This Privacy Policy applies between you, the User of Closr App and/or Website, and CLOSR APP LTD, and outlines our use of any Data collected by us or provided by you to use our App and/or Website.  

CLOSR APP LTD is registered with the Information Commissioner’s Office (ICO) under registration number 00019626191. We comply with UK GDPR and data protection laws to ensure your personal data is handled securely.

Definitions and Interpretations

In this Privacy Policy, the following definitions are used:

Data: Collectively all information that you submit to closr via the Website and/or App. This definition incorporates, where applicable, the definitions provided in Data Protection Laws. 

Data Protection Laws Any applicable law relating to the processing of personal Data, including but not limited to the GDPR, and any national implementing and supplementary laws, regulations, and secondary legislation. 

GDPR: The UK General Data Protection Regulation. 

CLOSR APP LTD, ‘we’ or ‘us: ’Company registered in England and Wales under company number 16136329, with its registered office at 18 Burrell Avenue, Lancing, West Sussex, BN15 8QB.

User or you: Any third party that accesses the Website and/or App and is not either(i) employed by closr and acting in the course of their employment, or(ii) engaged as a consultant or otherwise providing services to closr and accessing the Website and/or App in connection with the provision of such services. 

App and Website: The Website/App you are currently using. The Website registered URL is closr.deals and any subdomains of this site. The App refers to the mobile application provided by CLOSR APP LTD, which allows users to access and utilise the services offered by closr on their mobile devices.

2. In this Privacy Policy, unless the context requires a different interpretation: 

   1. The singular includes the plural and visa versa;

   2. References to sub-clauses, clauses, schedules or appendices of  this Privacy Policy; 

   3. A reference to a person includes firms, companies, government entities, trusts and partnerships; 

   4. “Including” is understood to mean “including without limitation”;

   5. Reference to any statutory provision includes any modification or amendment to it; 

   6. The headings and sub-headings do not form part of this Privacy Policy. 
      
      

Scope of this Privacy Policy

1. This Privacy Policy applies only to the actions of closr and Users with respect to this Website/App. It does not extend to any website that can be accessed from this Website/App including, but not limited to, any links we may provide to social media websites and individual business pages. 

2. For the purposes of the applicable Data Protection Laws, CLOSR APP LTD is the “data controller”. This means that we determine the purposes for which, and the manner in which, your Data is processed.

Who are we?

closr is an app designed to support and promote local independent businesses by offering them free exposure on the platform. The app is free for end users to download, with optional subscriptions available at £2/month or £1/month for Blue Light workers. 5% of app profits are donated to charity on a monthly basis.

Type of Data Collected and the Purpose of Processing 

Personal Data/Contact Information: Name, Email address, Phone number, Postal address, Process memberships, Respond to queries, Send service updates, Verify identity, Verify eligibility, Display relevant offers. 

Payment Information: Payment details, Billing address, Process payments, Manage subscriptions, Preference Information, Order history, App usage

Marketing preferences: Send updates, Provide personalised recommendations, Improve services, Unique Identifiers, Membership codes, Login details, Verify identity, Ensure secure access to services Location, Information Use of current location at the time of using the App, Recommend local business, Promote locally available offers 

Company Information: Provision of services on behalf of an employer, third-party benefit provider or reward provider

Communication Information: Comments Posts Feedback, Collect feedback to improve services, Respond to queries 

How is your Data collected?

We collect your Data in the following ways:

(i) data is given to us by you; and 

(ii) data is collected automatically. 

Data That is Given to Us by You

closr will collect your Data when you:

1. Register an account or sign up for a subscription 

2. Engage with the app, such as searching for local businesses

3. Provide feedback

4. Contact customer support

5. Update your profile settings

6. Enabling your location for App use.

Data Collected Automatically

To the extent that you access the App/Website, we will collect your Data automatically, for example:

(i) We automatically collect information about your visit to the Website or use of the App. This information helps us improve our content and navigation and includes your IP address, the date, time, and frequency with which you access the App or Website, and how you use and interact with our content.

How is Your Data Handled? 

The lawful bases for processing your information are:

1. Consent – When you agree to our terms or opt into specific features.

2. Contractual Obligations – To provide services you have subscribed to.

3. Legitimate Interests – To improve and personalise the App/Website experience.

Who Do We Share Your Data With?

We may share your data with third parties who help provide the app's services, such as:

1. Payment Processors for managing subscription payments.

2. Technical Support Providers for maintaining App/Website functionality and security.

3. Analytics Platforms to monitor App/Website performance and user experience improvements.

We will never sell your personal data to third parties or use it for marketing without your consent.

Keeping Your Data Secure

We take security seriously and use measures such as:

1. SSL encryption for payment and data transmission.

2. Secure servers to store personal data.

3. Limited access to personal data based on job role requirements.

While we strive to protect your information, please note that data transmitted over the Internet cannot be guaranteed to be 100% secure. If you would like more detailed information from Get Safe Online on how to protect your information and devices against fraud, identity theft, viruses, and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by the HM Government and leading businesses. 

Data Retention Period

We retain personal data for as long as necessary for the purposes outlined:

1. Type of Record, Membership Records - Retention Period 5 years after cancellation or last user interaction

2. Provision of personal documents to verify your Blue Light Discount - The Data provided will be destroyed within 1 week of processing your application.

Your Rights

Under the UK General Data Protection Regulation (GDPR), you have rights to:

1. Right to access - the right to request:

(i) copies of the information we hold about you at any time, or

(ii) that we modify, update or delete such information. 

If we provide you with access to the Data we hold, we will not charge you for this, unless your request is “manifestly unfounded or excessive”. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why. 

2. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete. 

3. Right to erase - the right to request that we delete or remove your Data from our systems.

4. Right to restrict our use of your Data - the right to “block” us from using your Data or limit the way in which we can use it. 

5. Right to data portability - the right to request that we move, copy or transfer your Data. 

6. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests. 

To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us at support@closr.deals

If you are not satisfied with the way we handle a complaint you make in relation to your Data, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/. 

It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

2. Right to request account deletion - delete your closr account:

You may delete your closr account at any time by heading to the 'my account' section within the app, click 'my profile, and then at the bottom select 'delete my account'. Or you may do this by raising a request to support@closr.deals

Do we profile or make automated decisions with your information?

Yes, we use automated tools to:

1. Recommend nearby venues based on location.

2. Personalise offers and experiences based on app usage patterns.

3. Decisions are not made without human oversight, ensuring fairness and transparency.

Cookies, Tracking, and Marketing

We use cookies and tracking technologies to:

1. Monitor app activity and improve functionality.

2. Provide location-based recommendations.

If you opt into marketing communications, we may send updates on app features, local businesses, and exclusive offers. You can unsubscribe anytime via the app or by following the link in emails or SMS.

International Data Transfers

If we use third-party services located outside the UK, we ensure compliance through safeguards such as:

1. Data Protection Agreements.

2. Standard Contractual Clauses.

Changes to This Privacy Policy 

We reserve the right to change this Privacy Policy as we deem necessary from time to time or as required by law. Changes will be posted in the app and on our website. We will notify you of significant updates through email or app notifications.

Last updated: 22/01/2025