Privacy Policy

This Privacy Policy explains how Clozers ("Clozers," "we," "us," or "our"), a product of Prime 5 Digital LLC, collects, uses, discloses, and protects information when you use the Clozers application, mobile applications, websites, and related services (collectively, the "Service").

By using the Service, you agree to the collection and use of information in accordance with this Policy. If you do not agree, please do not use the Service.

Note: Clozers is a sales-coaching and team-management platform intended for use by businesses and their personnel. It is not directed to anyone under 18, and we do not knowingly collect personal information from minors.

1. Who We Are

The Service is operated by Prime 5 Digital LLC ("Company"). For privacy-related questions:

• Email: rick@clozers.app

For users in jurisdictions that require a designated contact, the above also serves as the point of contact for data-protection inquiries.

2. Our Role: When We Control Data and When We Only Process It

Clozers handles two different categories of information, and your rights differ depending on which applies.

Account Data — we act as the controller. Information about the businesses and individuals who subscribe to Clozers: names, emails, billing details, and how the platform is used. We determine how this information is used, and this Policy governs it.

Customer Content — we act as a processor / service provider. Material your organization uploads or generates inside Clozers: call recordings, transcripts, deal and appointment records, notes, coaching scores, and data synced from your CRM. Your organization controls this data. We process it only to provide the Service and on your organization's instructions.

If you are a sales representative using Clozers through your employer, or a prospect whose conversation was recorded by a Clozers user, your organization or the recording party — not Clozers — determines how that content is collected, used, and retained. Direct your requests to them; we will support them in responding.

3. Information We Collect

3.1 Information You Provide

• Account information: name, email address, password (stored hashed), company or team name, and role (owner, manager, representative).

• Profile information: details you add to your profile or team settings, including uploaded branding assets such as a logo for white-label customers.

• Content you submit: messages, notes, deal and appointment records, pipeline information, voice recordings and audio, and other content you create or upload.

• Communications: information you provide when you contact us for support.

3.2 Billing Information

Payments are processed by Stripe. Payment-card details are collected and processed directly by Stripe; we do not store full payment-card numbers. We receive limited billing information such as subscription status, plan tier, seat count, billing contact, and the last four digits and card brand of a payment method.

3.3 Recordings, Transcripts, and Coaching Data

Where enabled, the Service captures audio of sales conversations — conducted in person, by telephone, or over video conferencing — and generates:

• Transcripts of those recordings;

• Coaching feedback produced by the AI Coach;

• Competency and skill-level scores, including changes to those scores over time and the reasons recorded for each change.

These materials necessarily contain the personal information of people who are not Clozers users — see Section 4.

3.4 Information From Connected Systems

If your organization connects a third-party system — including HubSpot, GoHighLevel, MarketSharp, or Lead Perfection — we receive data from that system according to the permissions your administrator grants. This typically includes contact records, lead and opportunity data, activity history, and pipeline status. We use it only to power the features you have enabled and for no independent purpose of our own.

3.5 Information Collected Automatically

• Usage data: features used, pages viewed, actions taken, session duration, timestamps.

• Device and log data: IP address, browser type, operating system, device identifiers, mobile app version.

• Cookies and similar technologies: used to operate and secure the Service and keep you signed in. You can control cookies through your browser; disabling some may affect functionality.

We honor Global Privacy Control (GPC) signals where applicable law requires.

3.6 Mobile Application Data

Our mobile applications request access to your device's microphone in order to capture audio for recording and voice coaching features. Audio is captured only while a recording session is active. We may also request notification permissions to deliver coaching and account alerts. You may revoke these permissions in your device settings at any time, though doing so will disable the corresponding features.

3.7 Information From Team Administrators

If you use the Service as a member of a team, the owner or administrator who invited you may provide your email address and assign your role. Your activity within the team — including recordings, transcripts, coaching feedback, competency scores, and pipeline data — is visible to your team's managers and owner through manager-facing features.

4. Recordings and the Information of Third Parties

Recordings and transcripts captured through the Service contain the voices, names, statements, and sometimes contact and financial details of prospects and customers who are not Clozers users.

The Customer and the individual user are solely responsible for obtaining all legally required notices and consents before recording any conversation. Recording is regulated by federal and state wiretapping and eavesdropping laws, and a number of states require the consent of every participant to a call or conversation. Clozers provides the recording capability; it does not obtain consent on your behalf and does not verify that consent has been obtained.

We process third-party information contained in recordings only as a processor, on the Customer's instructions, for the purpose of transcription, coaching analysis, and storage. If you are a prospect or customer who was recorded and you wish to access or delete that recording, contact the business that recorded you. If you contact us directly, we will forward your request to the relevant Customer.

5. Voice Data and Biometric Information

Because the Service processes recorded speech, we want to be explicit.

We use audio recordings to produce transcripts, analyze conversation structure and content, and generate coaching feedback against the sales methodology on which the platform is trained.

[CONFIRM BEFORE PUBLISHING — must match what the system actually does] We do not create voiceprints or voice templates, perform speaker identification or verification against enrolled biometric profiles, or use voice characteristics to identify any individual. Where the Service separates speakers within a recording, that separation is used solely to attribute dialogue within that recording and is not retained as a biometric identifier.

Several states — including Illinois (BIPA), Texas (CUBI), and Washington — impose specific written-notice and consent requirements on the collection of voice biometrics, and Illinois provides a private right of action. If any feature is enabled that would create a voiceprint, your organization must obtain written consent from each affected individual before use.

If you are located in Washington State, certain audio and inferred data may fall within the My Health My Data Act. We do not knowingly collect consumer health data through the Service.

6. How We Use Information

We use the information we collect to:

• Provide, operate, maintain, and secure the Service;

• Create and manage accounts, teams, seats, and roles;

• Process transactions and manage subscriptions and billing;

• Transcribe recordings and power the AI Coach, including generating coaching feedback, summaries, and competency scores;

• Provide manager and team-administration features, including activity summaries, recordings review, and pipeline visibility to authorized team members;

• Synchronize data with connected CRM systems at your direction;

• Communicate with you about the Service, including transactional messages such as invitations, confirmations, and password resets;

• Respond to your requests and provide customer support;

• Produce aggregated and de-identified analytics to understand feature usage and improve the Service. Aggregated data does not identify any individual or organization;

• Detect, prevent, and address fraud, abuse, security incidents, and technical issues;

• Comply with legal obligations and enforce our terms and agreements.

We do not sell personal information, and we do not share personal information for cross-context behavioral advertising.

6.1 AI Model Training

[CONFIRM BEFORE PUBLISHING] We do not use Customer Content — including your recordings, transcripts, deal data, or coaching history — to train, fine-tune, or improve any general-purpose AI model, whether ours or a third party's. Our AI subprocessors are engaged under terms that prohibit the use of submitted data for model training. Coaching output is generated at the time of the request and is not used to alter models available to other customers.

7. Automated Scoring and Profiling

The Service generates competency and skill-level scores for individual sales representatives, and updates those scores automatically following sales calls, closed deals, and other recorded activity. These scores are produced by automated analysis of recorded conversations and outcomes, and are visible to your organization's managers and owner.

Clozers does not make employment decisions. Scores are informational coaching output. Any decision an employer makes on the basis of them — including decisions about compensation, advancement, assignment, or continued employment — is the employer's decision alone, and the employer is responsible for the lawfulness of that decision.

Where required, individuals have the right to request an explanation of how a score was produced, to contest it, and to request human review. Direct such requests to your organization's administrator, who controls the workspace. Residents of certain jurisdictions may have the right to opt out of profiling that produces legal or similarly significant effects; contact us at rick@clozers.app.

8. Third-Party Service Providers (Subprocessors)

We rely on a limited set of trusted third-party providers ("subprocessors") to operate the Service. Each processes information only on our behalf, under contract, and is bound by obligations of confidentiality and security. We use the following categories of provider:

All of our infrastructure providers store data in the United States.

When you use AI-powered features, the content you submit is transmitted to the applicable provider to generate a response and return it to you. We select providers that offer appropriate confidentiality and security commitments, and our agreements with AI providers prohibit the use of submitted content to train their models.

Named list. We do not publish the identities of our individual subprocessors, as our provider relationships are commercially confidential. A current named list is available to business customers and to individuals exercising data-protection rights, on written request to rick@clozers.app, subject to reasonable confidentiality terms. We will provide notice of material changes to that list in accordance with our Data Processing Addendum.

9. How We Share Information

We may share information:

• Within your team or organization, as described in Sections 3.7 and 7.

• With service providers, as described in Section 8.

• For legal reasons — to comply with applicable law, regulation, legal process, or governmental request; to enforce our agreements; or to protect rights, property, or safety. Where legally permitted, we will notify the affected Customer before disclosing Customer Content.

• In a business transfer — merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, subject to this Policy.

• With your consent or at your direction, including to systems you connect.

10. Data Retention

Team administrators can delete recordings and records within the platform. After account termination, we delete or de-identify Customer Content within [30–90] days, except where retention is required by law or necessary to resolve a dispute. Deletion from live systems occurs promptly; removal from encrypted backups occurs on the rotation cycle above.

Note that team-related content you contributed may remain accessible to your team after you leave it, consistent with how shared workspaces operate.

11. Security

We implement technical and organizational measures designed to protect information, including encryption in transit and at rest, role-based access controls, row-level security and tenant isolation between organizations, least-privilege internal access, and logging and monitoring. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your credentials confidential and notifying us promptly of suspected unauthorized access.

In the event of a security breach affecting personal information, we will notify affected Customers without undue delay and no later than [72] hours after becoming aware, consistent with applicable law.

12. Your Rights and Choices

Depending on where you live, you may have the right to:

• Access the personal information we hold about you;

• Correct inaccurate information;

• Delete your information;

• Object to or restrict certain processing;

• Obtain a portable copy of certain information;

• Opt out of sale, sharing for cross-context behavioral advertising, or profiling with legal or similarly significant effects (we do not sell or share);

• Withdraw consent where processing is based on consent;

• Non-discrimination for exercising these rights.

To exercise a right, contact rick@clozers.app. We will verify your identity before responding and will respond within the period required by law (generally 45 days, extendable once). You may use an authorized agent with proof of authorization.

Appeals. If we deny your request, you may appeal by writing to rick@clozers.app with the subject line "Privacy Appeal." We will respond to appeals within [45] days.

If you are a member of a team, some requests may need to be directed to or coordinated with your team's administrator, who controls the workspace.

You can also update your account and profile in Settings, adjust cookie preferences in your browser, and opt out of non-essential communications via the unsubscribe link (transactional messages are necessary to provide the Service).

13. International Data Transfers

We operate and store data in the United States. If you access the Service from outside the United States, your information may be transferred to, stored in, and processed in the United States and other countries where we or our providers operate.

Where we transfer personal data out of the EEA, UK, or Switzerland, we rely on the European Commission's Standard Contractual Clauses and the UK Addendum, together with supplementary measures where appropriate. A copy is available on request.

14. Region-Specific Disclosures

California (CCPA/CPRA). You have the right to know what personal information we collect, to request deletion or correction, and to opt out of "sale" or "sharing." We do not sell or share personal information as those terms are defined under California law. We do not knowingly collect the personal information of consumers under 16. You will not be discriminated against for exercising your rights. We do not disclose personal information to third parties for their own direct marketing purposes.

Virginia, Colorado, Connecticut, Utah, Texas, and other U.S. states. You have the rights described in Section 12, including the right to appeal a denied request.

EEA / UK (GDPR / UK GDPR). Our legal bases are: performance of a contract (providing the Service), legitimate interests (security, service improvement, and business operations), compliance with legal obligations, and consent where applicable. You have the rights described in Section 12 and may lodge a complaint with your local supervisory authority. For Customer Content we act as processor and will refer your request to the relevant Customer.

[If applicable: our Article 27 representative is [NAME / ADDRESS].]

Business customers may request our Data Processing Addendum at rick@clozers.app.

15. Changes to This Policy

We may update this Policy from time to time. When we make material changes, we will update the "Last updated" date and, where appropriate, provide additional notice by email or in-app message at least [30] days before the change takes effect. Continued use after changes take effect constitutes acceptance.

16. Contact Us

• Email: rick@clozers.app