Privacy Policy

1. About this policy

This Privacy Policy explains how Closelio AI LLC, a {{ENTITY_STATE}} limited liability company ("Closelio," "we," "us"), handles personal information in connection with our websites (closelio.ai, app.closelio.ai and api.closelio.ai) and our software (together, the "Service").

Closelio is a business tool for US life and health insurance agents and agencies. It includes a CRM, SMS messaging, AI voice agents, a Power Dialer, appointment scheduling and related features. The Service is offered only to businesses and professionals in the United States who are at least 18 years old. It is not offered to consumers.

In this policy, "Customer" means the business or person that signs up for and pays for the Service. "Users" are the people a Customer allows into its workspace, such as the agents in an agency. "Contacts" (also called "Leads") are the Customer's prospects and clients whose information the Customer uploads to, or receives through, the Service. "You" means a Customer or User unless we say otherwise.

This policy should be read together with our Terms of Service and our Data Processing Addendum.

2. Our two roles

We handle personal information in two different roles, and the rules differ for each.

Data we control. Information about Customers and Users, such as account details, billing records and how you use the Service, is information we collect for our own business purposes. We decide how it is used, and this policy describes what we do with it.

Data we process for Customers. Information about Contacts belongs to the Customer that brought it into the Service. We process it only on that Customer's behalf and under its instructions, acting as a "service provider" or "processor" under US state privacy laws. Our Data Processing Addendum governs that processing. The Customer, not Closelio, decides which Contacts to reach, what to say to them, and how long to keep their data. Section 6 explains more.

3. Information we collect about Customers and Users

Information you give us. When you create an account, join a workspace or use the Service, you may give us your name, email address, phone number, password, business or agency name, and profile settings. If you sign in with Google, we receive basic profile details from Google, such as your name and email address.

Verification information. We send one-time codes to your email address or phone number to confirm that you control them and to protect your account. We keep a record that verification took place.

Business and registration information. To register your business for SMS messaging with US carriers (known as A2P 10DLC registration), we collect the details carriers require. Depending on whether you register as a sole proprietor or a standard brand, this can include your legal name, business name, business address, contact phone and email, tax or business identifiers, website, a description of how you will send messages, and sample messages. We may also ask for licensing details such as your National Producer Number (NPN). We pass this information to our messaging provider and, through it, to The Campaign Registry and the carriers for the purpose of registration.

Billing information. Payments are handled by Stripe. When you pay, you give your card or bank details directly to Stripe. We do not store full card numbers. We receive and keep limited billing details from Stripe, such as your plan, billing contact, the card brand and last four digits, payment status and invoices.

Usage information. We record how the Service is used, including features used, messages and calls sent and received, minutes and dials consumed, campaign settings, and actions taken in the app. We use this to run the Service, to calculate charges for usage beyond your plan allowances (see our Included-Usage Terms), and to support you.

Device and log information. When you use our websites or app, our systems automatically record technical information such as IP address, browser type, operating system, pages and API endpoints requested, timestamps, and error reports. We use an error monitoring service to help us find and fix problems.

Information from connected services. If you connect a third-party account, such as Google Calendar or Meta lead ads, we receive the information needed to make that connection work, for example calendar availability and appointments, or new leads from your lead forms. You can disconnect these services at any time.

Communications with us. If you email us or ask for support, we keep the messages and any information you include.

4. How we use information about Customers and Users

We use the information in Section 3 to:

• create and manage your account and workspace, and sign you in securely;
• provide the features you use, including messaging, calling, AI features, scheduling and reporting;
• register your brand and messaging campaigns with carriers when you ask us to;
• bill you, collect payments and handle billing disputes;
• send you service messages, such as verification codes, security alerts, billing notices and notice of changes to our terms;
• respond to support requests;
• monitor, secure and fix the Service, and detect and prevent fraud, abuse and violations of our Acceptable Use Policy;
• understand how the Service is used so we can improve it;
• comply with law, respond to lawful requests, and enforce our agreements.

We may send you product news or offers about Closelio by email. You can opt out of those at any time using the link in the message. Service messages are not optional while you have an account.

5. Cookies and similar technologies

We use cookies and similar browser storage to keep you signed in, maintain your session, remember your preferences, and protect against forged requests. These are needed for the Service to work. If you block them, you may not be able to sign in.

{{TODO: confirm whether the marketing site uses any analytics or advertising cookies or pixels; if so, describe them here and add an opt-out method}}

6. Contact data we process for Customers

Customers use the Service to store and communicate with their Contacts. Contact data can include names, phone numbers, email addresses, mailing addresses, dates of birth, insurance interests and other details from lead forms, consent records, notes, appointment details, the content of text messages, call recordings, call transcripts, and call outcomes. It can arrive by CSV upload, from lead vendors through webhooks, from Meta lead ads, or from Contacts' own replies and calls.

We process Contact data only to provide the Service to the Customer, as described in our Terms of Service and Data Processing Addendum, and as required by law. The Customer is responsible for having a lawful basis to collect Contact data and to contact each Contact, as explained in our Communications Compliance Addendum.

If you are a Contact, the insurance agent or agency that contacted you is responsible for your information. Please contact them first with any question or request, such as asking to see or delete your information. If you send a request to us, we will pass it to the relevant Customer where we can identify them, and we will help the Customer respond as our agreements require. To stop text messages from a number that uses our Service, reply STOP. To stop calls, tell the caller or the agent that you do not want to be contacted again.

7. AI processing

Several features use artificial intelligence. For example, the Service can write suggested or automatic replies to a Contact's text messages, run AI voice agents that speak with Contacts on calls, turn call audio into text, and summarize conversations.

To do this, we send the relevant content, such as a Contact's message, recent conversation history, the Customer's instructions, or live call audio, to AI subprocessors that generate the reply, voice or transcript and return it to us. These subprocessors are listed on our Subprocessor List.

We do not use Customer Contact data to train our own foundation models, and we do not provide it to third parties for the purpose of training their foundation models. {{TODO: confirm vendor zero-retention / no-training settings}}

AI output can be wrong. Customers decide whether to turn on AI features, how they are configured, and are responsible for the messages and calls sent from their accounts.

8. Call recordings and transcripts

Call recording is a workspace-level setting. A Customer can turn it on, and in some configurations it may be on for all calls in a workspace. When recording is on, we store the call audio and may create and store a transcript. Calls handled by AI voice agents are transcribed so the agent can understand and respond.

Recordings and transcripts are Contact data that we process for the Customer. The Customer is responsible for giving any notice and getting any consent that recording laws require.

9. How we share information

We do not sell personal information, and we do not share it for cross-context behavioral advertising. We share personal information only as follows:

• Subprocessors and service providers. We use other companies to host and run the Service, including for hosting, databases, networking, telephony and messaging, AI, speech-to-text, payments, email delivery and error monitoring. They may use the information only to provide services to us. Our current list is on the Subprocessor List.
• Carriers and registration bodies. To deliver texts and calls, message content and phone numbers pass through our telephony provider and the telephone carriers. For A2P 10DLC registration, we share the business information you provide with our telephony provider, The Campaign Registry and carriers.
• Within your workspace. Information in a workspace is visible to its Users according to their roles. In an agency workspace, the agency owner and authorized Users can see data in that workspace. See our Agency Addendum.
• Services you connect. If you connect a service such as Google or Meta, we exchange the information needed for that connection.
• Legal and safety reasons. We may disclose information if we believe in good faith it is required by law, subpoena, court order or other legal process, or is needed to protect the rights, safety or property of Closelio, our Customers, Contacts or others, or to investigate fraud or abuse.
• Business transfers. If we are involved in a merger, acquisition, financing, reorganization or sale of assets, information may be transferred as part of that deal, subject to this policy.
• With your direction. We may share information when you ask us to.

Mobile phone numbers and SMS opt-in or consent information are never shared with third parties or affiliates for their own marketing or promotional purposes. This does not stop us from sharing information with subprocessors and carriers that help us deliver messages.

10. How long we keep information

We keep personal information for as long as needed for the purposes in this policy. That generally means for as long as an account is active, and afterward as needed to comply with legal, tax and accounting obligations, resolve disputes, prevent abuse, and enforce our agreements. Records of messages, calls, consent and opt-outs may be kept longer than other data because they can be needed to show compliance with communications laws.

Customers control how long Contact data stays in their workspace and can delete it from the app. When a Customer's account ends, we handle Contact data as described in the Data Processing Addendum.

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11. Security

We use reasonable administrative, technical and physical measures designed to protect personal information. These include encrypting data in transit, limiting access to people and systems that need it, and logging access to our systems. No method of transmission or storage is completely secure, and we cannot guarantee the security of any information.

You are responsible for keeping your password and devices secure and for managing who has access to your workspace. Tell us right away at privacy@closelio.ai if you think your account has been compromised.

12. Where information is processed

The Service is provided from the United States. Our application servers and database are located in the United States, and we process personal information in the United States. The Service is intended only for use in the United States.

13. Children

The Service is not directed to anyone under 18, and we do not knowingly collect personal information from children. Customers must not use the Service to contact or store information about minors except as the law allows. If you believe we have collected information from a child, contact privacy@closelio.ai and we will take steps to delete it.

14. Your US state privacy rights

Depending on the state where you live, you may have some or all of these rights regarding personal information we control about you:

• Access. To know what personal information we have collected about you, and to get a copy.
• Deletion. To ask us to delete personal information we collected from you.
• Correction. To ask us to correct inaccurate personal information.
• Opt-out. To opt out of the sale of personal information, sharing for cross-context behavioral advertising, targeted advertising, and certain profiling. We do not sell personal information or use it for those purposes.
• Non-discrimination. We will not treat you differently for using these rights.

To make a request, email privacy@closelio.ai. We will need to verify your identity before acting on most requests, usually by confirming information we already hold, such as asking you to reply from the email address on your account. We may deny a request if we cannot verify it, or if an exception in the law applies, and we will tell you why.

You may use an authorized agent to make a request for you. We may ask the agent for written permission signed by you and may still ask you to confirm your identity directly with us.

If we deny your request, you may appeal by replying to our decision or emailing privacy@closelio.ai with "Appeal" in the subject line.

These rights apply to information we control. If you are a Contact, your request about information an insurance agent holds should go to that agent, as described in Section 6.

15. Changes to this policy

We may update this policy from time to time. If we make a material change, we will notify Customers by email, in the app, or both. Material changes take effect 30 days after we give notice. The version in effect will always be available on this page.

16. Contact us

For privacy questions or requests, email privacy@closelio.ai. For legal matters, email legal@closelio.ai. For general support, email hello@closelio.ai.

Postal address: Closelio AI LLC, {{ADDRESS}}