Privacy Policy

Effective from: July 5, 2016

We’ve updated our Terms of Service and Privacy Policy to make them easier to understand and to let you know about some changes to our current services and a few that we’re planning in future. Please don’t forget to read the Terms of Service and Privacy Policy to make sure you understand any changes that may be important to you!

Rappier Pte Ltd ("Rappier") provides this Privacy Policy to help you make an informed decision about whether to use or continue using the Closrr Site, Closrr Software and/or the Closrr Service. If you do not agree to our practices, please do not use the Closrr Site, Closrr Software, or Closrr Service.

This Privacy Policy is incorporated into and is subject to the Closrr Terms of Service. Your use of the Closrr Site, Closrr Software and the Closrr Service and any personal information you provide on the Closrr Site or Closrr Service remains subject to the terms of this Privacy Policy and our Terms of Service.

Please note that any Status Submissions or other content posted at the direction or discretion of users of the Closrr Service becomes published content and is not considered personally identifiable information subject to this Privacy Policy.

What Does This Privacy Policy Cover?
This Privacy Policy is part of Closrr’s Terms of Service and covers the treatment of user information, including personally identifying information, obtained by Closrr, including information obtained when you access the Closrr Site, use the Closrr Service or any other software provided by Closrr.

This Privacy Policy does not apply to the practices of companies that Closrr does not own or control, or to individuals whom Closrr does not employ or manage, including any of the third parties to which Closrr may disclose user information as set forth in this Privacy Policy.

The Information Closrr Collects
Closrr may obtain the following types of information from or concerning you or your mobile phone device, which may include information that can be used to identify you as specified below (“Personally Identifying Information”):

User Provided Information: You provide certain Personally Identifiable Information, such as your name, your email address, your mobile phone number, push notification name (if applicable), billing information (if applicable) and mobile device information to Closrr when choosing to participate in various uses of the Closrr Service, such as registering as a user, assigning shortcuts to your contacts, updating your status or requesting status for your contacts. In order to provide the Closrr Service, Closrr will periodically access your address book or contact list on your mobile phone to locate the mobile phone numbers of other users (“in-network” numbers).

Birthdate: We collect this information to validate your age as Closrr Social Xpress is appropriate for use by users over 12 years of age.

Gender: We collect this information so that we can show appropriate advertising content to you. You may choose ‘Other’ option if you choose not to disclose this information.

The Information We Share:
We collect information only to provide you with the Services, to improve your experience using the Services and develop new services. We do not sell personal information of users to other parties.
 

Closrr Offers (for ANDROID Only): We may share limited information with advertisers who are interested in presenting you with a tailored offer on Closrr Offers. For example, we may provide the approximate location associated with your IP address (i.e. country and state/province), your age or age range and your gender so that you’ll receive more relevant offers. We do not share your username or email address with advertisers without your consent. 

Our service providers: We use third-party service providers to help operate our business. Examples include suppliers that host our data or provide customer service.  Use of your personal information by our service providers is limited to the information they need to provide services on our behalf. 

Our related companies: We may share some or all of your information with our related companies, including our affiliates, subsidiaries, or joint ventures who are also required to honour this privacy policy.

To protect Closrr and its users, or for legal purposes: We may disclose your information:  (a) if we think it’s needed to detect, prevent or address illegal activity on our Services, or identify, contact or bring legal action against someone who appears to be causing injury to or interfering with our rights or property or other users; (b) as part of a Closrr legal matter or investigation, including an investigation related to a suspected breach of our Terms of Service; (c) when we believe that disclosure is required or permitted by law, including when responding to subpoenas, warrants, production orders, or similar instruments; or (d) if we believe that disclosure is needed to protect your safety or the safety of others, including when there is an emergency involving potential harm, loss of security or serious injury to people or threats of such emergencies.

If you post content on Closrr’s social networking feature ‘Xpress’ using the Closrr app, we will provide your content as you’ve requested. The information you choose to share on social networking sites is not covered by this privacy policy, and you agree that you are solely responsible for your use of those services.

Cookies Information: When you visit the Closrr Site, we may send one or more cookies - a small text file containing a string of alphanumeric characters - to your computer that uniquely identifies your browser. Closrr uses both session cookies and persistent cookies. A persistent cookie remains after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser help file directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, the Closrr Site may not function properly if the ability to accept cookies is disabled.

Log File Information: When you use the Closrr Site, our servers automatically record certain information that your web browser sends whenever you visit any website. These server logs may include information such as your web request, Internet Protocol ("IP") address, browser type, browser language, referring / exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request, one or more cookies that may uniquely identify your browser, your phone number, phone number you are requesting the status of and various status information. When you use the Closrr Service, our servers log certain general information that our application sends whenever a message is sent or received, or if you update or request any status information, including time and date stamps and the mobile phone numbers the messages were sent from and to.

The Information Closrr Does Not Collect
Closrr does not collect names, emails, addresses or other contact information from its users’ mobile address book or contact lists other than mobile phone numbers—the Closrr mobile application will associate whatever name the Closrr user has assigned to the mobile telephone number in his/her mobile address book or contact list — and this occurs dynamically on the mobile device itself and not on Closrr’s servers and is not transmitted to Closrr. This means that if you have your friend’s mobile phone number associated with the name “Maverick” in your mobile address book, that’s the name that will appear for that mobile phone number in your Closrr contact list. Likewise, the profile image of your friend will appear as in your mobile address book if an image is associated otherwise the profile image is taken from the user’s profile image stored on their Closrr profile; User initials are displayed when no image is available. We do not collect location data, but users may voluntarily share their location with other users via the Closrr Service.

The contents of messages that have been delivered by the Closrr Service are not copied, kept or archived by Closrr in the normal course of business. The Closrr Service uses the data service through a user’s phone (either via cell network or wifi). Users type their messages, which are sent via data service to our servers, and routed to the intended recipient (who must also be a Closrr user), if that recipient is online. If the recipient is not online, the undelivered message is held in Closrr’s server until it can be delivered. If the message is undelivered for thirty (30) days, the undelivered message is deleted from our servers. Once a message has been delivered, it no longer resides on our servers. The contents of any delivered messages are not kept or retained by Closrr — the only records of the content of any delivered messages reside directly on the sender’s and recipient’s mobile devices. Notwithstanding the above, Closrr may retain date and time stamp information associated with successfully delivered messages and the mobile phone numbers involved in the messages, as well as any other information which Closrr is legally compelled to collect. Files that are sent through the Closrr Service will reside on our servers after delivery for a short period of time, but would be deleted within a short period of time in accordance with our general retention policies.

The Way Closrr Uses Information
If you submit Personally Identifiable Information to us through the Closrr Site, or Closrr Service, then we use your personal information to operate, maintain, and provide to you the features and functionality of the Closrr Site and Closrr Service. In particular, your mobile phone number is essential to your use of the Closrr Service and will be retained. Any Personally Identifiable Information or status content that you voluntarily disclose on the Closrr Service becomes publicly available and may be collected and used by other users of the Closrr Service (unless such user is blocked by you). Your name (as it is saved in other user's mobile phone address book or contact list) may be displayed to other users when you update your status messages through the Closrr Service and other users may contact you through the Closrr Service. We do not use your mobile phone number or other Personally Identifiable Information to send commercial or marketing messages without your consent or except as part of a specific program or feature for which you will have the ability to opt-in or opt-out. We may, however, use your mobile phone number (or email address, if provided) without further consent for non-marketing or administrative purposes (such as notifying you of major Closrr Site or Closrr Service changes or for customer service purposes). We may use both your Personally Identifiable Information and certain non-personally-identifiable information (such as anonymous user usage data, cookies, IP addresses, browser type, clickstream data, etc.) to improve the quality and design of the Closrr Site and Closrr Service and to create new features, promotions, functionality, and services by storing, tracking, and analyzing user preferences and trends. We may use cookies and log file information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you use the Closrr Service or Closrr Site; (b) provide custom, personalized content and information; (c) monitor individual and aggregate metrics such as total number of visitors, pages viewed, etc.; and (d) track your entries, submissions, views and such.

When Closrr Discloses Information
Other users of the Closrr Service may see your Status Submissions in a way that is consistent with the use of the Closrr Service. In other words: If another user has your mobile phone number stored in their mobile phone address book or contact list, they will be able see your status information. At this time, we do not have any facility block such information to other users. “Last Seen” information is available and displayed to each user who has your mobile phone number in their mobile phone address book or contact book (and which you have not blocked), and reflects the last approximate time the Closrr mobile application has been used or brought to the foreground on your mobile phone. “Last Seen” information is reported to Closrr when a user brings the mobile application to the foreground.
We do not sell or share your Personally Identifiable Information (such as mobile phone number) with other third-party companies for their commercial or marketing use without your consent or except as part of a specific program or feature for which you will have the ability to opt-in or opt-out. We may share your Personally Identifiable Information with third party service providers to the extent that it is reasonably necessary to perform, improve or maintain the Closrr Service. We may share non-personally-identifiable information (such as anonymous User usage data, referring / exit pages and URLs, platform types, asset views, number of clicks, etc.) with interested third-parties to assist them in understanding the usage patterns for certain content, services, advertisements, promotions, and/or functionality on the Closrr Site or Service. We may collect and release Personally Identifiable Information and/or non-personally-identifiable information if required to do so by law, or in the good-faith belief that such action is necessary to comply with authoritities, international law or respond to a court order, subpoena, or search warrant or equivalent, or where in our reasonable belief, an individual’s physical safety may be at risk or threatened. Closrr also reserves the right to disclose Personally Identifiable Information and/or non-personally-identifiable information that Closrr believes, in good faith, is appropriate or necessary to enforce our Terms of Service, take precautions against liability, to investigate and defend itself against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Closrr Site or our servers, and to protect the rights, property, or personal safety of Closrr, our users or others.

Your Choices
You may, of course, decline to submit Personally Identifiable Information through the Closrr Site or the Closrr Service, in which case Closrr may not be able to provide certain services to you. If you do not agree with our Privacy Policy or Terms of Service, please delete your account, uninstall the Closrr mobile application and discontinue use of the Closrr Service; your continued usage of the Closrr Service will signify your assent to and acceptance of our Privacy Policy and Terms of Service. To protect your privacy and security, we take reasonable steps (such as SMS authentication) to verify your identity before registering your mobile phone number and granting you access to the Closrr Service. Please contact Closrr via email to team@closrr.com with any questions or comments about this Privacy Policy.

Our Commitment To Data Security
Closr uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. We cannot, however, ensure or warrant the security of any information you transmit to Closrr and you do so at your own risk. Using unsecured wifi or other unprotected networks to submit messages through the Closrr Service is never recommended. Once we receive your transmission of information, Closrr makes commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If Closrr learns of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. Closrr may post a notice on the Closrr Site or through the Closrr Service if a security breach occurs.

Special Note to International Users
The Closrr Site and Service are hosted in Singapore and are intended for and directed to users in Asia. If you are a user accessing the Closrr Site and Service from the United States, European Union, or any other region with laws or regulations governing personal data collection, use, and disclosure, that differ from Singapore laws, please be advised that through your continued use of the Closrr Site and Service, which are governed by Singapore law, this Privacy Policy, and our Terms of Service, you are transferring your personal information to Singapore and you expressly consent to that transfer and consent to be governed by Singapore law for these purposes.

In the Event of Merger, Sale, or Bankruptcy
In the event that Closrr is acquired by or merged with a third party entity, we reserve the right to transfer or assign the information we have collected from our users as part of such merger, acquisition, sale, or other change of control. In the (hopefully) unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your personal information is treated, transferred, or used.

Changes and updates to this Privacy Notice
This Privacy Policy may be revised periodically and this will be reflected by the "effective date". Please revisit this page to stay aware of any changes. Your continued use of the Closrr Site and Closrr Service constitutes your agreement to this Privacy Policy and any amendments.