Last updated 10/10/22
CloseSimple (“CloseSimple”, “we”, “us” or “our”) provides Users (as defined below) with web-based proactive and on-demand communication platforms (collectively, the “Services”). Learn more about our Services at closesimple.com (“Website”).
Information We May Collect
Here are some examples of the types of information CloseSimple may collect (collectively “Personal Information”):
Some information (which may be deemed personal information in some jurisdictions) may be automatically received and stored as non-identifiable personal information. Such information is collected passively using various technologies and cannot presently be used to specifically identify you. Examples of this non-personal information includes the type of internet browser or mobile device you use, any Website or device from which you have come to the Services, your operating system location data (which is anonymous), your IP address, cookie ID, pages accessed and clickstream, additional session information and timestamps. We may store such non-personal information ourselves or it may be included in databases owned and maintained by our affiliates, agents, or service providers. The Services may use such non-personal information to assist us in providing effective Services and to collect broad demographic information for aggregate use.
Most web and mobile device browsers automatically accept cookies. You may change or adjust your settings to prevent this if you wish. Please note, however, that by blocking or deleting cookies you may not be able to take full advantage of the Services. If you have questions about how to change or adjust your settings, please direct those inquiries to the maker of your device or service provider.
Use of Information
In general, Personal Information you submit to us is used either to respond to requests that you make or to aid us in serving you better. We and our service providers may use your Personal Information in various ways, including to:
Use of Other Information
We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. We may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where CloseSimple is accessed so that we can better understand customer behavior and improve our products, Services, and advertising.
If we combine non-Personal Information with Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.
Disclosure to Third Parties
At times CloseSimple may make Personal Information available to strategic partners that work with CloseSimple to provide products, Services, or Content, or that help CloseSimple market to customers or Users. Personal information will only be shared by CloseSimple to provide or improve our products, Services, content, and advertising; it will not be shared with third parties for their marketing purposes nor will it in any event be sold to any third party.
We share Personal Information with our service providers for the purpose of providing the Services and to companies who provide additional services such as information processing, payment processing, delivering products to you, managing and enhancing user data, providing user service, assessing your interest in our products and Services, and conducting User research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever CloseSimple operates.
We will share Personal Information with third party companies, organizations, or individuals outside of CloseSimple if we have a good faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to:
Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.
CloseSimple will not sell or rent your Personal Information.
Retention of Personal Information
Update to Personal Information
If your Personal Information is incorrect or needs updating, please contact CloseSimple immediately at info@CloseSimple.com.
Protecting Your Information
The security of your Personal Information is important to us. When you enter Personal Information on our Website, we encrypt the transmission of that information using TLS encryption.
We take commercially reasonable technical, administrative, and physical safeguards to protect information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Unfortunately, however, no security system is impenetrable. We cannot guarantee the security of our databases or the security of the databases of our affiliates or third parties with which we may share information, nor can we guarantee that information stored with us will not be stolen while being transmitted over the Internet. Email sent to us may not be secure and you should be careful when determining what information you wish to communicate via email. If you have questions about security on our Website or concerning the Services please contact info@CloseSimple.com.
Third Party Links and Services [and Payment Processing]
Our products and Services may also use or offer products or services from third parties. Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices.
[For online payments using credit or debit cards, Apple Pay, PayPal, Venmo and/or Automated Clearing House (ACH) payouts, we use the payment services of PaySimple. We do not store any of your credit card information after you make a purchase.]
Use of Information by You
Choices and Exclusions
You may visit the Website and use the Services without providing any Personal Information. If you do not provide the required information, however, you will not be able to use certain Services.
California Consumer Privacy Act Notice
Information We Collect
We may collect “Personal Information,” defined as information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. Personal Information does not include publicly available information from government records, de-identified or aggregate consumer information, health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
The Personal Information we collect may depend on your relationship to us. We may have collected the following categories of Personal Information from California consumers in the past 12 months:
Sources of Personal Information
We collect some of the Personal Information described above directly from you and your agents, such as through documents you provide, and your interactions with us, including those on our websites and through our systems. We also collect Personal Information from categories of sources such as third parties authorized by you.
Use of Personal Information
Depending on your relationship with us, we may use or disclose the Personal Information we collect for one or more of the following business purposes:
We will not collect additional categories of Personal Information from those identified above or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We do not sell your Personal Information for monetary consideration to anyone. We may disclose your Personal Information to a third party for a business purpose. We do not disclose the Personal Information of consumers under 18 years of age.
In the preceding twelve (12) months, we have disclosed the following categories of personal information to third parties for a business purpose:
Category A: Identifiers;
Category B: Personal Information as defined in the California customer records law;
Category C: Protected classification characteristics under California or federal law;
Category D: Commercial Information;
Category H: Audio / Video / Electronic information;
Category I: Professional or employment-related information; and
Category K: Inferences drawn from Personal Information
We share your Personal Information for a business purpose to the following categories of third parties:
Your California Privacy Rights
If you are a California resident, you may have certain rights with respect to your Personal Information, including the following:
If you exercise the right to delete your Personal Information, we may still retain your Personal Information as permitted under applicable law, including but not limited to the following purposes:
In addition, California Civil Code Section 1798.83 permits California residents who use our Website to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.
215 Kentucky Ave S
Minneapolis, MN 55426
Phone: 1-866-942-5673 (1-866-94-CLOSE)
Only you (or a person registered with the California Secretary of State you have authorized to act on your behalf) may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. You may make such a request no more than twice during a 12-month period.
We shall respond to consumer inquiries within forty-five (45) days and at no cost to you. We will inform you in writing if we require more time to respond, up to an additional forty-five (45) days. We may charge a fee to respond to excessive, repetitive, or manifestly unfounded requests, in which case we will provide you with a cost estimate and rationale before completing your request.
We must verify your identity with respect to such inquiries. Please provide enough information to permit us to locate you in our records. Depending on the nature of the Personal Information at issue and the clarity of your request, we may require additional measures or information from you as part of that verification. If you have an account with us, we will deliver our written response to that account. If you request delivery of specific pieces of Personal Information, we will select a readily useable format that should permit you to transmit the information to another entity without hindrance.
For California residents under age 18 who have publicly posted content or information, you may request and obtain removal of such content or information pursuant to California Business and Professions Code Section 22581, provided you are registered user of any Website where this Notice is posted. To make such a request, please send an email with a detailed description of the specific content or information to info@CloseSimple.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that the law may not require or allow removal in all instances, even if requested.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Changes to Our Privacy Notice
We may change or update this Notice from time to time. When we do, we will post the revised Notice on this page with a new “Last Updated” date.
Phone: 1-866-942-5673 (1-866-94-CLOSE)
Postal Address: CloseSimple, Inc.
215 Kentucky Ave S
Minneapolis, MN 55426
Last Updated: 10/10/22
Notice for Individuals Located In EU
215 Kentucky Ave S
Minneapolis, MN 55426
Please note that when we collect information about end users, we are acting as a data processor on behalf of our Customers. If you are an end user, please contact the business or individual who sent you the text message.
We need to inform users about the legal basis for our processing of their personal data. Our legal basis depend on the context in which the personal data is collected and processed. Generally, we only collect personal data when we need the personal data to perform a contract with users (such as our Terms of Service), when we have consent to do so or when the processing is in our legitimate business interests and not overridden by the privacy or other fundamental rights and freedoms of users (such as when we process personal data to prevent spam or fraud).
In some cases, we also may have a legal obligation to collect personal data from users. If we ask you to provide personal data 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 providing your personal data is mandatory and the possible consequences if you do not provide your personal data.
Similarly, if we collect and use personal data in reliance on our legitimate interests (or those of any third party), this interest is typically to provide our Services and communicate with you about our Services and for our legitimate commercial interests, such as responding to queries, improving our site and Services, advising users about new features or maintenance or undertaking marketing activities. We may have other legitimate interests and if appropriate we will make clear our legitimate interests at the relevant time.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided below.
For personal data for which we are the data controller and for which applicable law grants you data protection rights, if you would like to review, correct, update, suppress, restrict or delete personal data that you have previously provided to us as or if you would like to receive an electronic copy of your personal data for purposes of transmitting it to another company (where this right to portability is provided to you by law), please submit your request to us as follows:
215 Kentucky Ave S
Minneapolis, MN 55426
In your request, please make clear what personal data you would like to have changed, whether you would like to have your personal data suppressed from our database or other limitations you would like to put on our use of your personal data. For your protection, we only fulfill requests for the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity and geographic residency before fulfilling your request. We will try to comply with your request as soon as reasonably practicable and within the time periods required by applicable law.
Please note that we often need to retain certain personal data for record keeping purposes and/or to complete any transaction that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the personal data provided until after the completion of such purchase or promotion). Our databases and other records may have residual personal data which will not be removed. We also may not allow you to review certain personal data for legal, security or other reasons.
EEA residents have the right to lodge a complaint with a data protection authority about how we process your personal data. Please see https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en for more information.
International Transfers of Personal Information
CloseSimple may transfer your personal information to jurisdictions other than the one in which you reside. These other jurisdictions may have data protection laws that are different from the laws of your place of residence (and, in some cases, not as protective).
Specifically, our servers are located in countries which may be located outside of the jurisdiction where we collected the data. This means that when we collect your personal information, we may transfer it to or process it in any of the countries in which we do business. Also, some of the third-party service providers with which we may share personal information (as described above) are located in and may transfer personal information to various jurisdictions around the world. When we transfer personal data from the EEA to a jurisdiction outside the EEA, we deploy appropriate technical and organizational safeguards consistent with the requirements of applicable data protection law.