1. Overview
The services described in this policy, including this website and the systems we build and operate, are developed and operated by the developer ClosersConnect on behalf of Closers Connect Limited, a company registered in Hong Kong. We take the privacy of our clients, partners, and website visitors seriously.
This policy explains the information we may collect, the reasons we collect it, the ways we use it, and the circumstances in which we may share it with others. We design our own systems with data protection in mind, and we apply the same discipline to our own operations that we bring to the systems we build for clients.
We encourage you to read this policy in full so that you understand how your information is handled. If you have a question that this document does not answer, please contact us using the details at the end of this policy, and we will respond as quickly as we can.
2. Scope of This Policy
This policy applies to information collected through our website at www.closersconnect.lat, through our email and telephone communications, through project work we perform for clients, and through any other interaction with our firm. It also applies to the information we handle when we operate or maintain systems on behalf of our clients.
This policy does not apply to the practices of third party websites or services that we do not control, even where those services are linked from our pages. Each third party remains responsible for its own handling of information, and you should review its own policy before sharing anything with it.
Where a separate written agreement with a client contains different data handling terms, the terms of that agreement will govern in relation to that specific project. In all other respects, this policy applies to our interactions with you.
3. Information We Collect
We collect information in several categories: identity information, contact information, project information, technical information, and engagement information. Identity information includes names and job titles. Contact information includes business email addresses, telephone numbers, and company addresses.
Project information includes the technical specifications, system descriptions, and operational data that you share with us in the course of an engagement. This category may contain business data that belongs to your organization, and we treat it with the same care we apply to personal information.
Technical information includes browser type, device type, operating system, referring pages, and the pages you view on our website. Engagement information includes the dates and times of your interactions with us and the outcomes of those interactions. We collect only what we need, and we collect it for clear purposes.
4. Sources of Information
We collect information directly from you when you contact us, submit a form, request a proposal, or engage our services. When you write to us by email, the correspondence itself becomes part of our records, and we retain it for the purposes described in this policy.
We collect information automatically through standard technologies such as server logs and cookies when you visit our website. These tools tell us how the site is used so that we can make it more useful, more secure, and easier to navigate.
We may also receive information from public business directories and from your own company when you are introduced to us as a contact or as a nominated project owner. We do not buy personal data from brokers, and we do not require sensitive categories of information in order to provide our services.
5. Legal Bases for Processing
We process information only where we have a lawful basis to do so. In most cases our basis is the performance of a contract, where processing is necessary to deliver the systems design services we have agreed to provide. This covers the work of planning, building, integrating, and supporting client systems.
Where we process information for our legitimate interests, such as improving our services, maintaining security, and responding to inquiries, we balance those interests against your rights and expectations. We keep records of these assessments so that our reasoning remains transparent.
Where we are required to comply with a legal obligation, such as record keeping or responding to lawful requests, we will process information as the law requires. We do not rely on consent where another basis is more appropriate, and we will not sell your information for any purpose, commercial or otherwise.
6. How We Use Information
We use the information we collect to respond to inquiries, prepare proposals, deliver projects, manage our client relationships, improve our website and services, protect our systems against misuse, send administrative notices, and meet legal and regulatory obligations.
We use project information solely to perform the work you have engaged us to do. We do not mine client data for other purposes, and we do not combine the data of one client with the data of another. Every engagement is treated as a separate matter, governed by its own documentation.
We use technical information to understand how visitors use our website so that we can make it more useful and secure. We do not use your information for advertising purposes, and we do not build marketing profiles from the information you share with us.
8. International Data Transfers
Our registered office is in Hong Kong, and we may engage service providers who store or process information in other jurisdictions. When information is transferred across borders, we take steps to ensure it receives an appropriate level of protection.
Those steps include data processing agreements, standard contractual protections, and, where required, additional safeguards such as technical controls on access. We review our transfer arrangements whenever a provider or a location changes.
You should be aware that countries outside your own may have data protection laws that differ from those where you are located. By using our services, you acknowledge that your information may be transferred in accordance with this policy and with applicable law.
9. Data Retention
We keep information only for as long as it is needed for the purposes described in this policy or for as long as the law requires. We set retention periods at the start of every engagement and review them regularly.
Project records are retained for the duration of the engagement and for a reasonable period afterwards to support warranty, support, and audit obligations. Website logs and technical information are retained for a shorter period, typically twelve months or less.
When information is no longer needed, we delete it or render it anonymous so that it can no longer be linked back to an identifiable person. Our deletion processes are applied consistently and verified by the responsible team member before records are destroyed.
10. Data Security
We apply administrative, technical, and physical safeguards to protect the information we hold. These measures include access controls, encryption in transit and at rest, secure storage for our records, staff training on data handling, and routine review of our security practices.
We treat security as a continuous discipline rather than a one-time certification. Our engineers test our systems, review our configurations, and respond to new threats as they emerge. We also keep our own policies under review so that they reflect current practice.
No method of transmission or storage is completely secure, and we cannot guarantee absolute security. However, we are committed to protecting your information and to notifying you promptly if a risk to your information arises, in the manner described later in this policy.
11. Your Privacy Rights
Depending on where you are located, you may have rights in relation to the information we hold about you. These rights may include the right to access your information, the right to correct inaccurate information, and the right to request deletion of your information.
You may also have the right to object to certain processing, the right to restrict processing in certain circumstances, and the right to request a copy of your information in a portable format. We will honour these rights to the extent required by applicable law.
To exercise any of these rights, please contact us using the details at the end of this policy. We will respond within the timeframes required by applicable law and will ask you to verify your identity before acting on your request.
12. Privacy for Children
Our website and services are directed to business and professional audiences and are not designed for children. We do not knowingly collect information from children under the age of sixteen.
If you believe that a child has provided information to us without the consent of a parent or guardian, please contact us and we will take steps to delete that information promptly. We rely on the assistance of parents and guardians to bring such cases to our attention.
Because our services are business oriented, the information we handle belongs to adults acting in a professional capacity. We have no reason to collect information from children through any of our channels, and we do not target our services to minors.
14. Third Party Services and Links
Our website may include links to third party websites and may rely on third party services for functions such as hosting, analytics, and communication. When you leave our website or use a third party service, the privacy practices of that third party will apply.
We encourage you to read the privacy policies of any third party service you use before you share information with it. We review the third party services we engage for their data handling standards and seek to work only with providers who take data protection seriously.
We cannot be responsible for the practices of providers we do not control. Where a third party service is integral to our own operations, we document that relationship in our internal records and subject it to the same review discipline as our own systems.
15. Automated Decision Making
We do not use your personal information for automated decision making that produces legal or similarly significant effects. Our systems do not score, rank, or profile you in a way that would decide an outcome affecting you.
Where we use automated tools, such as form validation or spam protection, those tools operate within narrow technical limits. They are not used to make judgments about your character, credit, or eligibility for any service.
If this position changes, we will update this policy and provide you with information about any automated decision making that affects you, including the logic involved and your right to request human review.
16. Data Breach Notification
In the event of a breach of our systems that affects your information, we will take immediate steps to contain the incident, assess its scope, and preserve evidence for investigation. Our team follows a documented incident response plan that is tested regularly.
Where required by applicable law, we will notify the relevant authorities and affected individuals without undue delay. Our notification will include a description of the incident, the categories of information involved, the measures we have taken, and the steps we recommend you take to protect yourself.
We treat every incident seriously, regardless of its size. Even where notification is not legally required, we will inform affected clients where we believe the information at risk merits attention, so that they can make their own decisions.
17. Changes to This Policy
We may update this policy from time to time to reflect changes in our services, in technology, or in the law. When we make material changes, we will revise the effective date at the top of this page and, where appropriate, notify you by email or by a notice on our website.
We encourage you to review this policy periodically so that you remain informed about how we handle your information. The date of the latest revision is always shown at the top of this page for easy reference.
Continued use of our website or services after a change takes effect indicates your acceptance of the revised policy, subject to any rights you hold under applicable law. If you do not accept the revised policy, you should stop using our services.
18. Contact Information
If you have questions, comments, or requests regarding this policy or the way we handle information, please contact us by email at help@closersconnect.lat or by telephone at +15675505414.
Our registered office is Closers Connect Limited, Rm 509 5/F THE CLOUD, 111 TUNG CHAU ST, Tai Kok Tsui, Hong Kong (HK). You may write to us at this address by post, and we will treat all correspondence in confidence.
We will respond to your inquiry as quickly as we can. If you are not satisfied with our response, you have the right to raise a concern with the data protection authority in your jurisdiction.