Privacy Policy

1. Introduction

Clozer CRM (Pty) Ltd ("Company", "we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our Clozer CRM service ("Service"). This policy complies with the Protection of Personal Information Act (POPIA) of South Africa.

2. Information We Collect

2.1 Information You Provide

• Account Information: Name, email address, phone number, and password when you register
• Profile Information: Agency name, professional details, and preferences
• Property Listings: Property details, images, and descriptions you upload
• Lead Data: Information about leads captured through your AI chatbot
• Payment Information: Billing details processed through our secure payment provider
• Communications: Messages you send through the Service or to our support team
• AI Training Data: Custom preferences and questions you configure for your AI assistant

2.2 Information Collected Automatically

• Usage Data: How you interact with the Service, features used, and actions taken
• Device Information: Browser type, operating system, device identifiers
• Log Data: IP address, access times, pages viewed, and referring URLs
• Cookies and Similar Technologies: Information collected through cookies and analytics tools

2.3 Information from Third Parties

• Google OAuth: If you sign in with Google, we receive your name, email, and profile picture
• WhatsApp Business API: Message data when you use WhatsApp integration
• Email Providers: Lead information parsed from connected email accounts

3. How We Use Your Information

We use your personal information for the following purposes:

• Provide the Service: Operate and maintain your account, process lead qualifications, and deliver AI chatbot functionality
• Communication: Send SMS and email notifications about qualified leads, account updates, and service announcements
• Improve the Service: Analyze usage patterns to enhance features and user experience
• AI Training: Improve our AI models using aggregated, anonymized data
• Security: Detect, prevent, and address fraud, abuse, and security issues
• Legal Compliance: Comply with legal obligations and respond to lawful requests
• Customer Support: Respond to your inquiries and provide technical assistance

4. Legal Basis for Processing (POPIA)

Under POPIA, we process your personal information based on:

• Consent: Where you have given explicit consent for specific processing activities
• Contract: Processing necessary to perform our contract with you (providing the Service)
• Legal Obligation: Processing required to comply with South African law
• Legitimate Interest: Processing necessary for our legitimate business interests, balanced against your rights

5. Information Sharing and Disclosure

We may share your information with:

• Service Providers: Third-party vendors who assist in operating our Service (hosting, payment processing, analytics, SMS/email delivery)
• Business Transfers: In connection with a merger, acquisition, or sale of assets
• Legal Requirements: When required by law, court order, or government request
• Protection of Rights: To protect our rights, privacy, safety, or property

We do not sell your personal information to third parties.

6. Data Security

We implement appropriate technical and organizational measures to protect your personal information, including:

• Encryption of data in transit (TLS/SSL) and at rest
• Secure authentication mechanisms including OAuth 2.0
• Regular security assessments and penetration testing
• Access controls and employee training on data protection
• Incident response procedures for data breaches

While we strive to protect your information, no method of transmission over the Internet is 100% secure. We cannot guarantee absolute security.

7. Data Retention

We retain your personal information for as long as your account is active or as needed to provide the Service. After account closure, we may retain certain information for up to 5 years for legal, accounting, or compliance purposes. Aggregated, anonymized data may be retained indefinitely for analytics purposes.

8. Your Rights Under POPIA

Under POPIA, you have the right to:

• Access: Request a copy of your personal information we hold
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information (subject to legal retention requirements)
• Object: Object to processing of your personal information for direct marketing
• Withdraw Consent: Withdraw consent where processing is based on consent
• Data Portability: Request your data in a structured, commonly used format
• Lodge a Complaint: File a complaint with the Information Regulator of South Africa

To exercise these rights, contact us at privacy@clozercrm.com. We will respond within 30 days.

9. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Keep you signed in to your account
• Remember your preferences and settings
• Analyze how you use the Service
• Improve performance and user experience

You can control cookies through your browser settings. Disabling certain cookies may affect Service functionality.

10. Third-Party Services

Our Service integrates with third-party services including:

• Google: For authentication (Google OAuth)
• WhatsApp Business API: For messaging integration
• SMS Providers: For sending lead notifications
• Analytics Services: For usage analysis

These services have their own privacy policies. We encourage you to review them.

11. International Data Transfers

Your information may be transferred to and processed in countries outside South Africa. We ensure appropriate safeguards are in place, including standard contractual clauses, to protect your information in compliance with POPIA.

12. Children's Privacy

Our Service is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child, we will delete it promptly.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on this page and updating the "Last updated" date. We encourage you to review this policy periodically.

14. Contact Us

For privacy-related inquiries or to exercise your rights, contact our Information Officer:

You may also lodge a complaint with the Information Regulator of South Africa:
Website: www.justice.gov.za/inforeg/
Email: complaints.IR@justice.gov.za