1Close AI Global Privacy Policy.

This Policy aims to give you information on how 1Close AI collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product or service or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements other notices and privacy policies and is not intended to override them.

2.2.1 1Close AI is the controller and responsible for your personal data (collectively referred to as 1Close AI), "we", "us" or "our" in this Policy).

2.2.2 1Close AI has several subsidiaries as listed in the subprocessor list below. This Policy is issued on behalf of 1Close AI's group of companies so when we mention "1Close AI", "Company", "we", "us" or "our" in this privacy policy, we are referring to any of the relevant companies in the Company Group responsible for processing your data. 1Close AI Limited is the controller and responsible for this website.

2.3.1 If you have any questions about this Policy or our privacy practices, please contact our data privacy manager in the following ways:

2.3.2 You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

2.4.1 We keep our Policy under regular review. The personal data we hold about you must be accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2.4.2 1Close AI may occasionally update this Policy. When it does, 1Close AI will also revise the Effective Date at the top of this Policy. 1Close AI encourages you to periodically review this Policy to stay informed about 1Close AI's collection, use, and disclosure of personal information. 1Close AI reserves the right, at its discretion, to change, modify, add, or remove portions of the Policy at any time.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

We will receive personal data about you from various third parties as set out below.

5.3.1 Marketing

5.3.2 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

5.3.3 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product / service purchase.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

On our public marketing website, our Install Chat onboarding surface, and within our authenticated application, we use a cookie consent banner (Cookiebot) to obtain your preferences before non-essential cookies are set. Statistics cookies (for example, Google Analytics and Hotjar) are used only if you consent (in the UK, EEA, and similar regions; they may run on visit in the United States). We use Hotjar for product behaviour analytics (heatmaps and session recordings) so that we can understand how users interact with our application and improve usability. These session recordings are masked so that text you or others enter is hidden by default, and we do not use them to read the content of your deals, messages, or other business data. Marketing cookies (for example, Google Ads remarketing, the LinkedIn Insight Tag, and the X Pixel) are used only if you consent to marketing cookies in the UK, EEA, and similar regions; in the United States they may be set when you visit, subject to applicable state privacy laws and your opt-out choices.

For more information about the cookies we use, how to change your preferences, and the third parties involved, please see 1Close AI's Cookie Policy.

5.6.1 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

5.6.2 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

5.6.3 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may record telephone calls with our customers, clients, and other third parties for quality assurance, training, compliance, and record-keeping purposes. By engaging in a telephone call with us, you acknowledge and consent to this practice.

Purpose of Recording

The recordings help us to:

• Enhance the quality of our services through detailed review.
• Provide training to our staff by using real-life examples.
• Comply with legal and regulatory obligations.
• Address any complaints or disputes that may arise.

We may process the following categories of personal data in respect of these individuals:

• Identity and Contact Data: names, job titles, email addresses, telephone numbers, employer or company details, and professional identifiers.
• Communications Record Data: call recordings, voicemails, voice data, video and audio recordings, chat logs, and transcripts.
• Business Relationship Data: deal status, pipeline information, interaction history, engagement metrics, and related commercial information.
• AI-Generated Data: summaries, analyses, sentiment assessments, recommendations, or other outputs generated by our AI systems from the above data.
• Technical Data: IP addresses, device information, and other technical data captured in connection with communications conducted through our platform.

We obtain this personal data from the following sources:

• directly from our customers, who upload or input data into our platform;
• automatically, through calls, meetings, or communications conducted using our platform;
• from third-party data providers, lead generation tools, and publicly available sources integrated with or used in connection with our services; and
• through AI processing of the above data, which generates new data outputs.

In many cases, our customers are the controller of this data and we process it on their behalf as a data processor in accordance with their instructions and our Data Processing Agreement. However, we also process this data as a controller in our own right for the following purposes:

If you are an individual whose personal data is processed through our platform (but you are not a direct user of our services), you have the same rights under applicable data protection law as our direct users. These include the right to access your personal data, the right to rectification, the right to erasure, the right to restrict processing, the right to data portability, and the right to object to processing based on legitimate interests.

To exercise any of these rights, please contact us using the details set out in the "Contact details" section of this Policy. We may need to verify your identity before responding to your request, and in some cases we may need to liaise with our customer (the controller) to fulfil your request.

Our platform processes voice data through call recordings and transcription. In certain jurisdictions, voice data may be classified as biometric data if it is processed for the purpose of uniquely identifying an individual. We do not process voice recordings for biometric identification purposes. However, where applicable law treats voice recordings as special category data or biometric information, we will ensure that appropriate safeguards are in place, including obtaining explicit consent where required.

11.1.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

11.1.2 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

11.1.3 By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

11.1.4 In some circumstances you can ask us to delete your data.

11.1.5 In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

11.1.6 When 1Close AI has no ongoing legitimate business need to process personal information, we will either delete or anonymise/de-identify it or, if this is not possible (for example, because the data has been stored in backup archives), 1Close AI will securely store the personal information and isolate it from any further processing until deletion is possible.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

1. Our Policy applies to all California residents. The following additional California-specific disclosures are required by California law and relate to both our online and offline practices for handling "Personal Information" (as defined below) of California residents.

1.2 The California Consumer Privacy Act (CCPA) regulates the processing of Personal Information, which is defined as "information that identifies, relates to, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly with a particular consumer or household." For purposes of honoring the rights of California residents, all references to PII or Personal Data in our Policy include personal information as defined in the CCPA.

1.3 For purposes of this section, "Personal Information" has the meaning given in the California Consumer Privacy Act ("CCPA"), the California Privacy Rights Act of 2020 ("CPRA"), and any regulations promulgated under either law, in each case, as amended from time to time.

This Section 1 does not apply to;

• information exempted from the scope of the CCPA;
• activities governed by a different privacy notice, such as notices we give to California personnel or job candidates; or
• Personal Information we collect, use, and share on behalf of our customers as a "service provider" under the CCPA.

2. Your Rights

2.1 You have the following rights:

• Right to Information / Know and Data Portability. You can request whether we have collected your Personal Information, and in certain cases, the following information about how we have collected and used your Personal Information during the past 12 months:
  • The categories of Personal Information we have collected.
  • The categories of sources from which we collected the Personal Information.
  • The business or commercial purpose for collecting, sharing, and/or selling Personal Information.
  • The categories of Personal Information that we sold or disclosed for a business purpose.
  • The categories of third parties to whom Personal Information was sold, shared, or disclosed for a business purpose.
• Right to Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
• Right to Correction. You can request that we correct inaccurate Personal Information that we have collected about you.
• Right to Deletion. You can ask us to delete the Personal Information that we have collected from you.
• Right to Opt-Out of Tracking for Targeted Advertising Purposes. While we do not sell Personal Information for money, like many companies, we use services that help deliver targeted ads (also known as interest-based ads) to you, as we have described in the "How and Why We Use Your Personal Data" section above. The CCPA classifies our use of some of these services as "sharing" your Personal Information with the advertising partners that provide the services, from which you have the right to opt-out.
• Right to Nondiscrimination. You are entitled to exercise the rights described above free from discrimination prohibited by the CCPA.

3. How to exercise your rights

3.1 Right to Information / Know, Access, Correction, and Deletion. You can exercise any of the above rights by emailing us at help@1close.ai.

3.2 Verification of Identity. We will need to verify your identity to process your information / know, access, correction, and deletion requests and reserve the right to confirm your California residency. To verify your identity, we may require you to provide government identification, give a declaration as to your identity under penalty of perjury, and/or provide additional information. These rights are not absolute, and in some instances, we may decline your request as permitted by law.

3.3 Authorised Agents. Your authorized agent may make a request on your behalf upon our verification of the agent's identity and our receipt of a copy of the valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity and provide us with written confirmation that you have given the authorized agent permission to submit the request.

4. Personal Information that we collect, use and disclose

The table below describes our Personal Information practices by reference to the categories in the "Personal Data Collected by 1Close AI" section above and the categories described in the CCPA (Cal. Civ. Code Section 1798.140(v)) and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in webforms, may contain other categories of personal information not described below. Note that:

• We do not "sell" personal information as defined by the CCPA and have not sold Personal Information in the preceding 12 months.
• We do not use or disclose sensitive personal information for purposes that California residents have a right to limit under the CCPA.

5. Response Timing

5.1 We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact help@1close.ai.

5.2 We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

5.3 If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically.

5.4 Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

5.5 We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

1. Our Policy applies to all Colorado, Connecticut, and Virginia residents. The following supplemental disclosures are specifically required by state law.

2. Colorado, Connecticut, and Virginia regulate the processing of "Personally Identifiable Information", which generally has the same definition as Personal Data in our Policy. We recognise all requests to exercise state privacy rights including both personal data under applicable state law and Personal Data as defined in our Policy.

Mandatory Disclosures

• We process the following categories of personal data: identifiers / contact information, demographic information (including gender and age), payment card information, commercial information (such as information about your business), internet activity, audio and electronic information, and inferences.
• The purposes for processing your Personal Data are described in our Policy.
• We may disclose all of the categories of Personal Data described above to the third parties described in our Policy.
• We process the following categories of personal data for targeted advertising purposes: identifiers, demographic information, commercial information, internet activity, and inferences.

3. The Right to Opt-Out of Marketing and Advertising

We recognise the right to opt-out of targeted marketing and advertising communications. You can exercise this right by sending us an email at help@1close.ai. If you are a customer, you can also opt-out of targeted marketing and advertising communications by notifying your customer success manager.

4. How to Exercise Your Rights

4.1 You, or an authorised agent, may make a request to exercise your rights to know, access, correct, delete, transfer (portability), or opt-out of marketing by emailing us at help@1close.ai. You, or an authorized agent, can also send your request by mail to the address listed in our Policy.

4.2 We reserve the right to use commercially reasonable methods to verify your identity and the authority of any authorized agent to act on your behalf.

5. Time To Respond

Under state law, we have 45 days to respond to your inquiry and may add an additional 45 days depending on the complexity of your request. Please note, however, that as a general rule we normally respond to requests within 30 days as set forth in our Policy.

6. Right of Appeal

6.1 If we reject your request, you have the right to appeal that denial by notifying us that you disagree with our decision by email at help@1close.ai.

6.2 If you choose to appeal, please explain why you believe you are entitled to receive the information requested despite our denial. We will respond to any appeal within 45 days.

7. Right to Complain to Attorney General

If we deny any request you made under our Policy or this state Supplemental Privacy Policy, you may file a complaint with your state's attorney general.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service / product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

External Third Parties

• Service providers acting as processors based worldwide; Singapore, EEA, United Kingdom and USA who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom and Pakistan who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.