Privacy Policy

Two kinds of data, two roles. For information about our own account holders (our customers), Closr acts as a data controller. For the contact lists, call recordings, and campaign data our customers upload and run through the Service, Closr acts as a data processor on the customer’s behalf — the customer decides who is called and why, and is responsible for the lawful basis of those calls. See sections 4 and 11.

01Who we are

Closr provides software that places outbound telephone calls on behalf of its customers using an AI voice agent, delivers a customer-defined sales script, handles conversation, and can transfer a live prospect to a human. Closr is operated by ClosrCall, and references to “we” and “us” mean that entity. If you have questions about this policy or how your information is handled, contact us using the details in section 17.

02Information we collect

Account & profile information

When you register or use an account we collect your name, email address, organization name, login credentials (stored only as salted hashes), and any two-factor authentication settings you enable.

Billing & payment information

We record account balances, credit top-ups, usage charges, and transaction history. Payments are processed by a third-party cryptocurrency payment processor; we receive confirmation of a payment and its amount, but we do not collect or store your wallet keys or card numbers.

Campaign & contact data (uploaded by customers)

Customers upload contact lists that may include names, telephone numbers, email addresses, and custom fields used to personalize calls. This data is provided and controlled by the customer.

Call data

When the Service places a call we process the destination number, call metadata (time, duration, status such as answered / voicemail / failed, outcome, and disposition), audio recordings where enabled, and machine-generated transcripts and analysis of those recordings.

Support communications

If you contact support through our chat or by email, we keep the messages, attachments, and related contact details so we can respond and improve the Service.

Technical & usage information

Like most online services, we automatically collect log data such as IP address, browser and device type, pages viewed, and actions taken, together with security telemetry used to detect abuse and fraud.

03Call recordings & transcripts

Where call recording is enabled by the customer, the Service may record the full conversation and generate a transcript and automated quality/outcome analysis. Recordings and transcripts are used to deliver the Service, to let the customer review calls, to detect fraud and abuse, and — only where the customer enables it — to help improve the customer’s own scripts and agent performance.

Call recording is regulated. Laws in many places require that one or all parties be informed of, or consent to, recording. The customer running a campaign is responsible for providing any required recording disclosure to the called party. See our Acceptable Use Policy.

04Controller vs. processor

Closr is the controller of account, billing, support, and technical data described above — we decide how that data is used to run our business and the Service.

Closr is a processor of the contact lists, campaign definitions, call recordings, and transcripts that a customer uploads or generates. The customer is the controller of that data: they choose who is called, on what basis, and with what script, and they instruct us to process it. We process it only to provide the Service, to comply with law, and to protect the platform. Customers are responsible for having a lawful basis to contact the people on their lists and for honouring opt-out and do-not-call obligations.

05How we use information

• To provide, operate, and maintain the Service, including placing calls, routing transfers, and billing usage.
• To authenticate users and secure accounts.
• To process payments and maintain accurate balances and ledgers.
• To provide customer support.
• To detect, prevent, and investigate fraud, abuse, toll fraud, and security incidents.
• To generate analytics and reporting for the customer about their own campaigns.
• To comply with legal obligations and enforce our Terms.
• To communicate with you about your account, service changes, and security notices.

We do not sell personal information, and we do not use the content of customer call recordings or contact lists to advertise to third parties.

06Legal bases (where applicable)

Where data-protection laws such as the GDPR apply, we rely on the following bases for our own controller processing: performance of a contract (to provide the Service you signed up for), legitimate interests (to secure, improve, and protect the platform and prevent fraud), legal obligation (to meet regulatory and record-keeping duties), and consent (where we ask for it, such as certain cookies). For campaign data processed on a customer’s behalf, the customer is responsible for establishing the lawful basis for contacting the individuals concerned.

07How we share information

We share personal information only as needed to run the Service and as described here:

• Telephony carriers & SIP providers — to originate and connect calls, we pass the destination number and caller-ID to the carrier the customer uses.
• Payment processor — to take payment and confirm top-ups.
• Infrastructure & security providers — hosting, content delivery, and network protection used to run and defend the platform.
• Support tooling — the system that powers our support inbox.
• Legal & safety — where required by law, court order, or to protect the rights, property, or safety of Closr, our customers, or the public.
• Business transfers — in connection with a merger, acquisition, or sale of assets, subject to this policy.

08Service providers (sub-processors)

We use a limited set of vetted providers to deliver the Service, including cloud hosting and network protection, telephony and SIP carriers selected or supplied by the customer, a cryptocurrency payment processor, and a customer-support platform. Each is bound to process data only as needed to provide their service to us. We keep an up-to-date list available to customers on request.

09Data retention

We keep personal information for as long as needed to provide the Service and to meet legal, accounting, and security obligations. In particular, call recordings are retained by default for a limited period (currently 90 days) and then deleted or archived according to the customer’s settings, and account and billing records are kept for the period required by applicable law. Customers can request deletion of their campaign data as described in section 12.

10Security

We use technical and organizational measures to protect information, including encryption of sensitive credentials and recordings, hashed passwords, optional two-factor authentication, least-privilege access, network firewalls, automated abuse and toll-fraud blocking, and intrusion monitoring. No system is perfectly secure, but we work to protect your data and to respond promptly to incidents.

11International transfers

We and our providers may process information in countries other than the one you live in. Where we transfer personal data across borders, we take steps to ensure it remains protected in line with applicable law, including using appropriate safeguards such as standard contractual clauses where required.

12Your rights

Depending on where you live, you may have rights to access, correct, delete, or receive a copy of your personal information, to object to or restrict certain processing, and to withdraw consent. To exercise these rights over data for which Closr is the controller, contact us using section 17. Where the data relates to a campaign run by one of our customers (for example, if you were called by a Closr customer), we are the processor — please contact that customer directly, or contact us and we will route your request to them.

13Rights of called parties

If you received a call made through Closr and wish to opt out, be added to a do-not-call list, or ask who called you, that request is handled by the customer who ran the campaign, since they control the contact list and the basis for the call. You may ask to opt out directly on the call, or contact us and we will forward your request to the relevant customer and support suppression of your number where we can.

14Cookies

Our website and application use cookies and similar technologies that are necessary to sign you in, keep your session secure, and remember basic preferences. We keep non-essential tracking to a minimum. You can control cookies through your browser settings; blocking essential cookies may stop parts of the Service from working.

15Children

The Service is a business tool and is not directed to children. We do not knowingly collect personal information from anyone under 16. If you believe a child has provided us information, contact us and we will delete it.

16Changes to this policy

We may update this policy from time to time. When we make material changes we will update the “Last updated” date above and, where appropriate, notify account holders. Your continued use of the Service after an update means you accept the revised policy.

17Contact us

Questions, requests, or complaints about this policy or your information can be sent to privacy@closrcall.com, or through the support option in your account. Postal and legal-entity details: ClosrCall.

See also our Terms of Service and Acceptable Use Policy.