THE SHORT VERSION
Information We Collect – You directly provide us with most of the information we collect: when you register to the Site, use it, complete forms, or register to any of our programs. We also collect information about your communications with CloseRocket as well as any of your communication with other users of CloseRocket. In addition, we automatically collect information while you access, browse, view or otherwise use the Site and receive information from third party vendors or other available sources.
Our Legal Basis for Using Your Personal Information – Where relevant under applicable laws, all processing of your personal information will be justified by a “lawful ground” for processing as detailed below.
How Do We Use the Information Collected? – We use personal information to provide you with quality service and security, to operate the Site, understand how people use the Site, and to perform our obligations to you; to ensure marketplace integrity and security; to prevent fraud; to contact you and send you direct marketing communications; to promote and advertise the Site, our services and the CloseRocket marketplace; to comply with lawful requests by public authorities and to comply with applicable laws and regulations.
How Long Do We Keep Personal Information – We will keep personal information only for as long as is required to fulfil the purpose for which it was collected. However, in some cases we will retain personal information for longer periods of time.
Children – This Site is offered and available to users who are at least 18 years of age and of legal age to form a binding contract. Minors are not permitted to use the Site or the CloseRocket services. We do not knowingly collect personal information from children under 18.
Sharing Personal Information with Third Parties – We share personal information with third parties in order to operate the Site, provide our services to you, fulfil obligations imposed on us by applicable laws and regulations, and prevent fraud, infringements and illegal activities.
Where We Store Personal Information – Some of the personal information you provide to us will be stored or processed on our behalf by third party suppliers and data processors and may be located in other jurisdictions.
Do Not Track (DNT) – Our Site does not respond to Do Not Track (DNT) signals.
External Links – the Site contains links to third party sites and if you link to a third-party site from the Site, any data you provide to that site and any use of that data by the third party are not under the control of CloseRocket and are not subject to this Policy.
Security – We implement technical and organizational measures to maintain the security of the Site and your personal information and in preventing unauthorized access, loss, misuse, alteration, destruction or damage to it through industry standard technologies and internal procedures.
Rights of EU, EEA and UK Users – Where we process personal data related to EU, EEA and UK user, further terms apply to our processing in relation to your rights as a data subject under EU data protection laws, as detailed below.
Updating Personal Information – We take steps to ensure that the personal information we collect is accurate and up to date, and we provide you with the opportunity to update your information through your account profile settings. In the event that you believe your information is in any way incorrect or inaccurate, please let us know immediately.
Contact Us – You can exercise your rights over your personal information, by contacting us at firstname.lastname@example.org. More details about the rights applicable to you are in the long version of the Policy.
The above are just the highlights. We encourage you to read more about the information we collect, how we use it, understand the meaning of cookies and more in the long version of our Policy below.
THE LONGER VERSION
CloseRocket is committed to protecting the personal information of its users – sales persons, companies and other visitors browsing the Site (“users”) as well as affiliates, influencers and other collaborators interacting with CloseRocket. We believe that you have a right to know our practices regarding the information we collect when you visit and/or use the Site. This Policy explains our privacy practices for the Site and services provided by CloseRocket as well as privacy practices that apply to affiliates, influencers and other collaborators who are individuals. By accessing and/or using the Site and its related sites, services, goods and/or registering for an account, you acknowledge that you understand how we process your personal data in accordance with this Policy, including our collection, use, disclosure, processing and retention of personal information. You can also learn how to limit sharing of information in this Policy.
1 Information We Collect
1.1 Information You Provide. When you register to the Site, use it, complete forms, participate in skills tests or surveys, we ask you to provide certain personal information, including a valid email address and username. We will also ask you to provide or otherwise collect additional information, such as, your name, profile details, physical address or billing information, telephone number or other contact details, transactional information, payment information (for example, in certain cases we process your payment method and credit card number), taxpayer information and forms, details about other social networks linked accounts, details about your listed gigs, purchases, education, profession and expertise, information and files uploaded by you to the Site, and additional authentication information (such as copies of your government issued ID, passport, or driving license, as permitted by applicable laws). We also collect information about or contained in your communications with CloseRocket as well as any of your communication with other users of CloseRocket.
1.3 Information We Receive from Third Parties. We receive information from third party vendors and/or other commercially available sources, such as:
- Third party vendors who provide us data to supplement the information we collect about you, in accordance with applicable laws. For example, we receive fraud warnings from service providers for our fraud prevention and risk assessment efforts. We also receive information from enrichment service providers to enhance and personalize your experience as well as from advertising and marketing partners in order to manage and measure our campaigns.
- If you integrate into your account information from third parties or otherwise integrate your account with third party systems, tools or products, we will receive certain information about you according to your permissions at such third parties.
We combine your personal information with information we collect automatically or obtain from other companies and use it for the purposes detailed in this Policy.
2 Our Legal Basis for Using Your Personal Information
2.1 Where relevant under applicable laws, all processing of your personal information will be justified by a “lawful ground” for processing. In the majority of cases, processing will be justified on the basis that:
- you have provided your consent for us to use your personal information for a specific purpose;
- our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to provide you with services which you have purchased);
- the processing is necessary to comply with a relevant legal obligation or regulatory obligation that we have (e.g. fraud prevention); or
- the processing is necessary to support our legitimate interests as a business (e.g. to improve our services to you), subject to your interests and fundamental rights and provided it is conducted at all times in a way that is proportionate.
3 How Do We Use The Information Collected?
3.1 We will use your personal information for the following purposes:
- to provide you with quality service and security, to operate the Site, to perform our obligations to you and to develop and improve our service. For example, we use personal information to verify your identity. We also use this information to establish and set up your account, verify or re-issue a password, log your activity, enable your communications with other users, provide customer support and contact you from time to time. The information helps us to develop and improve our services, to understand and analyse our performance as well as your preferences and performance and to customize and personalize our service and enhance your experience.
- to ensure marketplace integrity, prevent fraud and maintain a safe and secure marketplace and services. For example, we use personal information to monitor, track and prevent fraudulent activities and other inappropriate activities, monitor content integrity, conduct security investigations and risk assessments, verify or authenticate information provided by you, enforce our Terms of Service and comply with applicable laws. We conduct certain behavioural analytics to achieve the above objectives and in limited cases, if we detect activity that we think poses a risk to the CloseRocket marketplace, other users, our community, or third parties, automated processes may restrict or limit your ability to use CloseRocket.
- to contact you, as requested by you or as otherwise approved by you or permitted according to this Policy.
- to promote and advertise the Site, our services and the CloseRocket marketplace. For example, we use the information collected from you for the purpose of sending direct marketing messages (as detailed below), to show you information that may be of interest to you, or other promotional activities or events.
- to maintain appropriate business records, to comply with lawful requests by public authorities and to comply with applicable laws and regulations or as otherwise required by law.
3.2 We will ask for your consent before using information for a purpose other than those set out in this Policy.
3.3 Direct marketing:
- We use your personal information to send you direct marketing communications about our products, services or promotions from CloseRocket that may be of interest to you or our related services. This may be via email, post, SMS, telephone or targeted online advertisements.
- Our processing of your personal information for marketing purposes is based on our legitimate interest, or on your consent, or as otherwise permitted according to applicable laws. You have a right to prevent direct marketing of any form at any time – this can be exercised by following the opt-out link attached to each communication or by sending an email to email@example.com.
- We take steps to limit direct marketing to a reasonable and proportionate level, and to send you communications which we believe may be of interest or relevance to you, based on the information we have about you.
4 How Long Do We Keep Personal Information?
4.1 We apply a general rule of keeping personal information only for as long as is required to fulfil the purpose for which it was collected. However, in some circumstances, we will retain your personal information for longer periods of time. We will retain personal information for the following purposes:
- as long as it is necessary and relevant for our operations, e.g., so that we have an accurate record of your dealings with us in the event of any complaints or challenge; and
- in relation to personal information from closed accounts to comply with applicable laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Site terms and take other actions as permitted by law.
5.1 This Site is offered and available to users who are at least 18 years of age or older and of legal age to form a binding contract. Minors under 18 are not permitted to use the Site or the CloseRocket services. We do not knowingly collect personal information from children under 18. Parents and guardians should at all times supervise their children’s activities. If we learn we have collected or received personal information from a child under 18, we will delete that personal information. If you believe we might have any information from or about a child under 18, please contact us at firstname.lastname@example.org.
6 Sharing Personal Information with Third Parties
6.1 We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent.
6.2 We share your personal information with third parties as detailed below:
- With other users and Site visitors. Once you register, your username, country, and additional information regarding your account and activity, experience with sales, languages is made public and is visible to all users of the Site. Please be aware that certain information, such as your user name and profile, will be publicly displayed when you use such features. Your information will also be shared with other users when you message or otherwise communicate with such users. When you publish your information and/or share your data with other CloseRocket users, you do so at your own risk. If you choose to share personal information with other users, such personal information is shared with other users as separate controllers. While our Terms of Service require users to keep the information shared with them confidential, CloseRocket cannot ensure that all users will do so and it is your responsibility to ensure that other users will comply with your standards.
- With Service Providers. We share personal information for business purposes with service providers that provide us with services for the purpose of operating the Site, opening and operating your account as well as providing ancillary services and solutions. These include, among others, hosting services, billing and payment processors and vendors, CRM systems, forum hosting, community management services, data and cybersecurity services, web analytics and performance tools, translation tools, IT SaaS services, session recording, communication systems, mailing systems, data optimization and marketing services, data enrichment services, legal and financial advisors or technical consultants. Consistent with applicable legal requirements, we take appropriate technical and organizational measures to require third parties to adequately safeguard your personal information and only process it in accordance with our instructions;
- For legal reasons. We share personal information with law enforcement agencies, public authorities or other parties in order to respond to a subpoena or court order, judicial process or to regulatory authorities, if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes; when we believe it necessary or appropriate to disclose personal information to law enforcement authorities, such as to investigate actual or suspected fraud or violations of law, breaches of security, or breaches of this Policy; to respond to claims against us; and to protect the rights, property, or personal safety of CloseRocket, our customers, or the public;
- For payments and fraud detection. We share personal information with payment processors, fraud detection agencies and similar third parties for the purpose of facilitating payments done via the Site and securing the Site and protecting it against fraud, unauthorized transactions (such as money laundering), claims or other liabilities;
- With users with whom you interact. We share personal information to help facilitate interactions between users.
- In the context of a corporate transaction. Personal information will also be disclosed if we go through a business transition such as a merger, sale, transfer of all or a portion of CloseRocket’s assets, acquisition, bankruptcy or similar event. In the event that we sell any business or assets, we will disclose your data to the prospective buyer. If we or substantially all of our assets are acquired by a third party, information held by us about our users will be one of the transferred assets.
7 Where We Store Your Personal Information
7.1 Some of the personal information you provide to us will be stored or processed on our behalf by third party suppliers and data processors and may be located in other jurisdictions, such as the United States and Israel, whose laws may differ from the jurisdiction in which you live. Whether to third parties or internally, there are also transfers of personal information from the European Economic Area (“EEA”) to countries outside of the EEA not deemed to provide an adequate level of data protection from a European data protection perspective, such as the United States. With regard to data transfers to such recipients outside of the EEA we provide appropriate safeguards, in particular, by way of entering into European Union (EU) standard contractual clauses as amended from time to time, and/or equivalent data transfer safeguards. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy.
8.2 A cookie is a piece of information (text file) stored on your device. When you visit our site, we set our own cookies (called first-party cookies) to store information on your device, such as your language preferences or login information. We also use 3rd-party cookies, which are cookies set by our partners (such as Google, etc.).
8.3 The duration of a cookie depends on its function. “Session cookies” are only active during your online session, while “persistent cookies” will stay active on your device after closing your browser.
9 Do Not Track
10 External Links
11.1 We implement technical and organizational measures to maintain the security of the Site, our services and personal information and in preventing unauthorized access, loss, misuse, alteration, destruction or damage to it through industry standard technologies and internal procedures. We contractually ensure that any third party processing your personal information equally provides for confidentiality and integrity of your data in a secure way. However, the transmission of data via the internet is not completely secure, and although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to the Site. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access. Users who have registered to the Site agree to keep their password in strict confidence and not disclose such password to any third party. Further information about our data security practices can be provided on request.
12 Rights of EU, EEA and UK Users
12.1 This section of the Policy applies to you if you are in the EU, the European Economic Area (EEA) or UK.
12.3 Under applicable EU regulation, you have the following rights in respect of your personal information:
- to obtain information about how and on what basis your personal information is processed and to obtain a copy;
- to rectify inaccurate personal information;
- to erase your personal information in limited circumstances where (a) you believe that it is no longer necessary for us to hold your personal information; (b) we are processing your personal information on the basis of legitimate interests and you object to such processing, and we cannot demonstrate an overriding legitimate ground for the processing; (c) where you have provided your personal information to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your personal information; and (d) where you believe the personal information we hold about you is being unlawfully processed by us;
- to restrict processing of your personal information where: (a) the accuracy of the personal information is contested; (b) the processing is unlawful but you object to the erasure of the personal information; (c) we no longer require the personal information for the purposes for which it was collected, but it is required for the establishment, exercise or defence of a legal claim or (d) you have objected to us processing your personal information based on our legitimate interests and we are considering your objection;
- to object to decisions which are based solely on automated processing or profiling;
- where you have provided your personal information to us with your consent, to ask us for a copy of this data in a structured, machine-readable format and to ask us to share (port) this data to another data controller; or
- to obtain a copy of or access to safeguards under which your personal information is transferred outside of the EEA.
12.4 Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, to the processing of your personal data by us and we may be required to no longer process your personal data. Moreover, if your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your personal data will no longer be processed for such purposes by us.
12.5 In addition to the above, you have the right to lodge a complaint with a supervisory authority for data protection. Please note that the right of access and the right to erasure do not constitute absolute rights and the interests of other individuals may restrict your right of access or erase in accordance with local laws.
12.6 We will ask you for additional data to confirm your identity and for security purposes, before disclosing data requested by you. We reserve the right to charge a fee where permitted by law. We will decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we will retain where necessary certain personal information for a limited period of time for record-keeping, accounting and fraud prevention purposes.
13 Updating Personal Information
13.1 We take steps to ensure that the personal information we collect is accurate and up to date, and we provide you with the opportunity to update your information through your account profile settings. In the event that you believe your information is in any way incorrect or inaccurate, please let us know immediately. We will make sure we investigate the matter and correct any inaccuracies as quickly as possible where necessary or give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. When updating your personal information, we will ask you to verify your identity before we can act on your request. If for any reason you have a problem with deleting your personal information, please contact CloseRocket at email@example.com and we will make reasonable efforts to delete any such information pursuant to any applicable privacy laws.
13.2 You can review and change your personal information by logging into the Site and visiting your account profile page.
14 Contact Us
14.1 To exercise any of your rights in connection with your personal information, we kindly ask that you contact us at firstname.lastname@example.org.
14.2 If you have any questions (or comments) concerning this Policy, please email our team at email@example.com, and we will make an effort to reply within a reasonable timeframe. For the purposes of GDPR (Article 27), you may contact our EU representative under the following contact details: Deal machine s. r. o., with its registered seat at Hlboká cesta 1418/42, 010 01 Žilina, Slovak Republic, registered with the Commercial Register of District Court Žilina, Section: Sro, Insert No.: 81291/L.