If you are a California resident, the California Consumer Privacy Act and the California Privacy Rights Act (collectively, the “CCPA”) provide you with certain rights regarding your Personal Information, including the right to know about Personal Information collected, disclosed, or sold; the right to request that we delete Personal Information that we have collected from you; the right to update or correct your information; the right to opt-out of the sale or sharing of your Personal Information; the right to limit our use of your sensitive Personal Information; and the right not to be discriminated against for exercising your rights. These rights are subject to certain exceptions. You may also visit our Privacy Policy to learn more about how we protect your information.
Any capitalized terms in this California Privacy Notice that are not otherwise defined have the same meaning as they do in the CCPA or in our Privacy Policy. This California Privacy Notice also serves as our “Notice at Collection” under the CCPA.
Please note that this California Privacy Notice only applies to the extent that we are a data controller (or “Business”) in relation to the processing of Personal Information. To the extent that we are a data processor (or “Service Provider”) in relation to the Processing of Personal Information (such as in relation to Customer Content), this California Privacy Notice may not apply.
Collection of Personal Information
If you use our Services, we may collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). We may have collected the following categories of Personal Information about you over the past 12 months:
- Identifiers, such as your name and email address.
- Categories of Personal Information described in subdivision (e) of California Civil Code Section 1798.80, such as your name, address, or payment information.
- Log-in credentials, such as your username and password.
- Commercial information including records of your purchases with us.
- Professional or employment-related information.
- Internet or other electronic network activity information, such as your cookies or other unique identifiers, log data, or web beacons.
- Geolocation data, in order to enable synchronization of data between our Services.
- Inferences drawn from any of the information identified above.
We collect the Personal Information listed above from the following sources:
- From you directly, when you provide it to us.
- Automatically from your browser, device, or from our Services.
- Through actions, such as communications, initiated by our Customers.
- Through certain third parties, such as analytics providers and advertising networks.
Disclosure of Personal Information
In the last 12 months, we may have disclosed for our business purposes the following categories of Personal Information subject to the CCPA:
- Identifiers, such as your name and email address.
- Categories of Personal Information described in subdivision (e) of California Civil Code Section 1798.80, such as your name, address, or payment information.
- Log-in credentials, such as your username and password.
- Commercial information including records of your purchases with us.
- Professional or employment-related information.
- Internet or other electronic network activity information, such as your cookies or other unique identifiers, log data, or web beacons.
- Geolocation data, in order to enable synchronization of data between our Services.
- Inferences drawn from any of the information identified above.
We may have disclosed or shared any of the information listed above with:
- Our service providers and contractors, including app developers and data providers.
- Cloze users and non-users as related to actions, initiated by our Customers, such as communications.
- Analytics providers and advertising networks.
- Other third parties when necessary to fulfill your requests for Services, to complete a transaction that you initiate, to meet the terms of any agreement that you have with us or our partners; or to manage our business.
- Other third parties for a legal purpose (such as in response to a court order or to defend against a legal claim).
- Other third parties when necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party.
- Other third parties in the event of corporate sale, merger, reorganization, financing due diligence, dissolution, or similar event.
Purposes for Processing Personal Information
We may collect or disclose your Personal Information to the entities listed above for the following purposes:
- To enable you to share Content and communicate with other users;
- To provide our Services or information you request, and to process and complete any transactions;
- To respond to your emails, submissions, questions, comments, requests, and complaints and provide customer service;
- To monitor and analyze usage of the Services and trends, and to personalize and improve our Services and our users’ experiences on our Services, such as content, or features that match their profiles or interests, and to increase the functionality and user friendliness of our Services;
- To send you confirmations, updates, security alerts, and support and administrative messages and otherwise facilitate your use of, and our administration and operation of, our Services;
- To contact you about the Services in which you have expressed interest or that might be of interest to you; and
- For any other purpose for which the information was collected.
Your Rights
If we maintain Personal Information about you that is subject to the CCPA, you may exercise certain rights in connection with this data if you are a California resident.
Please note that, in some situations, Cloze has no direct relationship with the individuals whose Personal Information we process and is Service Provider to its Customers in relation to such information. In these situations, we may forward your request to correct, amend, or delete inaccurate data to the Customers to whom you relate to directly. We provide tools to allow our Customers to export, delete, or update information so that they can comply with these requests.
Right to Know
California residents have the right to request that we disclose certain information about our collection and use of your Personal Information over the past twelve months (“Right to Know”). Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- The categories of Personal Information that we have disclosed for a business or commercial purpose.
- Our business or commercial purposes for collecting, selling, or sharing Personal Information.
- The categories of third parties with whom we share or disclose that Personal Information.
- The specific pieces of Personal Information we collected about you (i.e., a data portability request).
Right to Delete
California residents have the right to request that we delete the Personal Information that we collected from you and retain, subject to certain exceptions (“Right to Delete”). Once we receive and verify your request, we will delete (and direct our service providers/contractors to delete) your Personal Information from our records, unless an exception applies.
Right to Correct
California residents have the right to correct or amend the Personal Information we have on file (“Right to Correct”). You may correct or amend by logging into your account or by contacting us using the information below.
Right to Opt-Out of Sale or Sharing
The CCPA provides California residents with the right to opt-out of the “sale” or “sharing” of their Personal Information (“Right to Opt Out”). Our Services enable third-party tracking mechanisms to collect your information for use in online interest-based advertising, which may be considered to be “sharing” under the CCPA. You may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance by opting out here .
We do not knowingly sell or share the Personal Information of children under the age of 16.
Right to Limit the Use of Your Sensitive Personal Information
The CCPA provides California residents with the right to limit the use of their “sensitive Personal Information” for the purposes outlined in 11 CCR § 7027(m) of the CCPA.
We do not use your sensitive Personal Information for any purposes outside of those permitted in 11 CCR § 7027(m).
Right to Nondiscrimination
The CCPA provides California residents with the right not to receive discriminatory treatment for the exercise of their privacy rights conferred by the CCPA. We will not discriminate against you for exercising any of your CCPA rights.
Exercising Your Rights
If you are a California resident and wish to exercise your Right to Know, Right to Delete, or Right to Correct, you may submit a request to us by email at privacy@cloze.com or by regular mail addressed to:
Cloze, Inc.
Attn: Privacy Officer at Cloze, Inc.
396 Washington St., Suite 138
Wellesley, Massachusetts 02481
When you submit a request, we will confirm your identity by asking you to provide information associated with what we have on file for you, including your name, email address, and other identifying information. We may only be able to comply with your request after we have verified your identity.
Authorized Agent
You may authorize an agent to make a request on your behalf. To designate an agent, please provide a written and signed document by both you and the agent that authorizes the agent to act on your behalf. You may also use a power of attorney. We will still require you to provide information to allow us to reasonably verify that you are the person about whom we collected Personal Information.
Data Retention
We retain Personal Information about you necessary to fulfill the purpose for which that information was collected or as required or permitted by law. We do not retain Personal Information longer than is necessary for us to achieve the purposes for which we collected it. When we destroy your Personal Information, we do so in a way that prevents that information from being restored or reconstructed. By accessing our Services, you authorize us, on your behalf, and in accordance with your account preferences to delete information when not reasonably needed for the Services.
Shine the Light Law
In addition to the CCPA, California's "Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses' practices related to disclosing Personal Information to third parties for the third parties' direct marketing purposes. We do not disclose Personal Information to third parties for this purpose.
Contact for More Information
If you wish to contact us regarding this California Privacy Notice, you may do so by email at privacy@cloze.com or by regular mail addressed to:
Cloze, Inc.
Attn: Privacy Officer at Cloze, Inc.
396 Washington St., Suite 138
Wellesley, Massachusetts 02481