Effective date: Jan 1, 2020
As part of our Services, we provide our Customers access to certain information (including Personal Information) regarding executives at many different companies. This information is generally publicly available, including on company websites and in public filings. We call this type of Personal Information, “Executive Information” and the persons about whom such information relates, “Executives.” If you believe that we may have Executive Information about you and wish to understand how we use and share that information, please see “Executive Information” section. If you are in the EU, please see “Additional Information for European Union Users” section to understand your rights regarding any Executive information we have about you.
When we say “we”, “us”, “our” or “CloseFactor”, we’re referring to Ogmagod, Inc.
“Websites” means CloseFactor’s websites (including without limitation closefactor.com and any successor URLs, mobile or localized versions and related domains and subdomains), and the “Services” means CloseFactor’s products, web and mobile applications and services, in each case in whatever format they may be offered now or in the future. The Websites and Services are collectively referred to herein as the “Offerings.”
“Customer” refers to any customer that has entered into an agreement with CloseFactor to use CloseFactor’s services.
“Visitor” refers to anyone accessing the CloseFactor marketing website at closefactor.com.
“Personal Information” refers to any information which may identify an individual personally, such as first and last name, billing address, email address, job role and employer, telephone number, etc
Information we collect
When accessing the Websites as a Visitor, you may choose to interact with the Websites in a way that results in you providing Personal Information to CloseFactor, such as giving us your name, email address, phone number and company name when contacting us with an enquiry or request to demo CloseFactor.
Customers of the Services
When registering as a Customer to use the Services, we may require or ask you to provide certain personally identifiable information (these are referred to below as your “Personal Contact Information”). The Personal Contact Information that we require you to provide may include, but is not limited to, the following:
- Full name
- Company name
- Job title
If you are a Customer personally purchasing access to the Services, we will require you to provide financial and billing information, such as billing name and address, and credit card number (“Billing Information”). Your Personal Contact Information and your Billing Information, together with any other information we gather through the Services that may be used to identify, contact, or locate you individually, are collectively referred to herein as your “Personal Information.”
We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
Data, Diagnostic & Login Information
You may be able to create, upload, publish, transmit, distribute, display, store or share information, data, text, graphics, video, messages or other materials using our Services (this is collectively referred to below as “Data”). Some of this Data may be stored and maintained on our servers.
We may also collect certain information regarding your Operating System version, hardware, browser version (“Diagnostic Information”), which helps us identify and resolve technical errors that may occur in the course of using the Services.
Additionally, certain login information may be maintained in a cookie stored locally on your personal computing device (i.e. not on a server) in order to streamline the login process (“Login Information”).
Usage and Analytics Information
As a Visitor to the Websites and as a Customer using our Services, we may also collect information through the use of commonly-used information-gathering tools, such as cookies, log files, and Web beacons. Collectively, this information is referred to as “Usage and Analytics Information.”
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
As is true of most websites, we gather certain information automatically to analyze trends in the aggregate and administer the Services. This information may include your Internet Protocol (IP) address (or the proxy server you use to access the World Wide Web), your browser type, the pages and files you viewed, your operating system, and date/time stamps associated with your usage. Due to Internet communications standards, when you visit or use our websites and Services, We automatically receive the URL of the website from which you came and the website to which you go when you leave our website. This information is used to analyze overall trends, to help us improve the Services, to track and aggregate non-personal information, and to provide the Services. For example, we use IP addresses to monitor the regions from which customers and visitors navigate the Sites. We also collect IP addresses from customers when they log into the Services as part of the “IP Restriction” security feature as well as to maintain audit logs.
We use web beacons alone or in conjunction with cookies to compile information about your usage of the Services and interaction with emails from us. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website or Service tied to the web beacon, and a description of a website or Service tied to the web beacon. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to one of our websites. We also use web beacons to operate and improve the Services and our email communications.
We do not use GPS technology to collect any information regarding your precise real-time geo-location while using the Services. However, we may use elements of your Usage and Analytics Information (such as your IP address) to determine your generalized location. This information is referred to as “Generalized Geo-Location Information.”
Use of Information.
We use the information we collect in the following ways:
Personal Contact Information
We use this information to manage your account, to provide the Services, to maintain our customer/visitor lists, to respond to your inquiries or request feedback, for identification and authentication purposes, for service improvement, and to address issues like malicious use of the Services. We may also use Personal Contact Information for limited marketing purposes, namely, to contact you to further discuss your interest in the Services, and to send you information about us. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
We use Billing Information to manage your account, to provide the Services, and to check the financial qualifications of prospective customers and to collect payment for the Services. We may use a third-party service provider to manage credit card processing. If we do so, such a service provider will not be permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing on our behalf.
Data, Diagnostic Information and Login Information
We use this information for the purpose of administering and improving our Services to you. We may also use this information in conjunction with an analytics service to monitor and analyze use of the Services, for the Services’ technical administration, and to increase the Services’ functionality and user-friendliness.
Usage and Analytics Information
We may use your Usage and Analytics Information in conjunction with an analytics service such as Google Analytics to monitor and analyze use of the Services, for the Services’ technical administration, to increase the Services’ functionality and user-friendliness, and to verify users have the authorization needed for the Services to process their requests. We may also use this information to compile reports for enterprise customers analyzing CloseFactor usage, but limited only to usage by their employees and other users on the enterprise customer’s enterprise account.
Please note that if you are registering for or using the Services as an administrator on behalf of an organization, you may be able to view the activity and/or content associated with your Associated users use of the Services, including, but not limited to, their Personally Identifiable Information.
When you make a purchase on the Offerings, any credit card information you provide as part of your Payment Information is collected and processed directly by our payment processor. We never receive or store your full credit card information.
Disclosure of your Information
We will never sell your data to third parties. However, in the course of business, we may hire third-party individuals and organizations to help us improve the Offerings. For example:
We may share your personal information with third parties including our web host provider, other SaaS providers, such as an email hosting service, payment processors or outside contractors we hire to perform maintenance or assist us in securing our website.
We may share your personal information when we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce a Customer Agreement, including investigation of potential violations thereof, or (c) protect against imminent harm to our rights, property or safety, or that of our users or the public as required or permitted by law;
We may share your personal information with third parties (including our service providers and government entities) to detect, prevent, or otherwise address fraud or security or technical issues;
We may share your personal information with a third party if we have your consent to do so.
Your Controls and Choices
If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included on such communications or on the Offerings. Please note, however, that you may be unable to opt-out of certain service-related communications.
You can remove or block certain cookies using the settings in your browser but the Offerings may cease to function properly if you do so.
Choosing not to share your personal information
Where we need to collect your personal information by law, or to be able to provide the Services to you and you do not provide that information when requested (or you later ask to delete it), we may not be able to provide you with the Services and may need to close your account. We will tell you what information you must provide to receive the Services by designating it as required in the Service or through other appropriate means.
Do Not Track Signal
Right to Access, Edit, and Remove Your Information
You have a right to access personal information we hold about you. Whenever you use our Websites or Services, we strive to make sure that the Personal Information is correct. If that information is wrong, we give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. When updating your Personal Information, we may ask you to verify your identity before making any changes. We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems). Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort. Because we protect information from accidental or malicious destruction, even after information is deleted from the CloseFactor Services, it may not be immediately deleted from CloseFactor’s servers.
To request removal of your Personal Information from our Websites, Services or social media profiles, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.
Through the Services, we provide our Customers and users access to Personal Information about various Executives. We refer to this as Executive Information.
We obtain the Executive Information exclusively from publicly available sources, such as websites for the companies at which an Executive works or public company filings made with governmental regulators. We provide this Executive Information to our Customers and users to give them business insights regarding our Customers clients and competitors.
In particular, we store and provide our Customers access to the following categories of Executive Information:
- First and last name
- Job title
- Biographical information
We take the following steps to ensure the integrity of the Executive Information:
Business Information Only – CloseFactor only collects business-related information about Executives.
Opt Out – Anyone added to our databases may request to be removed at any time, via the contact information provided below. While CloseFactor will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such requests, if allowed or required by applicable laws.
In many cases, we have no direct relationship with the Executives who are the subject of the Executive Information. If you are contacted by one of our Customers who uses our Services and would no longer like to be contacted by them, please contact the Customer that you interact with directly. We may transfer Executive Information to companies that help us provide our Services. Transfers to subsequent third parties are covered by the service agreements with our Customers.
If you would like to know if we hold any Executive Information about you, or you wish for us to correct, amend, or delete such information, please follow the instructions under “Right to Access, Edit, and Remove Your Information”.
The security of your personal information is important to us. We maintain a variety of appropriate technical and organizational safeguards to protect your personal information. No method of transmission over the Internet, method of electronic storage or other security methods are one hundred percent secure. Therefore, while we strive to use reasonable efforts to protect your personal information, we cannot guarantee its absolute security.
You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your password, and safeguard your user name, password and personal credentials when you are using the Services, so that other people will not have access to your Personal Information. Furthermore, you are responsible for maintaining the security of any personal computing device on which you utilize the Services.
No Children Under Age 13
Your California Privacy Rights and Disclosures
California Shine the Light Law
If you are a California resident and we disclose your personally identifiable information to third parties for such third parties’ direct marketing purposes, California’s Shine the Light Law (CA Civil Code Section 1798.83) allows you to request certain information from us about such disclosures. To make a request under the Shine the Light Law, please contact us at email@example.com. Please note that under California law, businesses are not required to respond to such requests more than once during any calendar year.
At any time, you can delete or remove your information using the same deletion or removal procedures described in the “Right to Access, Edit, and Remove Your Information“ section, or otherwise through the Offerings. If you have questions about how to remove your posts or if you would like additional assistance with deletion you can contact our support team at firstname.lastname@example.org. Although we offer deletion capability for our Offerings, you should be aware that the removal of posts may not ensure complete or comprehensive removal of that content or information posted through the Offerings.
CloseFactor is headquartered in the United States and has affiliates and service providers in other countries, and your personal information may be transferred for storage and processing to the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction. By providing your Personal Information through the Services, you consent to such transfer, storage, and processing.
European Union users should read the ‘Additional Information for European Union Users’ below.
What If I Have Questions or Concerns?
Additional Information for European Union Users
Controller and Data Protection Officer
CloseFactor is the controller of your personal information for purposes of European data protection legislation. You can contact our Data Protection Officer at email@example.com.
Lawful bases for processing
We only use your personal information as permitted by law. A summary of lawful bases of our processing of your personal information are outlined in the table below.
|Processing purpose||Core types of processing||Lawful basis|
|To provide the Service||Provide, maintain and improve the Offerings and to operate certain features and functionality. Process payments you make through the Services. Communicate with you to deliver certain services or provide support,||Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Services.|
|To improve the Services To communicate with you||To analyze trends, administer or optimize the Offerings, monitor usage or traffic patterns (including to track users’ movements around the Offerings) and gather demographic information about our user base as a whole. If you request information from us, register for the Services or participate in our surveys, promotions or events, we may send you CloseFactor-related marketing communications if permitted by law but will provide you with the ability to opt out.||These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).|
|To comply with law||We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.||Processing is necessary to comply with our legal obligations.|
|With your consent||Post your personal testimonials or case studies along with those of other satisfied customers on our Site in addition to other endorsements.||Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us at firstname.lastname@example.org|
Use for new purposes
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Information) for six years after they cease being customers for tax purposes.
In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
Opt-out. Stop sending you direct marketing communications. You may continue to receive Service-related and other non-marketing emails.
Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information.
Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You can submit these requests by email to email@example.com. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as described in Section 9 below or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
Cross-Border Data Transfer
Whenever we transfer your personal information out of the EEA to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on one of the safeguards recognized by the European Commission as providing adequate protection for personal information, where required by EU data protection legislation.