I.  Collection and Use of Personal Data
Clozd is a consulting and software services provider that carries out data collection and analysis on behalf of our contracted clients to help them understand why they win and lose sales opportunities. In carrying out these services, we may collect or obtain personal data about you either directly from you (e.g., voluntarily filling out a website form), in the course of our relationship with you (e.g., voluntarily participating in a win-loss interview), or from our clients. The personal data we capture and store is limited to basic details which may include your name, work email address, company name, and browser data (e.g., browser type, IP address, operating system, etc.) as well as any views or opinions you voluntarily share with us via telephone interview and/or web survey. Whenever personal data is acquired directly from you (e.g., voluntarily filling out a website form) Clozd will process the data for its own business purposes such as monitoring website activity, responding to requests for information, and/or typical sales and marketing activities to promote our products and services to you. Whenever personal data is acquired indirectly (e.g., transferred from a client in order to facilitate research and analysis) Clozd will only process your data for the specific research purposes contracted for by the client.

Thus, all personal data is collected on the basis of either prior consent or the legitimate business interests of our contracted clients in seeking your consent to participate in business-related research activities. There is no material likelihood of any adverse impact on your interest, fundamental rights, or freedoms as a result of the collection and processing of your personal data.

Clozd does not collect or process any sensitive personal data, as defined by the Global Data Protection Regulation (GDPR) and prohibits its clients from sharing sensitive personal information.

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II. Protection & Processing of Personal Data
Clozd does not sell or share your personal data to third parties.

All data is stored and processed with commercially reasonable security measures consistent with industry standards in place to protect against the loss, misuse, and interception of information by third parties. Clozd holds its physical hosting facilities to these same standards.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement commercially reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk, and you are responsible for ensuring that any personal data that you send to us is sent securely.

Clozd also imposes strict internal controls over employees with access to systems used in the storage and processing of personal data. Such access is granted on a “need-to-know” basis only. All employees are required to sign and abide by Clozd’s internal data privacy and confidentiality agreement.

Please note that we may disclose your personal data to: legal and regulatory authorities, our contracted clients (e.g., solely with your consent to the client for whom we are conducting the research), any party as necessary in connection with legal proceedings, any party as necessary for investigating, detecting or preventing criminal offenses, any purchaser of our business, and any third party providers of advertising, plugins or content used on our web site.

If we engage a third-party processor to process your personal data for any legitimate business purpose, the processor will be one of the entities identified at www.clozd.com/privacy/subprocessors. Each of these processors have sophisticated data protection processes in place to protect the confidentiality and security of the personal data, and to comply with the requirements under applicable law.

If you are located outside of the United States, you should be aware that the personal data you provide to us is being transmitted to us and processed in the United States, and will be protected subject to this Privacy Policy and United States laws. Where we transfer your personal data from the EEA to recipients located outside the EEA who are not in adequate jurisdictions, we do so on the basis of standard contractual clauses.

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III. Data Retention & Erasure
We take every reasonable step to ensure that your personal data is only retained for as long as it is needed for the performance of our contractual obligations, to make its services available to you, for us to comply with our statutory obligations resulting from applicable laws, and to fulfill the purposes outlined in this Privacy Policy, at which time we will either (i) permanently delete or destroy the relevant personal data, or (ii) anonymize the relevant personal data.

You have many rights relating to your personal data that we store and process, including:

• The right not to provide personal data (e.g., we will always provide a conspicuous opt-out capability with research requests);

• The right of access to your personal data;

• The right to request rectification of inaccuracies;

• The right to request the erasure, or restriction of processing, of your personal data;

• The right to object to the processing of your personal data;

• The right to have your personal data transferred to another controller;

• The right to withdraw consent; and,

• The right to lodge complaints with data protection authorities.

We may require proof of your identity before we can give effect to these rights. To make any request, relating to these rights, please direct your specific request to security@clozd.com. Some requests may require the confirmation of additional facts (e.g., a determination of whether any processing is non-compliant with applicable law) and we will investigate your request reasonably promptly, before deciding what action to take.

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IV. Cookies and Similar Technologies
When you visit our web site we may place cookies onto your device, or read cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We may process your personal data through cookies and similar technologies. For further information, visit allaboutcookies.org.

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V. Opt Out
We may process your personal data in order to contact you via email, telephone, direct mail, or other communication formats to invite you to participate in research on behalf of our clients. In so doing, we will provide a functional and conspicuous opt out mechanism. You may unsubscribe (e.g., opt out) by simply clicking on the unsubscribe link included in each email we send.

After you unsubscribe, we will no longer contact you. In the event that another client legitimately provides us your personal data and requests we contact you, we will do so. To permanently opt out of all communication and invitations from Clozd, across all current and future Clozd clients, you may submit your request to security@clozd.com at any time. You will receive confirmation, reasonably promptly, that you have been successfully opted out of all future communications from us.

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VI. Global Data Protection Regulation (GDPR)
As has been outlined herein, Clozd complies with all GDPR requirements and values these regulations as important frameworks for establishing data privacy. As such, Clozd applies the same privacy practices to all personal data captured on behalf of all users globally. Learn more by visiting GDPR Compliance page

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VI. Contact Information

For additional requests or information regarding this privacy policy, please contact us at security@clozd.com.

Daryl Pinkal

Chief Technology Officer

Clozd, Inc.

1881 W Traverse Mountain Pkwy

Suite E #550

Lehi, UT 84043

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