Closo.ai Privacy Policy

Last updated: 13 Feb 2025

1. Introduction

UAB Growfeya (hereinafter referred to as "Closo.ai", "we", "us", or "the Company"), company registration number 306280430 having its registered office at Studentų g. 11-6, Kaunas, is committed to protecting and respecting your privacy.

This Privacy Policy ("Policy") explains how we collect, use, and disclose your personal data when you use our services ("Services"), visit our website, or otherwise interact with us. We process all personal data in accordance with the EU General Data Protection Regulation No. 2016/679 (GDPR), the Law on the Legal Protection of Personal Data of the Republic of Lithuania, and other applicable laws.

For any questions regarding this Policy or requests concerning your personal data, please contact us at info@closo.ai.

2. What Information We Collect and Why

PurposeLegal BasisPersonal Data
Contract Conclusion and Pre-contractual StepsTaking necessary steps before entering into a contract and/or conclusion of a contractName, surname, address, telephone number, email address, company name, job title, company website, payment information (if applicable)
Service ProvisionPerformance of a contractName, surname, email address, company name, job title, company website, usage data (IP address, browser information, pages visited), cookies and tracking data, company lists and data imported by you
Customer SupportLegitimate interestName, surname, email address, communication content, usage data
Website ContactYour consentName, surname, email address, phone number (optional), message content
Marketing CommunicationsYour consent (for non-clients) / Legitimate interest (for existing clients, for similar services, with opt-out)Email address, name, company name
Service Improvement and AnalyticsLegitimate interestUsage data, cookies and tracking data, anonymized and aggregated data
Security and Technical Issue ResolutionLegitimate interestUsage data, IP address, device identifiers
Legal Compliance and Dispute ResolutionLegal obligation / Legitimate interestAny collected data as required by law or for legal proceedings

3. How We Collect Your Personal Data

We collect your personal data in the following ways:

  • Directly from you: When you fill out forms on our website or platform, communicate with our customer support, contact us via email or social media, or use our Services.
  • From third parties: This may include business partners, subcontractors, service providers, payment processors, or other entities we collaborate with.

4. Direct Marketing

Existing Clients: We may use your email address for direct marketing of similar services, unless you object. You can opt-out at any time by following the unsubscribe link or instructions in any email we send.

Other Cases: We will only use your personal data for direct marketing with your explicit consent. You can withdraw your consent at any time. We provide a clear and easy way to opt-out of marketing communications in every email.

5. How We Share Your Personal Data

We may disclose your personal data to:

  • Public authorities, institutions, courts, and other third parties as required by law or to protect our legitimate interests.
  • Service providers who assist us with legal, financial, auditing, tax, business management, advertising, and other services. They are contractually obligated to protect your data and only process it according to our instructions.
  • Third parties for contract performance or with your consent.
  • Affiliate companies within our group.
  • Third parties in connection with a potential business sale or due diligence.

6. International Data Transfers

If your data is transferred outside the EEA, we will ensure appropriate safeguards are in place, such as:

  • Adequacy decisions by the European Commission.
  • Standard Contractual Clauses (SCCs) - for more information, see: European Commission SCCs
  • Other safeguards or derogations as permitted by the GDPR.

7. Data Retention

We will retain your personal data for as long as necessary for the purposes outlined in this Policy, to comply with legal obligations, or to resolve disputes. Personal data related to contractual relationships is typically stored for the duration of the contract and up to 10 years afterward. If you do not enter into a contract with us, data is usually stored for a maximum of [Insert Number] months. Longer retention may be necessary for legal defense, suspected illegal activity, or as required by law. Upon expiration of the retention period, we will delete or anonymize your data.

8. Your Rights

You have the following rights regarding your personal data:

  • Right to be informed: Receive clear information about how we process your data.
  • Right of access: Request a copy of your personal data.
  • Right to rectification: Request correction or updating of your data.
  • Right to data portability: Request transfer of your data to another organization or to you.
  • Right to erasure ("right to be forgotten"): Request deletion of your data.
  • Right to restriction of processing: Request limitations on how we process your data.
  • Right to object: Object to certain types of processing, such as direct marketing.
  • Right to lodge a complaint: Lodge a complaint with a supervisory authority (e.g., the State Data Protection Inspectorate of the Republic of Lithuania - address: L. Sapiegos st. 17, LT-10312 Vilnius, phone No.: +370 5 271 2804 / 279 1445, for more information, visit https://vdai.lrv.lt/en/).
  • Right to withdraw consent: Withdraw your consent at any time (where processing is based on consent).

To exercise these rights, please contact us at info@closo.ai. We will respond to your request within 30 calendar days, which may be extended by 60 days in complex cases. We may refuse requests that are manifestly unfounded or disproportionate, or where exceptions or limitations apply under the GDPR.

9. Data Security

We implement appropriate security measures to protect your data, but no method is 100% secure. We and our service providers are contractually obligated to respect the confidentiality of your personal data.

10. Cookies

We use cookies to operate and improve our service. You can manage cookies in your browser settings, but disabling them may affect some functionality. Examples of cookies we use include:

  • Session Cookies: To operate our Service.
  • Preference Cookies: To remember your preferences and various settings.
  • Security Cookies: For security purposes.

For more information on how to control cookie settings, please see the Cookie Policy on our website.

11. "Do Not Track" Signals

We do not currently respond to Do Not Track ("DNT") signals.

12. Service Providers

We may employ third-party companies and individuals ("Service Providers") to facilitate our Service, provide the Service on our behalf, perform Service-related services, or assist us in analyzing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. This includes:

  • Services Integration: To enrich data or perform features within Closo.ai.
  • Analytics: To monitor and analyze service usage.
  • Payments: We use third-party payment processors for paid services. We do not store your payment card details.

13. Company Website Data

By importing company websites into Closo.ai, you represent and warrant that you have all necessary rights and permissions to do so, including any required consents from the companies themselves. You are solely responsible for the accuracy and legality of the data you import.

14. Changes to these Terms

We may update this Policy at any time. Changes will be effective upon posting on our website.

15. Contact Us

For any questions, please contact us at info@closo.ai.