Privacy Policy

Effective Upon: January 1, 2020
Last Updated: June 3, 2020

We at The Close and Marc Waring Ventures, Inc. (collectively, “us”, “our”, or “we”) are strongly committed to transparency, and we want you (“you” or “your”) to understand how we collect, use, share and protect your personal information, as well as how you can manage the personal information we collect. This Privacy Notice applies to your interactions with us and your use of our website (www.fitsmallbusiness.com and www.theclose.com), products, services, and features, either online or offline (collectively, the “Services”).

By using our Services, you are accepting the terms of this Privacy Notice. If you do not agree to the terms of this Privacy Notice, please do not use our Services. If you do not understand, or if you have questions about, this Privacy Notice, please contact us before using, or continuing to use, our Services.

We reserve the right to change our Privacy Notice from time to time by posting the changes here. We will also provide you with notice by prominently posting on our website, via email or both, if we make any changes to this Privacy Notice that materially affect your rights. Your use of our Services after we have made changes to our Privacy Notice will mean that you have accepted those changes.

1. TYPES OF INFORMATION WE COLLECT
2. HOW WE COLLECT INFORMATION
3. HOW WE USE INFORMATION
4. HOW WE SHARE INFORMATION
5. HOW WE PROTECT INFORMATION
6. CHILDREN’S PRIVACY
7. YOUR CALIFORNIA PRIVACY RIGHTS
8. YOUR CHOICES
9. THIRD PARTY WEBSITE AND APPS
10. CONTACT US

1. TYPES OF INFORMATION WE COLLECT

We collect two basic types of information from you when you provide it to us or when you use or interact with our Services: personal information and non-personal information.

Personal information includes all information that relates to you personally and either identifies or may be used to identify you personally (collectively, “personal information”). We may collect the following types of personal information from you depending upon the device you are using and how you interact with us or use or interact with our Services, such as your:

• Contact Information. Name, mailing address, email address, phone number, and other contact information.
• Demographic Information. Date of birth and gender.
• Device Information. IP address, browser type and version, browser plug-in types and versions, operating system and platform, device type and device identifiers.
• Financial Information. Credit card number, banking information, transactional and financial information, and billing and shipping address.

Non-personal information includes information that does not personally identify you or information that has been anonymized (collectively, “non-personal information”). When we combine non-personal information with personal information, we treat the combined information as personal information.

You can always refuse to provide your information, except that it may prevent you from engaging in our Services or receiving responses to your inquiries or other information of interest.

2. HOW WE COLLECT INFORMATION

We need to collect personal information from you in order to provide you with our Services, as well as to improve your experience. You may provide us with personal information in several ways, including, for example when you:

• Visit our website or use our Services;
• Register for any website account;
• Correspond with us in any way, including through surveys and promotions;
• Sign up to receive our newsletter or promotional information;
• Ask for customer service, support or other assistance; or
• Interact with us in any other way, online or offline, including through our Services.

Cookies

Like many websites and apps, we use “cookies”, which are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences and actions. We may also use cookies to monitor traffic, improve our website and make it easier and/or relevant for your use. Like many websites and apps, we use cookies, web beacons and similar technologies to record your preferences and track the use of our Services. We use these technologies to:

• Remind us who you are when you access our Services which helps us to provide you with services tailored to your specific needs and interest;
• Determine the browser you are using so our Services work properly;
• Assist us with sending you notifications;
• Generate analytics regarding your use of our Services; and
• Estimate our audience size by determining whether your visit is your first.

You can set your browser or device to refuse all cookies or to indicate when a cookie is being sent. If you delete your cookies or if you set your browser or device to decline these technologies, some Services may not function properly. Our Services do not currently change the way they operate upon detection of a Do Not Track or similar signal.

Online Analytics

We also use various types of online analytics, including Google Analytics, a web analytics service provided by Google, Inc. (“Google”), on our Services. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the Services, compile reports on the related activities, and provide other services related to website activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google click here.

Offline Interactions and Other Sources

We also may collect personal information from other sources (such as our partners or third party service providers) or from our offline interactions with you to, among other things, enable us to verify or update information contained in our records and to better customize the Services for you.

Social Media Integration

Our Services may, from time to time, contain links to and from social media platforms. You may choose to connect to us through a social media platform, such as Facebook, LinkedIn or Twitter, and when you do, we may collect additional information from you, such as your screen names, profile picture, contact information, contact list, and the profile pictures of your contacts, through the social media platform. Please be advised that social media platforms may also collect information from you. When you click on a social plug-in, such as Facebook’s “Like” button or Twitter’s “Tweet” button, that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. We do not have control over the collection, use and sharing practices of social media platforms and encourage you to review their usage and disclosure policies and practices, including the data security practices, before using the social media platforms.

Surveys and Promotions

From time to time, we may provide you with the opportunity to participate in surveys or other promotions, some of which might be sponsored or conducted by a third party. Participation in these surveys and promotions is completely voluntary. If you choose to participate, we will request certain personal information from you. If there is a third party sponsor involved in the survey or promotion, please make sure to review the sponsor’s privacy policy. Please be aware that any sweepstakes, raffles, surveys or similar promotions offered by us may be governed by specific rules and terms and conditions that are separate from and in addition to this Privacy Notice. By participating in any such sweepstakes, raffles, surveys or similar promotion, you will become subject to those rules, including but not limited to receiving emails containing promotion communications.

3. HOW WE USE INFORMATION

We may use personal information to:

• provide you with our Services;
• facilitate your interactions and transactions with us;
• respond to your requests, communications, suggestions, comments, inquiries, and requests (including your feedback about our Services);
• administer our relationship with you, including creating and managing your account;
• maintain and improve our Services;
• measure performance;
• develop new products, features, and services;
• better understand the preferences of our customers;
• provide personalized Services, including content and ads;
• provide you with, and improve, relevant marketing offers or information from us or relevant third parties;
• facilitate your participation in our surveys and promotions;
• respond to legally binding requests from law enforcement, regulatory authorities, or other third parties;
• defend, protect or enforce our rights or applicable terms of service;
• to prevent fraud or the recurrence of fraud;
• assist in the event of an emergency; and
• comply with applicable law.

We may also combine your personal information collected through various sources, including information collected through our Services, and develop a customer profile that will be used for the purposes above.

We may retain personal information for as long as we have a business need to do so, including, for backup, archival, accounting, and/or audit purposes.

We may use personal information to create non-personal information. We may use non-personal information for any legitimate business purpose. We may retain non-personal information for as long as we have a business need to do so.

4. HOW WE SHARE INFORMATION

Except as disclosed in this Privacy Notice, we do not share personal information with any companies other than our partners and affiliates and their directors, officers, employees, agents, consultants, advisors or other representatives. In no event will we sell or rent personal information.

We may share personal information with our third party service providers, vendors, and business partners to help us:

• with the uses described in the How We Use Information section above;
• with our marketing and promotional projects, such as sending you information about products and services you may like and other promotions; and
• comply with your directions or any additional consent you have provided us.

We may share personal information with law enforcement and regulatory authorities or other third parties as required or permitted by law for the purpose of:

• responding to a subpoena, court order or other legal processes;
• defending, protecting or enforcing our rights;
• assisting in the event of an emergency; and
• complying with applicable law.

We may also transfer or assign personal information to third parties as a result of, or in connection with, a sale, merger, consolidation, change in control, transfer of assets, bankruptcy, reorganization, or liquidation. If we are involved in defending a legal claim, we may disclose information about you that is relevant to the claim to third parties as a result of, or in connection with, the associated legal proceedings.

We share non-personal information with third parties as reasonably necessary to meet our business needs.

5. HOW WE PROTECT INFORMATION

We are concerned about ensuring the security of your personal information. We exercise great care in providing secure transmission of your information from your equipment to our servers. We store personal information that we have collected in secure operating environments. Our security procedures mean that we may occasionally request proof of identity before we disclose your personal information to you. We try our best to safeguard personal information once we receive it, but please understand that no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. If you suspect an unauthorized use or security breach of your information, please contact us as soon as possible at privacy@theclose.com.

6. CHILDREN’S PRIVACY

Our Services are not for children under the age of 13. We do not knowingly collect personal information from children under 13 years of age. Individuals under the age of 13 should only use our Services with the permission and under the supervision of a parent or guardian. Individuals under the age of 13 should not attempt to provide us with any personal information. If you think we have received personal information from children under the age of 13, please contact us immediately at privacy@theclose.com.

7. YOUR CALIFORNIA PRIVACY RIGHTS

We do not share personal information with third parties for their own direct marketing purposes without your consent. California residents under 18 years old, in certain circumstances, may request and obtain removal of personal information or content about you and posted on our Services. Please be mindful that this would not ensure complete removal of the content posted on our Services by you. To make any request pursuant to California privacy law, please contact us.

8. YOUR CHOICES

We offer you certain choices in connection with our Services.

Access to your personal information

You have the right to request access to the personal information that we collect, use, and disclose about you. You also have the right to not receive discriminatory treatment for exercising your access right. To submit a request, please contact us.

Deleting your personal information

You have the right to request that we delete your personal information, subject to some exceptions. Once we have received and confirmed your request, we will delete (and direct our partners and service providers to delete) your personal information, unless an exception applies. You have the right to not receive discriminatory treatment for exercising your deletion right. To submit a request or designate an authorized agent to make a request, please contact us.

Updating your personal information

The accuracy of the information we have about you is very important. You may update your personal information by emailing hi@theclose.com or directly accessing your account and profile information.

Email Communications

You may have the opportunity to receive certain communications from us related to our Services. If you provide us with your e-mail address in order to receive communications, you can opt-out of marketing emails at any time by following the instructions at the bottom of our emails and adjusting your email preferences. Please note that certain emails may be necessary for the operation of our Services. You will continue to receive these emails, if appropriate, even if you unsubscribe from our optional communications.

Cookies/ Beacons

If you wish to minimize information collected by cookie or beacon, you can adjust the settings of your device or browser. You can also set your device or browser to automatically reject any cookies. You may also be able to install plug-ins and add-ins that serve similar functions. However, please be aware that some Services may not work properly. In addition, the offers we provide when you visit us may not be as relevant to you or tailored to your interests.

Network Advertising Initiative

Certain websites you visit may provide options regarding advertisements you receive. If you wish to minimize the amount of targeted advertising you receive, you can opt-out of certain network advertising programs through the Network Advertising Initiative (NAI) Opt-Out Page. Please note that even if you choose to remove your information (opt-out) you will still see advertisements while you’re browsing online. However, the advertisements you see may be less relevant to you. For more information or to opt-out of certain online behavioral advertising, please visit http://www.aboutads.info.

Additionally, many advertising network programs allow you to view and manage the interest categories that they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The NAI Opt-Out Page provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies.

Do Not Track

Some devices and browsers support a “Do Not Track” (or, DNT) feature, a privacy preference that you can set in certain web browsers, which is intended to be a signal to websites and services that you do not wish to be tracked across different websites or online services you visit.

Please note that we cannot control how third party websites or online services you visit through our website respond to Do Not Track signals. Check the privacy policies of those third parties for information on their privacy practices.

9. THIRD PARTY WEBSITES AND APPS

The Services may contain links to other websites or apps operated by third parties. Please be advised that the practices described in this Privacy Notice do not apply to information gathered through these third party websites and apps. We have no control over, and are not responsible for, the actions and privacy policies of third parties and other websites and apps.

10. CONTACT US

We welcome questions, comments, and feedback on this Privacy Notice and our management of personal information. If you have questions, concerns, or feedback, you can always contact us in the following ways. For your protection, we may need to verify your identity before assisting with your request, such as verifying that the information used to contact us matches the information that we have on file.

California Consumer Privacy Act Appendix

To learn more about the categories of personal information we collect, how we collect it, why it is collected, and with whom we share the information, please see the chart below.