Privacy Policy

This Privacy Policy explains how Closenine Inc collects, uses, shares and protects personal data.

Closenine Inc ("Closenine", "we", "us" or "our") is a business to business go-to-market, lead generation and appointment setting agency. We help our clients reach potential buyers through outbound prospecting, data enrichment and multichannel outreach. In doing so we handle two broad categories of data: information about our own website visitors and clients, and business contact data that we source, enrich and process on behalf of our clients.

For the personal data we collect about our website visitors and our own clients, Closenine acts as a data controller. For the prospect data we process on behalf of a client as part of a campaign, we generally act as a data processor, and the client is the controller. The sections below explain what that means for you.

The registered data controller is [Full legal entity name], [registered address]. If you have any questions about this policy or how we handle your data, contact us at [privacy@closenine.com].

This policy is aligned with the EU General Data Protection Regulation (GDPR), the UK GDPR and the Data Protection Act 2018. It also describes rights available to residents of California under the CCPA and CPRA.

A few terms used throughout this policy.

• Personal Data. Any information relating to an identified or identifiable natural person, such as a name, email address, phone number or online identifier.
• Business Data. Information about a company or organisation, such as company name, size, industry, website or general contact details, which may or may not identify an individual.
• Controller. The party that determines the purposes and means of processing personal data.
• Processor. The party that processes personal data on behalf of, and under the instructions of, a controller.
• Client Data. Personal and business data that our clients provide to us, or that we generate for a client, in order to deliver our services. The client is the controller of this data.
• Prospect Data. Business contact data, for example names, business email addresses, phone numbers, job titles and company information, that we source, verify or enrich so a client can carry out B2B outreach. We process this data on the client's behalf.

The data we collect depends on how you interact with us.

• Website visitor data. When you visit our website, submit a form or book a call, we may collect your name, business email, company, role and the details you choose to share, along with technical data such as IP address, browser type, device information and pages viewed, gathered through cookies and analytics.
• Client account data. When you become a client, we collect the information needed to set up and manage your account, such as billing and contact details, your target customer profile, offer details, campaign preferences and communications with our team.
• Prospect and lead data. As part of delivering campaigns, we source and enrich B2B contact data on behalf of clients. This typically includes business names, business email addresses, phone numbers, job titles, employer and publicly available professional information, obtained from the client, from reputable data providers and from publicly available professional sources.

We only process personal data where we have a lawful basis to do so under Article 6 of the GDPR.

• Consent. Where you have given clear consent, for example to receive marketing communications or to store non-essential cookies. You can withdraw consent at any time.
• Performance of a contract. Where processing is necessary to provide our services to you, manage your account and fulfil our agreement.
• Legitimate interests. Where processing is necessary for our or our client's legitimate interests, such as business to business outreach to relevant professionals, improving our services and securing our systems, provided those interests are not overridden by your rights. For B2B prospecting we assess that promoting relevant products and services to professionals in a business context is a legitimate interest, and we always offer a clear way to opt out.
• Legal obligation. Where we must process data to comply with a legal or regulatory obligation.

We use personal data for the following purposes.

• Delivering our services, including list building, data enrichment, copywriting and outbound campaign execution.
• Setting up and managing client accounts, billing and support.
• Communicating with you about your account, enquiries, bookings and service updates.
• Running B2B outreach on behalf of clients to relevant business contacts.
• Measuring and improving website and campaign performance through analytics.
• Meeting our legal, tax and regulatory obligations, and protecting our rights.

We do not sell personal data. We share it only where necessary to run our services, and with providers bound by confidentiality and data protection obligations.

• Data enrichment and verification providers that help us build and validate contact lists.
• Email sending, CRM and outreach platforms used to run and track campaigns.
• Analytics and website providers that help us understand site usage.
• Payment and invoicing providers that process client billing.
• Professional advisers, and authorities where we are legally required to disclose.

Each sub-processor is engaged under terms that require it to protect personal data and to process it only for the purposes we specify. A current list of key sub-processors is available on request at [privacy@closenine.com].

We and some of our sub-processors may process personal data outside the European Economic Area (EEA) and the United Kingdom. Where we transfer personal data to a country without an adequacy decision, we put appropriate safeguards in place, such as the European Commission's Standard Contractual Clauses, the UK International Data Transfer Agreement or Addendum, and additional technical and organisational measures where needed.

You can request more information about these safeguards by contacting us at [privacy@closenine.com].

We keep personal data only for as long as necessary for the purposes described in this policy, or as required by law.

• Website enquiry and booking data is kept for as long as needed to respond and for a reasonable period afterwards.
• Client account and billing records are kept for the duration of the engagement and for the period required by tax and accounting law after it ends.
• Prospect data processed for a client is retained in line with that client's instructions and deleted or returned when the campaign or engagement ends, unless we are required to keep it.

When data is no longer needed, we securely delete or anonymise it.

We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse or alteration. These include access controls, encryption in transit, vendor due diligence, staff confidentiality obligations and regular review of our practices.

No system is completely secure, but we work to protect your data and to meet our obligations if an incident occurs, including notifying the relevant authority and affected individuals where required by law.

If you are in the EEA or the UK, you have the following rights over your personal data.

• Access. Request a copy of the personal data we hold about you.
• Rectification. Ask us to correct inaccurate or incomplete data.
• Erasure. Ask us to delete your data in certain circumstances.
• Restriction. Ask us to limit how we use your data.
• Objection. Object to processing based on legitimate interests, including B2B outreach and direct marketing.
• Portability. Receive certain data in a portable format, or ask us to transfer it.
• Withdraw consent. Withdraw consent at any time where we rely on it.
• Complain. Lodge a complaint with your supervisory authority, such as the UK Information Commissioner's Office or your local EU data protection authority.

To exercise any of these rights, contact us at [privacy@closenine.com]. We will respond within the timeframes required by law. Because much prospect data is processed on behalf of our clients as controller, we may need to pass your request to the relevant client, and we will help them respond.

California residents have rights under the CCPA and CPRA, including the right to know what personal information we collect, the right to request deletion, the right to correct, and the right to opt out of the sale or sharing of personal information. We do not sell personal information, and you will not be discriminated against for exercising these rights. To make a request, contact us at [privacy@closenine.com].

Our website uses cookies and similar technologies to make the site work, remember your preferences and understand how it is used. Essential cookies are always on. Non-essential cookies, such as analytics, are used only with your consent where required.

You can control cookies through your browser settings. Where we maintain a separate Cookie Policy, it is available at [link to Cookie Policy] and gives more detail about the specific cookies we use.

Our website and services are intended for businesses and professionals. They are not directed at children, and we do not knowingly collect personal data from anyone under the age of 16. If you believe a child has provided us with personal data, contact us at [privacy@closenine.com] and we will delete it.

We may update this policy from time to time to reflect changes in our practices, technology or the law. When we make material changes, we will update the date at the top of this page and, where appropriate, notify you by email or through our website. We encourage you to review this policy periodically.

If you have questions, concerns or requests about this Privacy Policy or your personal data, contact us at:

[Full legal entity name], [registered address]. Email: [privacy@closenine.com].

You can also reach us through the contact form on our website. If we have not resolved your concern, you have the right to complain to your data protection supervisory authority.