CLOSR APP LTD – Privacy Policy

Last updated: 05/12/2025

This Privacy Policy applies between you (the “User”) of the Closr App and/or Website, and CLOSR APP LTD (“we”, “us”, “our”).

It explains how we collect, store, process, and protect your personal data when you use our App or Website.

CLOSR APP LTD is registered with the Information Commissioner’s Office (ICO) under registration number 00019626191 and complies with UK GDPR and applicable data protection laws.

1. Definitions

Data – Any information you provide to Closr or that we collect about you through the App/Website.

Data Protection Laws – UK GDPR, Data Protection Act 2018, and all related legislation.

CLOSR APP LTD – Company number 16136329, registered office:

18 Burrell Avenue, Lancing, West Sussex, BN15 8QB.

User / You – Anyone accessing or using the Closr App or Website.

App / Website – The Closr mobile application and website at closr.deals, including all subdomains.

In this Privacy Policy:

Words in singular include plural and vice versa
“Including” means “including without limitation”
Headings are for convenience only

2. Scope of This Privacy Policy

This Privacy Policy covers only:

Closr App
Closr Website

It does not cover:

External websites linked within the App
Individual business websites or profiles

CLOSR APP LTD is the data controller, meaning we determine how and why your data is processed.

3. Who Are We?

Closr is a free community app built to support Sussex’s independent businesses.

Users can access offers, loyalty cards, and business information without any charge.

The App is free for Users. Businesses may choose to purchase promotional upgrades (e.g., Spotlight which is an external Closr Platforn), but this does not involve User data.

4. Data We Collect and Why

We only collect data necessary to operate and improve the App.

4.1 Personal & Contact Information

Name
Email address
Optional: postcode or address
Optional: phone number

Why?

Create and manage your account
Send service updates
Respond to queries
Display relevant local offers

4.2 Location Data

Your device’s location only when you allow it

Why?

Show nearby venues and location-based offers
Improve map-based features

Location data is never used for tracking outside the App.

4.3 Technical Data

Automatically collected when using the App/Website:

IP address
Device type
Operating system
App usage patterns
Pages/features used
Date/time of access

Why?

Improve App performance
Fix errors
Analyse usage trends

4.4 Communication & Feedback

Messages sent through support channels
Feedback, ratings, or reviews

Why?

Respond to queries
Improve App features

4.5 Business Data (Business Users Only)

For businesses using Spotlight or free listings:

Business contact details
Offer details
Images and promotional content

5. How Is Your Data Collected?

5.1 Directly from You

When you:

Register an account
Use app features
Contact support
Enable location
Submit feedback

5.2 Automatically

When using the App/Website, technical data is collected for analytics and functionality.

6. How We Use Your Data (Legal Basis)

We use your data under the following lawful bases:

Consent

When you opt into certain features (e.g., marketing updates, location access).

Contract

To provide services you request (e.g., creating an account).

Legitimate Interests

To improve the App, ensure security, and deliver relevant local content.

7. Who Do We Share Data With?

We only share data with trusted third parties essential to the App’s operation:

Technical service provider (hosting, security, support)
Analytics platforms (e.g., for performance monitoring)
Email/SMS providers (for updates)

We do NOT:

Sell your data
Share your data with advertisers
Share data with businesses without consent

Businesses only receive anonymised or aggregated performance stats, never your personal details.

8. Keeping Your Data Secure

We use measures including:

SSL encryption
Secure servers
Access controls
Data minimisation principles

No internet-based service is 100% secure, but we take all reasonable steps to protect your information.

9. Data Retention

We keep your data only as long as necessary:

Data Type / Retention

Account data / Active + 3 years after last activit
Support emails / 12 months
Location data / Real-time only (not stored permantly)

You may request deletion at any time.

10. Your Rights Under UK GDPR

You have the right to:

Access your data
Correct inaccurate data
Delete your data
Restrict processing
Object to processing
Transfer your data (data portability)
Withdraw consent at any time

To exercise rights or request account deletion:

support@closr.uk

11. Automated Decision-Making & Profiling

The App may use automated tools to:

Recommend nearby venues
Personalise your feed
Tailor offers based on usage

All automated processes are monitored by humans and do not make impactful or irreversible decisions.

12. Cookies & Tracking

Cookies and tracking tools may be used to:

Improve App functionality
Store basic preferences
Provide location-based recommendations
Analyse performance

Marketing communication is opt-in only, and you can unsubscribe at any time.

13. International Data Transfers

If data is processed outside the UK, we use:

Standard Contractual Clauses
Data Protection Agreements
UK GDPR-compliant safeguards

14. Changes to This Privacy Policy

We may update this policy from time to time.

Significant updates will be communicated via email or App notification.

15. Contact Us

For queries, support or requests:
support@closr.uk