1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• phone numbers
• email addresses

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Stripe and PayPal. You may find their privacy notice link(s) here: https://stripe.com/privacy and https://www.paypal.com/us/legalhub/privacy-full.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in section 7 below.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: https://closergym.com/cookies.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, settings, date/time stamps, pages/files viewed, searches, device event information (such as system activity, crash dumps), and hardware settings.
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device used to access the Services. This may include IP address, device IDs, location, browser type, hardware model, ISP/mobile carrier, and operating system.
• Location Data. We collect location data such as information about your device's location, which can be precise or imprecise (e.g., GPS or IP address). You can opt out by refusing access or disabling Location settings on your device.

Google API

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Calendar integration (Google Calendar and Outlook)

If you choose to connect a calendar, we request read-only access to your calendar events. We use it only to find your upcoming sales calls and to email you a warm-up before each one and a debrief after it. For each event in the period we check, we store its title, start time, end time, and whether it looks like a sales call. We read guest lists, meeting links and event descriptions only to make that decision, and we do not store them.

We never create, change or delete events, never contact anyone on your calendar, never use calendar data for advertising, never sell or transfer it, and never use it to train AI models. Access tokens are encrypted and stored only on our servers. Disconnecting your calendar in Integrations revokes our access where the provider allows it and deletes the events we stored.

If you write a debrief of a call, the text you write is processed by our AI provider to build a practice roleplay of that call and is stored with your account.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, social media URLs, and custom profiles.

If you interact with us on a social media platform using your social media account (e.g., Facebook or X), we receive personal information about you from such platforms such as your name, email address, and gender.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the purposes listed below, or for other purposes with your explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We process your information so you can create and log in to your account and keep it in working order.
• To deliver and facilitate delivery of services to the user. We process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We process your information to respond to inquiries and solve potential issues.
• To send administrative information to you. We process your information to send details about products/services, changes to terms/policies, etc.
• To fulfill and manage your orders. We process information to fulfill and manage orders, payments, returns, and exchanges.
• To enable user-to-user communications. We process information if you choose offerings allowing communication with another user.
• To request feedback. We process information when necessary to request feedback and contact you regarding platform usage.
• To send you marketing and promotional communications. You can opt out of our marketing emails at any time.
• To protect our Services. We process information for fraud monitoring and security.
• To identify usage trends. We process usage information to better understand how the platform is used so we can improve it.
• To determine the effectiveness of marketing campaigns. We process information to provide relevant marketing and promotional campaigns.
• To save or protect an individual's vital interest. We process information when necessary to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) under applicable law, like consent, contract performance, legitimate interests, legal obligations, or vital interests.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations and/or with specific categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We share data with third-party vendors, contractors, or agents who perform services for us under strict contracts designed to safeguard your personal data.

Categories of third parties include:

• AI Platforms
• Cloud Computing Services
• Data Storage Service Providers
• Payment Processors
• User Account Registration & Authentication Services
• Website Hosting Service Providers
• Communication & Collaboration Tools
• Sales & Marketing Tools
• Affiliate Marketing Programs
• Social Networks
• Data Analytics Services

We also share information in these specific situations:

• Business Transfers: During negotiations of mergers, sales of assets, or acquisitions.
• Business Partners: To offer certain products, services, or promotions.
• Other Users: When you share comments, contributions, or interact in public areas or team features, such content may be viewed by other users.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We use cookies, web beacons, and pixels to maintain site security, prevent crashes, save preferences, and analyze performance. Details are set out in our Cookie Notice: https://closergym.com/cookies.

Google Analytics: We share information with Google Analytics to track service usage. Opt out at https://tools.google.com/dlpage/gaoptout. View Google's privacy practices at Google Privacy & Terms.

PostHog: We use PostHog to measure how far people get through signing up, so we can find and fix the steps where they get stuck. It records a small, fixed set of product events: that you started signing up, that you started or finished a practice call and how many seconds it lasted, that you reached the pricing screen, and which plan and billing period you chose. Events are linked to a random account identifier, never to your name or email address. Read PostHog's privacy practices at posthog.com/privacy.

What analytics never receives. We do not use session recording or screen replay anywhere in CloserGym, and we do not capture keystrokes, form contents, or clicks automatically. No part of a roleplay, no call recording or transcript, no uploaded call, no script or offer text you write, and no information about your prospects is ever sent to an analytics provider. Web addresses are stripped of anything after the question mark before they are sent, so identifiers from a checkout or an email link are not shared. These analytics run only if you allow analytics cookies, and they stop immediately if you withdraw that permission or if your browser sends a Global Privacy Control signal.

6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

We offer AI Products powered by AI Service Providers (including Google Cloud AI). Your inputs, outputs, and personal information are shared with and processed by these providers to enable roleplays, scoring, and analysis.

Our AI Products include:

• AI applications
• AI bots
• AI insights
• Machine learning models
• Natural language processing
• Text analysis

How We Process Data Using AI: All personal information processed using AI is handled in line with our Privacy Notice and enterprise service agreements, ensuring high security safeguards.

How to Opt Out: Contact us using the contact details provided in section 20.

7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in using a social media account, we may have access to certain profile information about you.

Where you choose social logins (like Facebook or X), we receive profile info (name, email, profile picture, friend lists) as permitted by your social media privacy settings. We use this data strictly as described in this Privacy Notice.

8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our primary servers are located in the United States. If you access our Services outside the US, your information will be transferred to facilities in the US and other countries where our subprocessors operate.

Standard Contractual Clauses: We deploy the European Commission's Standard Contractual Clauses (SCCs) and UK Addendums for data transfers originating from the EEA, UK, or Switzerland.

9. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We retain personal data as long as your account remains active. When we have no ongoing legitimate business need, we either delete or anonymize such information, or isolate backup archives securely until deletion is feasible.

10. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures (TLS encryption, AES-256 disk encryption, role-based database security). However, no internet transmission is 100% secure; accessing the Services is at your own risk.

If a breach happens. If personal information collected through the Services is ever accessed or disclosed without authorization, we will notify the affected users by email, and any regulators where the law requires it, without undue delay.

11. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

By using the Services, you represent that you are at least 18 years of age. If we learn that personal information from minors has been collected, we will deactivate the account and delete the data promptly. Contact main@closergym.com if you suspect minor data has been collected.

12. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You have rights that allow you greater access to and control over your personal information depending on your jurisdiction (EEA, UK, Switzerland, Canada, US states).

Your rights include requesting access, copies, corrections, erasure, processing restriction, data portability, and human review for automated decisions.

Withdrawing your consent: You can withdraw consent at any time via https://closergym.com/contact.

Opting out of marketing: Click the unsubscribe link in emails or contact us to be removed from marketing lists.

Account Information: You can request account termination at any time. We will deactivate/delete your account from active databases.

13. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers include a Do-Not-Track ("DNT") setting. Because no uniform technology standard exists, we currently do not respond to DNT signals.

Global Privacy Control (GPC): We recognize and honor Global Privacy Control (GPC) signals. When detected, we automatically treat GPC signals as a valid opt-out of targeted advertising and sale/sharing under CCPA and state laws. Learn more at globalprivacycontrol.org.

14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Residents of CA, CO, CT, DE, FL, IN, IA, KY, MD, MN, MT, NE, NH, NJ, OR, RI, TN, TX, UT, or VA have specific state privacy rights.

Categories of Personal Information We Collect

Data Retention: Categories A, B, D, E, F, G, H, I, K are retained as long as the user maintains an active account with us.

We have not sold or shared personal data to third parties for a commercial purpose in the preceding 12 months.

Exercising US State Rights: Submit requests via https://closergym.com/contact or email support@closergym.com. California residents may also request annual "Shine The Light" disclosures.

19. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes, we may notify you by posting a notice or directly sending you a notification.

20. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at main@closergym.com, or contact us by post at:

21. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information.

To request to review, update, or delete your personal information, please visit: https://closergym.com/contact.