that you read and understand the privacy policies and terms and conditions of such third party websites and services, and the warranties for purchased products. You are knowingly and voluntarily assuming all risks of using third party sites to purchase products and services. You acknowledge and agree that we shall have no liability whatsoever with respect to such third party sites and your use of them.

Children

The Services are intended for general audiences and is not directed to children under 16. We do not knowingly collect personal information from children/users under 16. If you become aware that a child has provided us with personal information without parental consent, please contact us. If we become aware that a child under the age of 16 has provided us with personal information without parental consent, we take steps to remove such information and terminate the child's comment.

Assignment

We may transfer or assign your information, without any notice, and without a need to receive your consent, to any third party as a result of change of control, consolidation, merger, acquisition or reorganization. You acknowledge that in the event of bankruptcy, insolvency or receivership, we may have no control over the use and transfer of your Personal Information.

Updates to this policy

This Privacy Policy is subject to modifications. Please check the "Last Modified" heading at the bottom of this document to see when this Privacy Policy was last updated. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Website. Your use of the Services, or your provision of personal information following any changes means that you accept the updated Privacy Policy.

How to Contact Us

If you have any questions or concerns about the Closir Privacy Policy or its implementation please contact us by sending an email to info@closir.com or by writing to:

Closir Ltd.
One Canada Square, E14 5AB London, UK
info@closir.com
Attention: TIm Greer



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.