closrr

Privacy Policy

Last updated: February 23, 2026

1. Introduction

Closrr.io ("Closrr", "we", "us", or "our") is a company registered in England and Wales. We are committed to protecting the privacy of our users in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website and use our platform.

For the purposes of data protection law, Closrr is the data controller responsible for your personal data.

2. Information We Collect

2.1 Personal Information

We may collect the following personal data:

  • Name, email address, and contact information
  • Account credentials (encrypted)
  • Organisation and role information
  • Payment and billing information (processed by third-party providers)

2.2 Usage Data

We automatically collect:

  • Practice session recordings and transcripts
  • Performance scores and analytics
  • Device information, browser type, and IP address
  • Pages visited and features used
  • Cookies and similar tracking technologies

3. Lawful Basis for Processing

Under the UK GDPR, we process your personal data on the following lawful bases:

  • Contract: Processing necessary to perform our contract with you (providing the platform services)
  • Legitimate Interests: Processing necessary for our legitimate business interests (improving our services, analytics), provided these do not override your rights
  • Consent: Where you have given explicit consent (marketing communications, non-essential cookies)
  • Legal Obligation: Processing necessary to comply with UK law

4. How We Use Your Information

We use collected information to:

  • Provide, maintain, and improve our AI coaching services
  • Personalise your training experience
  • Process transactions and manage subscriptions
  • Send service updates and marketing communications (with consent)
  • Analyse usage patterns to improve our platform
  • Comply with legal obligations under UK law

5. Data Sharing and Disclosure

We do not sell your personal data. We may share data with:

  • Service Providers: Cloud hosting, analytics, and payment processors who act as our data processors
  • Organisation Admins: Aggregated team performance data within your organisation
  • Legal Requirements: When required by UK law, court order, or to protect our legal rights
  • Regulatory Bodies: The Information Commissioner's Office (ICO) or other regulators as required

6. Data Retention

We retain your personal data for as long as your account is active or as needed to provide services. Practice session data is retained for 24 months unless you request earlier deletion. You may request data deletion at any time through your account settings or by contacting us.

7. Your Rights Under UK GDPR

Under the UK GDPR and the Data Protection Act 2018, you have the following rights:

  • Right of Access: Request a copy of your personal data (Subject Access Request)
  • Right to Rectification: Correct inaccurate or incomplete personal data
  • Right to Erasure: Request deletion of your personal data ("right to be forgotten")
  • Right to Restriction: Restrict processing of your personal data
  • Right to Data Portability: Receive your data in a structured, commonly used, machine-readable format
  • Right to Object: Object to processing based on legitimate interests or direct marketing
  • Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent
  • Rights Related to Automated Decision-Making: Not be subject to decisions based solely on automated processing, including profiling

To exercise these rights, please contact our Data Protection Officer at privacy@closrr.io. We will respond to your request within one month, as required by UK GDPR.

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.

8. Your Rights Under CCPA

If you are a California resident, you additionally have the right to:

  • Know what personal information is collected about you
  • Know whether your personal information is sold or disclosed
  • Say no to the sale of personal information
  • Access your personal information
  • Request deletion of your personal information
  • Equal service and price, even if you exercise your privacy rights

We do not sell personal information. To exercise your CCPA rights, visit our Data & Privacy Preferences page.

9. Cookies and Tracking

We use cookies and similar technologies in accordance with the Privacy and Electronic Communications Regulations 2003 (PECR). You can manage your cookie preferences through our cookie consent banner. Our cookie categories are:

  • Strictly Necessary: Required for the platform to function (cannot be disabled)
  • Analytics: Help us understand usage patterns (opt-in required)
  • Marketing: Used for targeted advertising (opt-in required)

10. Data Security

We implement appropriate technical and organisational measures to protect your personal data, including encryption at rest and in transit, role-based access controls, regular security audits, and SOC 2 compliant infrastructure. In the event of a personal data breach, we will notify the ICO within 72 hours where required, and notify affected individuals without undue delay where there is a high risk to their rights and freedoms.

11. International Data Transfers

Your data may be transferred to and processed in countries outside the United Kingdom. Where we transfer personal data outside the UK, we ensure appropriate safeguards are in place in accordance with UK GDPR, including:

  • UK adequacy regulations (transfers to countries deemed adequate by the UK Government)
  • International Data Transfer Agreements (UK IDTAs) or the UK Addendum to EU Standard Contractual Clauses

12. Children's Privacy

Our services are not intended for individuals under 13 years of age (in line with the UK Age Appropriate Design Code). We do not knowingly collect personal data from children.

13. AI and Automated Decision-Making

Our platform uses artificial intelligence to provide coaching, scoring, and feedback on your sales practice sessions. This processing involves:

  • Analysing your practice session transcripts to generate performance scores
  • Providing AI-generated feedback, strengths, and areas for improvement
  • Simulating realistic sales scenarios with AI-powered prospect responses

Under Article 22 of UK GDPR, you have the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects. Our AI scoring is used as a training and coaching tool and does not produce legal effects or similarly significant decisions. However, if you have concerns about automated decision-making, you may contact our Data Protection Officer at privacy@closrr.io to request human review of any AI-generated assessment.

14. Data Protection Impact Assessments

We conduct Data Protection Impact Assessments (DPIAs) for processing activities that are likely to result in a high risk to individuals, as required under Article 35 of UK GDPR. This includes our use of AI for automated scoring and analysis of practice sessions. Our DPIAs are reviewed annually and whenever there are significant changes to our processing activities.

15. Sub-Processors

We engage third-party sub-processors to help deliver our services. Each sub-processor is bound by a Data Processing Agreement (DPA) that ensures your data is protected to the same standard we uphold. For a complete list of our sub-processors, including their purpose, data processed, and location, please visit our Sub-Processors page.

16. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last updated" date.

17. Contact Us

For privacy-related enquiries, contact our Data Protection Officer at: privacy@closrr.io

You can also contact the Information Commissioner's Office (ICO) if you have concerns about how we handle your data: ico.org.uk