Privacy Policy

Effective Upon: January 1, 2020
Last Updated: June 24, 2024

We at The Close, owned by TechnologyAdvice (collectively, “us,” “our,” or “we”), are strongly committed to transparency. We want you (“you” or “your”) to understand how we collect, use, share, and protect your personal information, as well as how you can manage the personal information we collect. This Privacy Notice applies to your interactions with us and your use of our website (www.fitsmallbusiness.com and www.theclose.com), products, services, and features, either online or offline (collectively, the “Services”).

By using our Services, you accept this Privacy Notice’s terms. If you do not agree to the terms of this Privacy Notice, please do not use our Services. If you do not understand or have questions about this Privacy Notice, please contact us before using or continuing to use our Services.

We reserve the right to change our Privacy Notice periodically by posting the changes here. We will also provide you with notice by prominently posting on our website, via email, or both if we make any changes to this Privacy Notice that materially affect your rights. Your use of our Services after we have changed our Privacy Notice will mean that you have accepted those changes.


  1. TYPES OF INFORMATION WE COLLECT
  2. HOW WE COLLECT INFORMATION
  3. HOW WE USE INFORMATION
  4. HOW WE SHARE INFORMATION
  5. HOW WE PROTECT INFORMATION
  6. CHILDREN’S PRIVACY
  7. YOUR CALIFORNIA PRIVACY RIGHTS
  8. YOUR CHOICES
  9. THIRD-PARTY WEBSITE AND APPS
  10. CONTACT US

1. TYPES OF INFORMATION WE COLLECT

We collect two basic types of information from you when you provide it to us or when you use or interact with our Services: personal information and non-personal information.

Personal information includes all information that relates to you personally and either identifies or may be used to identify you personally (collectively, “personal information”). We may collect the following types of personal information from you depending upon the device you are using and how you interact with us or use or interact with our Services, such as your:

  • Contact Information. Name, mailing address, email address, phone number, and other contact information.
  • Demographic Information. Date of birth and gender.
  • Device Information. IP address, browser type and version, browser plug-in types and versions, operating system and platform, device type, and device identifiers.
  • Financial Information. Credit card number, banking information, transactional and financial information, and billing and shipping address.

Non-personal information includes information that does not personally identify you or information that has been anonymized (collectively, “non-personal information”). When we combine non-personal information with personal information, we treat the combined information as personal information.

You can always refuse to provide your information, except that it may prevent you from engaging in our Services or receiving responses to your inquiries or other information of interest.

2. HOW WE COLLECT INFORMATION

We need to collect personal information from you to provide you with our Services and improve your experience. You may provide us with personal information in several ways, including, for example, when you:

  • Visit our website or use our Services;
  • Register for any website account;
  • Correspond with us in any way, including through surveys and promotions;
  • Sign up to receive our newsletter or promotional information;
  • Ask for customer service, support, or other assistance; or
  • Interact with us in any other way, online or offline, including through our Services.

Cookies

Like many websites and apps, we use “cookies,” which are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences and actions. We may also use cookies to monitor traffic, improve our website, and make it easier and/or relevant for your use. Like many websites and apps, we use cookies, web beacons, and similar technologies to record your preferences and track the use of our Services. We use these technologies to:

  • Remind us who you are when you access our Services, which helps us to provide you with services tailored to your specific needs and interests;
  • Determine the browser you are using so our Services work properly;
  • Assist us with sending you notifications;
  • Generate analytics regarding your use of our Services; and
  • Estimate our audience size by determining whether your visit is your first.

You can set your browser or device to refuse all cookies or to indicate when a cookie is being sent. If you delete your cookies or if you set your browser or device to decline these technologies, some Services may not function properly. Our Services do not currently change how they operate upon detecting a Do Not Track or similar signal.

Online Analytics

We also use various types of online analytics, including Google Analytics, a web analytics service provided by Google, Inc. (“Google”), on our Services. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the Services, compile reports on related activities, and provide other website activity and usage services. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor and any referring website. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google, click here.

Offline Interactions and Other Sources

We also may collect personal information from other sources (such as our partners or third-party service providers) or our offline interactions with you to, among other things, enable us to verify or update the information in our records and better customize the Services for you.

Social Media Integration

Our Services may, from time to time, contain links to and from social media platforms. You may choose to connect to us through a social media platform, such as Facebook, LinkedIn or Twitter. When you do, we may collect additional information from you, such as your screen names, profile picture, contact information, contact list, and the profile pictures of your contacts, through the social media platform. Please be advised that social media platforms may also collect information from you. When you click on a social plug-in, such as Facebook’s “Like” button or Twitter’s “Tweet” button, that particular social network’s plugin will be activated, and your browser will directly connect to that provider’s servers. We do not have control over social media platform collection, use, and sharing practices. We encourage you to review their usage and disclosure policies and practices, including the data security practices, before using the social media platforms.

Surveys and Promotions

Occasionally, we may invite you to participate in surveys or other promotions, some of which might be sponsored or conducted by a third party. Participation in these surveys and promotions is completely voluntary. If you choose to participate, we will request your personal information. If a third-party sponsor is involved in the survey or promotion, please review the sponsor’s privacy policy. Please be aware that any sweepstakes, raffles, surveys, or similar promotions we offer may be governed by specific rules and terms and conditions that are separate from and in addition to this Privacy Notice. By participating in any such sweepstakes, raffles, surveys, or similar promotions, you will become subject to those rules, including but not limited to receiving emails containing promotion communications.

3. HOW WE USE INFORMATION

We may use personal information to:

  • provide you with our Services;
  • facilitate your interactions and transactions with us;
  • respond to your requests, communications, suggestions, comments, inquiries, and requests (including your feedback about our Services);
  • administer our relationship with you, including creating and managing your account;
  • maintain and improve our Services;
  • measure performance;
  • develop new products, features, and services;
  • better understand the preferences of our customers;
  • provide personalized Services, including content and ads;
  • provide you with and improve relevant marketing offers or information from us or relevant third parties;
  • facilitate your participation in our surveys and promotions;
  • respond to legally binding requests from law enforcement, regulatory authorities, or other third parties;
  • defend, protect, or enforce our rights or applicable terms of service;
  • to prevent fraud or the recurrence of fraud;
  • assist in the event of an emergency, and
  • comply with applicable law.

We may also combine your personal information collected through various sources, including information collected through our Services, and develop a customer profile that will be used for the purposes above.

We may retain personal information for as long as necessary for business purposes, including for backup, archival, accounting, and/or audit purposes.

We may use personal information to create non-personal information, use non-personal information for any legitimate business purpose, and retain non-personal information for as long as we have a business need to do so.

4. HOW WE SHARE INFORMATION

Except as disclosed in this Privacy Notice, we do not share personal information with companies other than our partners and affiliates and their directors, officers, employees, agents, consultants, advisors, or other representatives. In no event will we sell or rent personal information.

We may share personal information with our third-party service providers, vendors, and business partners to help us:

  • with the uses described in the How We Use Information section above;
  • with our marketing and promotional projects, such as sending you information about products and services you may like and other promotions and
  • comply with your directions or any additional consent you have provided us.

We may share personal information with law enforcement and regulatory authorities or other third parties as required or permitted by law for the purpose of:

  • responding to a subpoena, court order, or other legal processes;
  • defending, protecting, or enforcing our rights;
  • assisting in the event of an emergency, and
  • complying with applicable law.

We may also transfer or assign personal information to third parties due to, or in connection with, a sale, merger, consolidation, change in control, transfer of assets, bankruptcy, reorganization, or liquidation. If we are involved in defending a legal claim, we may disclose information about you that is relevant to the claim to third parties as a result of, or in connection with, the associated legal proceedings.

We share non-personal information with third parties as reasonably necessary to meet our business needs.

5. HOW WE PROTECT INFORMATION

We are concerned about ensuring the security of your personal information. We exercise great care in providing secure transmission of your information from your equipment to our servers. We store personal information that we have collected in secure operating environments. Our security procedures mean that we may occasionally request proof of identity before we disclose your personal information to you. We try our best to safeguard personal information once we receive it. Still, please understand that no data transmission over the Internet or any other public network can be guaranteed 100% secure. If you suspect an unauthorized use or security breach of your information, please contact us as soon as possible at privacy@theclose.com.

6. CHILDREN’S PRIVACY

Our Services are not for children under the age of 13. We do not knowingly collect personal information from children under 13 years of age. Individuals under the age of 13 should only use our Services with the permission and under the supervision of a parent or guardian. Individuals under the age of 13 should not attempt to provide us with any personal information. If you think we have received personal information from children under the age of 13, please contact us immediately at privacy@theclose.com.

7. YOUR CALIFORNIA PRIVACY RIGHTS

We do not share personal information with third parties for their own direct marketing purposes without your consent. In certain circumstances, California residents under 18 years old may request and obtain the removal of personal information or content about you and posted on our Services. Please be mindful that this would not ensure the complete removal of the content posted on our Services by you. To make any request pursuant to California privacy law, please contact us.

8. YOUR CHOICES

We offer you certain choices in connection with our Services.

Access to your personal information

You have the right to request access to the personal information that we collect, use, and disclose about you. You also have the right not to receive discriminatory treatment for exercising your access right. To submit a request, please contact us.

Deleting your personal information

You have the right to request that we delete your personal information, subject to some exceptions. Once we have received and confirmed your request, we will delete (and direct our partners and service providers to delete) your personal information unless an exception applies. You have the right not to receive discriminatory treatment for exercising your deletion right. Please contact us to submit a request or designate an authorized agent to make a request.

Updating your personal information

The accuracy of the information we have about you is very important. You may update your personal information by emailing hi@theclose.com or directly accessing your account and profile information.

Email Communications

You may have the opportunity to receive certain communications from us related to our Services. Provide us with your e-mail address to receive communications. You can opt out of marketing emails anytime by following the instructions at the bottom of our emails and adjusting your email preferences. Please note that certain emails may be necessary to operate our Services. You will continue to receive these emails, if appropriate, even if you unsubscribe from our optional communications.

Cookies/ Beacons

If you wish to minimize information collected by cookies or beacons, you can adjust the settings of your device or browser. You can also set your device or browser to automatically reject any cookies. You may also be able to install plug-ins and add-ins that serve similar functions. However, please be aware that some Services may not work properly. In addition, the offers we provide when you visit us may not be as relevant to you or tailored to your interests.

Network Advertising Initiative

Certain websites you visit may provide options regarding advertisements you receive. If you wish to minimize the amount of targeted advertising you receive, you can opt out of certain network advertising programs through the Network Advertising Initiative (NAI) Opt-Out Page. Please note that even if you remove your information (opt-out), you will still see advertisements while browsing online. However, the advertisements you see may be less relevant to you. For more information or to opt out of certain online behavioral advertising, please visit http://www.aboutads.info.

Additionally, many advertising network programs allow you to view and manage the interest categories that they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The NAI Opt-Out Page provides a tool that identifies its member companies with cookies on your browser and links to those companies.

Do Not Track

Some devices and browsers support a “Do Not Track” (or DNT) feature, a privacy preference that you can set in certain web browsers. This feature is intended to signal to websites and services that you do not wish to be tracked across different websites or online services you visit.

Please note that we cannot control how third-party websites or online services you visit through our website respond to Do Not Track signals. Check the privacy policies of those third parties for information on their privacy practices.

9. THIRD-PARTY WEBSITES AND APPS

The Services may contain links to other websites or apps operated by third parties. Please be advised that the practices described in this Privacy Notice do not apply to information gathered through these third-party websites and apps. We have no control over and are not responsible for the actions and privacy policies of third parties and other websites and apps.

10. CONTACT US

We welcome questions, comments, and feedback on this Privacy Notice and our management of personal information. If you have questions, concerns, or feedback, you can always contact us in the following ways. For your protection, we may need to verify your identity before assisting with your request, such as verifying that the information used to contact us matches the information we have on file.

Email
Mail
355 Lexington Ave – 18th Floor New York, NY 10019

California Consumer Privacy Act Appendix

Please see the chart below to learn more about the categories of personal information we collect, how we collect it, why we collect it, and with whom we share it.

Category
What we collect
How we collect it
Why we collect it
With whom we share it
Identifiers
Name, mailing address, email address, phone number, and other contact information.

Please see the Types of Information We Collect section above for more information.

Collected online or offline when you directly provide it to us, through your use of our Services, or from third parties.
We collect this information for the purposes listed in the How We Use Information section above.
Shared with our affiliates, partners, vendors, and service providers as described in the How We Share Information section above.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Name, mailing address, email address, phone number, contact information, credit card number, banking information, and other financial information.

Please see the Types of Information We Collect section above for more information.

Collected online or offline when you directly provide it to us, through your use of our Services, or from third parties.
We collect this information for the purposes listed in the How We Use Information section above.
Shared with our affiliates, partners, vendors, and service providers as described in the How We Share Information section above.
Protected classification characteristics under California or federal law
Age and gender.

Please see the Types of Information We Collect section above for more information.

Collected online or offline when you directly provide it to us, through your use of our Services, or from third parties.
We collect this information for the purposes listed in the How We Use Information section above.
Shared with our affiliates, partners, vendors, and service providers as described in the How We Share Information section above.
Commercial information
Transactional information, such as the products or services purchased.

Please see the Types of Information We Collect section above for more information.

Collected online or offline when you directly provide it to us, through your use of our Services, or from third parties.
We collect this information for the purposes listed in the How We Use Information section above.
Shared with our affiliates, partners, vendors, and service providers as described in the How We Share Information section above.
Biometric information
Not Collected
N/A
N/A
N/A
Internet or other similar network activity
IP address, browser type, and version, browser plug-in types and versions, operating system and platform, device type, and device identifiers.

Please see the Types of Information We Collect section above for more information.

Collected online or offline when you directly provide it to us, through your use of our Services, or from third parties.
We collect this information for the purposes listed in the How We Use Information section above.
Shared with our affiliates, partners, vendors, and service providers as described in the How We Share Information section above.
Geolocation data
Not collected
N/A
N/A
N/A
Sensory data
When you speak with customer service, we record the conversation.

Please see the Types of Information We Collect section above for more information.

Collected when you directly provide it to us.
We collect this information for the purposes listed in the How We Use Information section above.
Shared with our affiliates, partners, vendors, and service providers as described in the How We Share Information section above.
Professional or employment-related information
Not collected
N/A
N/A
N/A
Non-public education information
Not collected
N/A
N/A
N/A
Inferences drawn from other personal information
The information generated from your use of our Services reflects your preferences.
Collected online or offline when you directly provide it to us, through your use of our Services, or from third parties.
We collect this information for the purposes listed in the How We Use Information section above.
Shared with our affiliates, partners, vendors, and service providers as described in the How We Share Information section above.