CloseChimp Privacy Policy

We may revise this Policy from time to time to reflect new developments or advances in legislation and the broader data protection landscape. Please check this page to ensure you are comfortable with any changes. If we make material changes, a notification will be rendered by publishing at closechimp.com/privacy-policy.

The Data Controller determines the purposes and means of the processing of Data. The Data Processor processes the Data on behalf of the Controller.

Your Data Controller for Client’s Data (as defined below) is GrowMeOrganic LLC, registered address: 30 N Gould ST STE R, Sheridan, WY 82801, United States (“CloseChimp”, “we”, “us”, “our”). CloseChimp processes Business Data and Shared Data as a processor on behalf of our Client. All processing activities performed on this basis are framed in a lawful and secure way, pursuant to our Data Processing Agreement. If you send us any request relating to such personal data, CloseChimp will promptly redirect the request to our relevant Client.

Where necessary, we may engage third-party service providers and share Data with them to operate, provide, improve, integrate, customize, support, and market the Website and Platform. The types of third parties we share information with include, in particular: cloud storage providers, data analytics providers, measurement partners, marketing partners, payment processing providers, and communication service providers. By providing services to us, those providers will also act as your Data Processors.

CloseChimp shares Business and Shared Data with our Clients for the purpose of providing our Services and Platform and allowing access to authentic, current, and up-to-date business contact information. We may also share Business and Shared Data with our affiliates for any of the purposes set out in this Policy, including current and future parents, subsidiaries, and other companies under common control with CloseChimp.

We may also use and disclose the Data to enforce the Terms, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or as otherwise required by law.

If we transfer personal data originating from the EEA to countries without an adequate level of data protection, we use Standard Contractual Clauses approved by the European Commission on June 4, 2021.

You are prohibited from using the Website and Platform if you are under 18 or under the age of legal majority in your country. We do not knowingly process personal data from persons under 18 years of age. If a minor submits personal information to us and we learn of it, we will attempt to delete such information as soon as possible. If you believe we may hold personal information of a child under the legal age range, please contact us at support@closechimp.com.

“Data” is any information relating to you that alone or in combination with other information allows identification of you as a person. Processing means any action with your Data, including collecting, storing, and transferring. We, directly or with the help of other Data Processors, may process the following categories of personal data:

1. Business Data.CloseChimp may obtain business data of businesspeople and companies (“Business Data”) — name, business email address, business phone number, website, and social media account address (including LinkedIn URL), job title, seniority and role, company name, country/state of business, and other publicly available business data from different sources:
   • CloseChimp’s search technology scanning the web and gathering publicly available information;
   • CloseChimp gets information from reliable partners, other trusted companies, and data providers;
   • Market research surveys and phone interviews conducted by our in-house research team.
2. Shared Data. When using the Services and Platform, the Client may contribute Business Information about itself or other businesspeople and companies. Shared Data may cover name, business email address, phone number, website, social media account addresses (including LinkedIn URL), job title, seniority and role, company name, country/state of business, and other data rendered by the Client to CloseChimp. CloseChimp may also collect Shared Data when you submit information through the Platform, when you use the Services and Platform, when you provide information about your prospects, or when you refer a friend.
3. Client’s Data.
   • Data we receive when you use the Website and Platform: duration of a session; history of interaction with the Website and Platform; information about how you use the Website and Platform and relevant statistics; survey responses; data you provide to our support team, including the language of your requests; email and content of your message; and other information you voluntarily provide by sending us direct messages.
   • Data you provide to CloseChimp via the account: full name; business information (company name and job title); account photo; billing name and address; email address; LinkedIn ID; phone number; any other information you provide; information we receive about you from third parties.
   • Data we collect automatically: how you found us; device and location data (language settings, IP address, time zone, device type and model, device settings, operating system, Internet service provider, mobile carrier, hardware ID, country, region, city); your activity on the Website; cookie identifiers.
   • Data provided by third parties: number of your sessions; session duration; operating systems and models of your devices; geography; first launch date; number of Website opens.

As Business and Shared Data, CloseChimp processes only business-related information. Any contacts that have an email address from services oriented to end-users (Gmail, Yahoo, etc.) are disregarded. CloseChimp does not disclose Clients who provide CloseChimp with Shared Data.

To avoid irrelevant Business and Shared Data, we maintain a list of excluded businesspersons and companies outside of Business and Shared Data (the “Opt-out list”). This list includes (i) contacts to whom we have not been able to send an information notice, and (ii) contacts who are public servants or otherwise public figures, to ensure that their data does not appear in Business and Shared Data.

We process Business and Shared Data for the following purposes:

1. to build our sales intelligence database to enable our Clients to generate and manage sales leads and launch advertising or communicative campaigns in respect of businesses and high-net-worth individuals;
2. to enable our Clients or their customers to serve relevant display ads on social and other services;
3. to enable our Clients or their customers to enrich their existing customer relationship management records and receive timely updates of changes;
4. to run our own marketing campaigns and promote our services.

We process Client’s Data for the following purposes:

1. to make the Website and Platform available for your access and to provide you with the most relevant services within the Platform;
2. to communicate with you regarding your use of the Website and Platform and to update you on services, information, and products;
3. to notify you of any crucial information or changes within the Website and Platform that may affect you;
4. to analyze the number of active users, to support users from different regions, and to provide proper operation of various versions of the Website and to develop and optimize the Website and Platform;
5. to keep the Website and Platform safe and secure, enforce the Terms, and prevent and combat fraud;
6. to generate statistical studies of the market;
7. to comply with our legal obligations.

CloseChimp’s collection of Business and Shared Data falls within both CloseChimp’s and the Client’s (as the Client’s Data Processor/service provider) legitimate interests to organize and make available business contact information, given the limited impact of this data on an individual’s private life, and because this information, unlike personal business contact details, is widely disclosed. CloseChimp has put safeguards in place to protect personal privacy and individual choice, including disclosures of its data processing activities and the use of consent or opt-outs wherever possible.

We process Client’s Data on the following legal bases:

1. Performance of the contract (the Terms) with you: (a) to make the Website available for your access and to provide you with the most relevant services within the Website and Platform; (b) to provide you with technical support; (c) to communicate with you regarding your use of the Website and Platform and to update you on services, information, and products; (d) to notify you of any crucial information or changes that may affect you.
2. Our legitimate interest: (a) to send you marketing communications; (b) to analyze the number of active users, support users from different regions, ensure proper operation of various versions of the Website and Platform, and develop and optimize them; (c) to keep the Website and Platform safe and secure, enforce the Terms, and prevent and combat fraud; (d) to comply with our legal obligations.

When Data is collected for marketing purposes, you will be additionally asked for such processing. You may at any time withdraw your consent free of charge by clicking the “Unsubscribe” button in any email sent or by emailing us at support@closechimp.com.

CloseChimp will retain personal Data for a period consistent with the original purposes for which it was collected. We will retain your information:

1. for as long as we have an ongoing relationship with you and as needed to provide you Services;
2. as necessary to comply with our legal obligations;
3. as necessary to resolve disputes or to protect ourselves from potential future disputes; or
4. as necessary to enforce our agreements.

Retention periods are determined considering the amount, nature, and sensitivity of the Data and the purposes for which it was collected. After the retention period ends, we will delete personal information. Where we are unable to do so, we will ensure that appropriate measures are put in place to prevent any further use of your information.

You are entitled to restrict us from processing your Data by sending us a Data erasure request or a notice of prohibition to process your Data. Please be aware that such action prohibits us from processing your Data and/or causes us to delete it, so you will lose access to the Website and Platform.

Our servers are based in the USA, so your Data will generally be processed and hosted outside the EU. The place of Data collection is the USA.

As a data subject, you have the following rights:

1. Right of access: you may ask what personal information of yours is being processed and request clarification on purpose, period of processing, and third parties with access. To exercise the right, contact us at support@closechimp.com.
2. Right to rectification: you may have inaccurate personal information corrected or completed.
3. Right to erasure: you may request erasure where processing is no longer necessary, or where there are no legal grounds for processing.
4. Right to restriction of processing: for example if you contest the accuracy of the Data being processed.
5. Right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
6. Right to lodge a complaint with a supervisory authority.
7. Right to data portability.

We will provide information on action taken on your request within one month of receipt. That period may be extended by two further months if we are overwhelmed by the number of requests. We will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.

CloseChimp provides notice to all data subjects from the EEA as required by the GDPR (Articles 13 and 14), as appropriate, and honors the rights of data subjects provided in Articles 12–23 of the GDPR, including the right to be forgotten. To exercise any of these rights, email support@closechimp.com.

We take technical and organizational measures to ensure information is processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage. For example, we use vetted contractors that may have access to the Data as specified above, with appropriate Data Processing Agreements in place.

California Civil Code Section 1798.83, also known as the “Shine the Light” law, grants our users who are California residents certain rights. This section applies solely to California consumers and also provides additional details about how we process personal data of California consumers and the rights available to them under the California Consumer Privacy Act (“CCPA”).

We do not sell your Data, so no opt-out choice is necessary. We do not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate in any way your Data to another company for monetary or other valuable consideration.

You have the right to request, twice in a 12-month period, the following information about the Data we have collected about you during the past 12 months:

1. the categories and specific pieces of Data we have collected about you;
2. the categories of sources from which we collected it;
3. the business or commercial purpose for which we collected the Data;
4. the categories of third parties with whom we shared the Data for a business purpose.

CloseChimp has not sold your Data. You have the right to request that we delete the Data we have collected from you. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment. To submit an access or deletion request, contact us at support@closechimp.com. To protect your privacy and maintain security, we take steps to verify your identity before granting you access to your Data or complying with your request.

Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law). If you are a Nevada resident, you may submit an opt-out request by emailing support@closechimp.com. We may take reasonable steps to verify your identity and the authenticity of the request.

We do not store or transfer to third parties any data accessed through Google APIs. We only use Google APIs to:

• authenticate users through Google Auth;
• send planned emails;
• check email responses to collect stats on newsletter performance.

No data at any stage of this process is saved on our end. We only send emails and collect statistical data (like number of sends and replies).

CloseChimp’s use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

If you have any questions regarding this Policy, please contact us at support@closechimp.com. For any questions regarding your personal data, you may also reach our Data Protection team at the same address.

GrowMeOrganic LLC
30 N Gould ST STE R
Sheridan, WY 82801
United States