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CLOS Inc. — Privacy Policy

Last updated: April 22, 2026

Effective date: April 22, 2026

This Privacy Policy explains how CLOS Inc. ("CLOS," "we," "us," or "our") collects, uses, shares, and protects personal information when you use our Services, including:

By using the Services, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use the Services.

1. Who We Are (Data Controller)

The data controller responsible for your personal information is:

CLOS Inc.
447 Broadway, 2nd Floor, #557
New York, NY 10013
United States
Email: privacy@clos.vc

2. Information We Collect

We collect the following categories of information:

2.1 Information you provide directly:

2.2 Payment information:

When you purchase a paid plan, payment is processed by our third-party payment processors — primarily Stripe, Inc. on the web, and Apple or Google for in-app purchases. These processors collect and handle your payment card number, expiration date, CVV, and billing address directly. CLOS does NOT receive, store, or have access to your full payment card number. We receive only limited information such as card brand, last four digits, expiration month/year, and billing country, which we use to manage your subscription and prevent fraud.

2.3 Information collected automatically:

2.4 Information from third parties:

3. How We Use Information

We use personal information to:

Legal bases (for users in the EEA, UK, and Switzerland): we rely on (a) performance of a contract with you; (b) our legitimate interests in operating and securing the Services; (c) your consent (which you may withdraw at any time); and (d) compliance with legal obligations.

4. How We Share Information

We do not sell your personal information. We share it only as follows:

4.1 Service providers (processors). We share information with vendors who help us run the Services under contracts that require them to protect your data and use it only for the services we request. These include:

4.2 Other users. If you invite another user to a virtual room, or if a shoot includes multiple participants, those participants will see your username, profile photo, and the content shared in that session.

4.3 Legal and safety. We may disclose information if we believe in good faith that disclosure is necessary to comply with law, respond to valid legal process, enforce our Terms, protect the safety of any person, or address fraud or security concerns.

4.4 Business transfers. If we are involved in a merger, acquisition, financing, or sale of assets, your information may be transferred to the acquiring party, subject to this Privacy Policy.

4.5 With your consent. We may share information in other ways with your explicit consent.

5. International Data Transfers

We are headquartered in the United States. Your information may be transferred to, stored in, and processed in the United States and other countries where our service providers operate. These countries may have data protection laws different from those in your country.

For transfers from the EEA, UK, or Switzerland to countries not deemed to provide an adequate level of protection, we use appropriate safeguards, including the European Commission's Standard Contractual Clauses or equivalent mechanisms.

6. Data Retention

We retain personal information for as long as necessary to provide the Services and for legitimate business or legal purposes:

7. Security

We use commercially reasonable technical and organizational measures to protect personal information, including encryption in transit (TLS), encryption at rest for stored content, access controls, and regular security reviews. No system is 100% secure, and we cannot guarantee absolute security. Please protect your password and notify us at security@clos.vc if you suspect unauthorized access.

8. Your Rights

Depending on where you live, you may have the following rights regarding your personal information:

To exercise any of these rights, email privacy@clos.vc. We will respond within the timeframe required by applicable law (typically 30 days). You may also lodge a complaint with your local data protection authority.

8.1 California residents (CCPA/CPRA). You have the right to know what personal information we collect, to delete it, to correct it, and to opt out of "sale" or "sharing" of personal information. We do not sell or share your personal information as those terms are defined under California law. To exercise your rights, email privacy@clos.vc.

8.2 Authorized agents. You may designate an authorized agent to make a request on your behalf. We will require verification of the agent's authority.

9. Cookies and Tracking

Our websites use cookies and similar technologies to:

You can control cookies through your browser settings. Disabling essential cookies may prevent parts of the Services from working correctly. Where required by law, we will ask for your consent before setting non-essential cookies.

10. Children

The Services are not directed to children under the age of 13 (or 16 in the EEA/UK). We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, email privacy@clos.vc and we will delete it promptly.

11. Third-Party Links

The Services may contain links to third-party websites or services. This Privacy Policy does not apply to those third parties. Please review their privacy policies before providing them with your information.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If the changes are material, we will notify you by email or through the Services at least 30 days before they take effect. The "Last updated" date at the top shows when this policy was last revised.

13. Contact Us

For privacy questions, requests, or complaints:

Email: privacy@clos.vc

Security issues: security@clos.vc

General support: support@clos.vc

CLOS Inc.
447 Broadway, 2nd Floor, #557
New York, NY 10013
United States