Privacy Policy

Effective date: 1 September 2025 · Last updated: 1 September 2025

S9 Media (UDYAM-MH-27-0218240), operating the ClosersHQ platform ("we", "us", or "our"), is committed to protecting your privacy. This Privacy Policy explains how we collect, use, share, and protect information when you use our CRM platform at closershq.in ("Service"). By using the Service, you agree to the practices described here.

We comply with the Information Technology Act, 2000 (India), the Digital Personal Data Protection Act, 2023 (DPDP Act), and where applicable, the General Data Protection Regulation (GDPR).

1. Information We Collect

a) Account information: When you register, we collect your name, email address, mobile number, organisation name, and billing information.

b) Lead and contact data (Your Data): Data about leads and contacts that you upload, import, or receive through integrations — including names, phone numbers, email addresses, enquiry details, and interaction history. This data belongs to you; we process it only to operate the Service.

c) Usage data: We automatically collect information about how you use the Service — pages visited, actions taken, timestamps, and IP addresses. This helps us improve the platform.

d) Integration data: When you connect third-party services (e.g., Facebook, SMS providers, IVR telephony), we may receive data from those services as authorised by you, such as Facebook page access tokens and lead form submissions.

e) Cookies and similar technologies: We use session cookies to keep you logged in. We do not use tracking or advertising cookies. See Section 9 for details.

2. How We Use Your Information

To provide, operate, and improve the Service.
To process and display lead and contact data on your behalf.
To send service-related communications (account confirmations, subscription alerts, security notices).
To respond to your support requests.
To enforce our Terms of Service and prevent fraud or abuse.
To comply with applicable legal obligations.

We do not use Your Data (lead/contact data) for advertising or profiling, and we will never sell it.

3. Legal Basis for Processing (GDPR)

Where GDPR applies, we process your personal data on the following bases:

Contract: Processing necessary to provide the Service you have subscribed to.
Legitimate interest: Analytics and security monitoring to maintain Service quality.
Legal obligation: Compliance with applicable laws.
Consent: Where we ask for your specific consent (e.g., marketing emails).

4. Sharing and Disclosure

We do not sell your personal data. We may share it only in the following circumstances:

Service providers: Trusted third-party vendors who process data on our behalf (hosting, email delivery, payment processing) under data processing agreements.
Third-party integrations: When you connect an integration (Facebook, SMS, IVR), data flows between ClosersHQ and that service as needed to operate the integration. Each service has its own privacy policy.
Legal requirements: If required by law, court order, or government authority, we may disclose information to the extent required.
Business transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred. We will notify you and provide options where legally required.

5. Data We Process on Your Behalf (Lead Data)

Lead and contact data you store in ClosersHQ belongs to you. You act as the data controller; we act as the data processor. You are responsible for:

Collecting lead data lawfully (with appropriate consent where required).
Informing individuals about how their data is used.
Handling data subject requests (access, deletion, rectification) directed at your organisation.

We will assist you in meeting these obligations as required under applicable law.

6. Data Retention

Active accounts: We retain your data for as long as your account is active.
After termination: Account and lead data is retained for up to 30 days after account termination, then permanently deleted unless a longer period is required by law.
Logs and analytics: Usage logs may be retained for up to 12 months for security and operational purposes.

7. Security

We implement industry-standard security measures including:

HTTPS/TLS encryption for all data in transit.
Encryption at rest for sensitive credentials (API tokens, OAuth tokens).
Password hashing using bcrypt.
Role-based access control (RBAC) within organisations.
Webhook signature verification for third-party integrations.

No system is 100% secure. If you discover a security vulnerability, please report it responsibly to support@closershq.in.

8. Your Rights

Depending on your location, you may have the following rights regarding your personal data:

Access: Request a copy of the personal data we hold about you.
Rectification: Request correction of inaccurate data.
Erasure: Request deletion of your personal data (subject to legal retention obligations).
Portability: Request your data in a machine-readable format.
Objection / Restriction: Object to or request restriction of certain processing.
Withdraw consent: Where processing is based on consent, you may withdraw it at any time.

To exercise any of these rights, contact us at support@closershq.in. We will respond within 30 days.

9. Cookies

We use only essential session cookies to keep you authenticated while using the Service. We do not use analytics cookies, advertising cookies, or any cross-site tracking technologies. You can disable cookies in your browser, but this may prevent you from logging in.

10. Third-Party Services and Links

The Service integrates with and may contain links to third-party services (Facebook/Meta, SMS providers, telephony providers). These services have their own privacy policies, and we are not responsible for their practices. We encourage you to review their policies before connecting integrations.

11. Children's Privacy

The Service is not directed at individuals under 18 years of age. We do not knowingly collect personal data from minors. If we become aware that we have collected data from a minor, we will delete it promptly.

12. International Data Transfers

Your data is primarily stored and processed on servers located in India. If we transfer data internationally (e.g., through third-party processors), we ensure appropriate safeguards are in place in accordance with applicable law.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy here and updating the "Last updated" date. Your continued use of the Service after changes are posted constitutes your acceptance.

14. Contact Us

For privacy-related queries, requests, or concerns, contact us at:

Email: support@closershq.in
Website: closershq.in
Legal entity: S9 Media
Address: 705, Bhaveshwar Valencia, Plot Number 8, Sector 26, Ulwe, Navi Mumbai, Maharashtra – 410206, India
UDYAM Registration: UDYAM-MH-27-0218240