CLOSURE PRIVACY NOTICE

Last Updated: July 25, 2026

This Privacy Notice explains how Closure Intel, Inc. and its affiliates (collectively, “Closure,” “we,” “us,” or “our”) collect, use, disclose, and otherwise process personal data in connection with your use of Closure's websites, platforms, and services (collectively, our “Services”). We may also choose or be required by law to provide different or additional disclosures relating to the processing of personal data about residents of certain states. Please refer to the Region-Specific Disclosures section below for additional disclosures that may apply to you.

This Privacy Notice does not address our privacy practices relating to Closure job applicants, employees, and other employment-related individuals, nor data that is not subject to applicable data protection laws (such as deidentified or publicly available information). This Privacy Notice is not a contract and does not create any legal rights or obligations not otherwise provided by law.

Our Role in Processing Personal Data

Data protection laws sometimes differentiate between “controllers” and “processors” of personal data. A “controller” determines the purposes and means (the why and how) of processing personal data. A “processor,” sometimes referred to as a “service provider,” processes personal data on behalf of a controller subject to the controller's instructions.

This Privacy Notice describes our privacy practices where we are acting as the controller of personal data. It does not cover or address how our customers may process personal data when they use our Services, or how we may process personal data on their behalf in accordance with their instructions where we are acting as their processor. We recommend referring to the privacy notice of the customer through which you engage with us as a processor for information about how they handle personal data. In addition, we are generally not permitted to respond to individual requests relating to personal data we process on behalf of our customers, so we recommend directing any such requests to the relevant customer.

Our Collection and Use of Personal Data

The categories of personal data we collect depend on how you interact with us and our Services. You may provide us your personal data directly when you open an account, contact us, or use our Services. We also collect personal data automatically when you interact with our websites and other services, and we may collect personal data from other sources and third parties.

Personal Data Provided by Individuals

We collect the following categories of personal data individuals provide to us:

Contact Information, including first and last name, phone number, email address, mailing address, and communication preferences. We use this information primarily to fulfill your request or transaction, to communicate with you directly, and to send you marketing communications in accordance with your preferences.
Professional Information, including job title, employer, information about your role, and the nature of your relationship with us. We use this information primarily to fulfill your request or transaction, to determine how we communicate with you, to administer your account, to provide you with our Services, and for customer support purposes.
Account Information, including first and last name, email address, account credentials or one-time passcodes, and the products or services you are interested in, purchased, or have otherwise used, as well as transaction information (such as records of payment). We use this information to administer your account, provide our Services, communicate with you regarding your account and use of our Services, and for customer support purposes.
Customer Content, including any files, documents, case information, data, or communications you choose to input, upload, or transmit to our Services. We use this content primarily to provide you with our Services, to facilitate your requests, and to improve our Services.
Feedback and Support Information, including the contents of messages sent through forms, chat platforms (including live or automated chat), email, or other contact channels we make available, as well as recordings of calls with us where permitted by law. We use this information to investigate and respond to your inquiries, to communicate with you, and to improve our Services.

If you choose to contact us, we may need additional information to fulfill the request or respond to your inquiry. We may provide additional privacy disclosures where the scope of the request or personal data we require falls outside the scope of this Privacy Notice, in which case those additional disclosures will govern.

Personal Data Automatically Collected

We, and our third-party partners, automatically collect information about how you access and use our Services. We typically collect this information through cookies or small data files stored on your device, as well as related technologies such as web beacons, pixels, embedded scripts, and logging technologies. Information collected automatically may be combined with other personal data we collect directly from you or receive from other sources.

We, and our third-party partners, use these technologies to collect:

Information About Your Device and Network, including device type, manufacturer, model, operating system, IP address, browser type, internet service provider, and unique identifiers associated with you, your device, or your network.
Information About How You Use Our Services, including the site from which you came, the site you go to when you leave our Services, how frequently you access our Services, whether you open emails or click links in emails, and other browsing behavior and actions you take on our Services (such as pages visited, content viewed, and features used).

We use this information to enhance and personalize your experience, monitor and improve our Services, offer support features such as live chat, remember your preferences, provide custom content, monitor aggregate usage metrics, diagnose technical problems, and otherwise plan for and enhance our Services. For information about your choices regarding automatic data collection, see Your Privacy Choices below.

Personal Data from Other Sources and Third Parties

We may receive the categories of personal data described above from:

Our Affiliates: to provide our Services and facilitate operations consistent with this Privacy Notice.
Employers: if you interact with our Services in connection with your employment, we may obtain your contact information from your employer.
Service Providers: providers that perform services on our behalf, such as analytics, hosting, and payment processing, may collect personal data and share it with us.
Other Sources: including publicly available sources, third-party data providers, and business transactions such as mergers or acquisitions.
Inferences: we may generate inferences or predictions about you based on other personal data we collect and our interactions with you.

Additional Uses of Personal Data

In addition to the primary purposes described above, we may use personal data to:

Fulfill contractual obligations, facilitate payment, or deliver requested Services;
Manage our organization and day-to-day operations;
Communicate with you, including via email, text message, chat, or telephone;
Facilitate our relationship with you and, where applicable, the company you represent;
Address inquiries or complaints;
Create and maintain user accounts;
Verify your identity and entitlement to our Services;
Market our products and Services to you;
Administer, improve, and personalize our Services;
Analyze how you use our Services and infer additional information, such as your interests;
Create aggregated or de-identified information for purposes outside the scope of this Privacy Notice;
Conduct research and analytics on our user base and Services;
Test, enhance, update, and monitor the Services, or diagnose technology problems;
Maintain the safety, security, and integrity of our products, services, technology, and business;
Defend or enforce our rights or applicable agreements, resolve disputes, and protect our business interests;
Detect, prevent, or investigate security incidents, fraud, or illegal activity;
Facilitate business transactions or reorganizations;
Comply with contractual and legal obligations;
Fulfill any other purpose for which you provided your personal data or otherwise consented.

Our Disclosure of Personal Data

We disclose or otherwise make available personal data in the following ways:

To Our Affiliates, to provide our Services and facilitate operations consistent with this Privacy Notice.
To Your Employer, if you interact with our Services in connection with your employment.
To Service Providers, third parties we engage to perform services on our behalf, such as hosting, analytics, customer support, and payment processing.
To Other Businesses as Needed to Provide Services, including payment processors and other third parties needed to fulfill a request or transaction.
In Connection with a Business Transaction or Reorganization, such as a merger, acquisition, financing, or sale of company assets, including in the event of bankruptcy or insolvency.
To Facilitate Legal Obligations and Rights, including disclosures to legal advisors and law enforcement to comply with law, respond to legal process, protect our rights and property, detect or prevent fraud, or protect health and safety.
With Your Consent or Direction, such as when you ask us to share information with a third party.

We do not sell personal data or share it for cross-context behavioral advertising, and we have not done so in the preceding 12 months.

Your Privacy Choices

Communication Preferences

Email: You can stop receiving promotional emails by clicking “unsubscribe” in any marketing email. You cannot opt out of service-related emails (such as account verification or transaction confirmations).
Phone/Text: You can stop receiving promotional calls or texts by informing us directly, following opt-out instructions provided, or replying STOP to a text message. We may still contact you for service-related purposes (such as login verification).

Automatic Data Collection Preferences

Where available, you can adjust cookie and tracking preferences through a cookie preference tool linked in the footer of our website, or through your browser or device settings. Blocking these technologies may affect how well our Services work.

Modifying or Deleting Your Personal Data

If you have questions about reviewing, modifying, or deleting your personal data, contact us at privacy-inquiries@closure-intel.com. We may not be able to modify or delete your personal data in all circumstances.

Children's Personal Data

Our Services are not directed to, and we do not knowingly collect or solicit personal data from, children under the age of 18. If you are under 18, please do not use our Services or provide us with personal data. If we learn that a child under 18 has provided personal data to us, we will promptly delete it. Parents or guardians who believe their child has provided us personal data should contact us at privacy-inquiries@closure-intel.com.

Security of Personal Data

We have implemented reasonable physical, technical, and organizational safeguards designed to protect your personal data. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Retention of Personal Data

We retain personal data for no longer than reasonably necessary to fulfill the purposes for which it was collected, consistent with our legitimate business interests and applicable law. We consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, and our legal, regulatory, and accounting obligations in determining retention periods. Once retention is no longer necessary, we will delete or deidentify the data, or, where that is not feasible (e.g., data in backup archives), securely isolate it from further active processing until deletion is possible.

Third-Party Websites and Services

Our Services may include links to third-party websites, plug-ins, applications, and other services. Except where we expressly adopt or refer to this Privacy Notice, it does not apply to the privacy practices of third parties. Please review the privacy notices of any third-party services you use.

Region-Specific Disclosures

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal data about residents of certain states:

United States: If you are a U.S. resident, please see the Additional United States Privacy Disclosures below for a description of personal data rights available to residents of certain states.

Additional United States Privacy Disclosures

These disclosures supplement the information in our Privacy Notice for residents of certain U.S. states.

Your Additional U.S. Privacy Choices

Depending on your state of residency, and subject to certain legal limitations and exceptions, you may be able to exercise the following rights:

Right to Know: The right to confirm whether we process personal data about you and, for residents of certain states, to obtain details about the categories of personal data collected, sources, purposes of collection, and categories of third parties to whom personal data has been disclosed (if any).
Right to Access & Portability: The right to obtain a copy of the personal data we have collected about you in a portable format, where required by law.
Right to Correction: The right to correct inaccuracies in your personal data.
Right to Deletion: The right to have us delete personal data we maintain about you.

Submitting Privacy Rights Requests

To exercise any of these rights, please contact us at privacy-inquiries@closure-intel.com. Before processing your request, we will need to verify your identity and confirm your state of residency. We may decline or limit a request where we are unable to verify your identity, cannot locate your information in our systems, or where you are not a resident of an eligible state.

Nevada Residents

If you are a Nevada resident, you have the right to opt out of the sale of your personal data. We do not currently sell the personal data of Nevada residents (as defined under Nevada law), but you may still submit an opt-out request at privacy-inquiries@closure-intel.com.

California Residents

If you are a California resident, you may ask us to provide a list of the categories of personal information we have disclosed during the preceding year to third parties for their direct marketing purposes, and the identity of those third parties. We currently do not sell or share your personal information with third parties for their direct marketing purposes. To request this list, contact us at privacy-inquiries@closure-intel.com.

Updates to This Privacy Notice

We may update this Privacy Notice from time to time. When we make changes, we will update the date at the top of this Privacy Notice. If we make material changes, we will notify individuals by email, by prominent posting on our website, or through other appropriate communication channels. Changes are effective as of the date of publication unless otherwise stated.