Privacy Policy
Privacy and cookies policy

1. Introduction

This Privacy Policy sets out the conditions for the processing and protection of personal data of users of the Closer page (hereinafter “the User“), which is available at (hereinafter “the Website“) and contains information about conditions for using cookies. If you do not accept this Privacy Policy, you are not allowed to use the Website.Capitalized terms that are not defined otherwise in the Privacy Policy shall have the meaning ascribed to them in the Regulations, which sets out the terms of Website use.

2. Who is the Users’ personal data Controller?

The data Controller, i.e. the entity that decides how personal data of Users will be used, is Closer Sp. z o. o. with headquarters at Aleja 3 maja 9, 30-062 Kraków, Poland (hereinafter “Closer“).

4. What type of personal data does the Controller process?

The controller collects ordinary data of Users, who use the services of the Website, in particular registered Users with individual accounts. In order to create an account the User has to provide data enabling performance of the Agreement in accordance with the Regulations, including contact details, in particular email address, name and surname, position telephone number and company details.

5. What is the purpose and legal basis for processing personal data?

a) The legal basis for processing Users’ personal data is their consent collected data processing, collected from the Users during registration on the Website – i.e. art. 6 section 1 point a GDPR.

b) The Controller will use the data provided by the User in the registration form available on the Website to draw up and conclude a contract for the provision of electronic services, which covers the provision of services referred to in the Website Regulations, including, but not limited to, the creation of accounts and the provision of services. This does not exclude the possibility of processing the provided personal data, in particular the email address and telephone number, to ensure contact between you and the data Controller.

c) If the relevant consent was given at the time of completing the registration form or if the relevant option is selected in the account settings, the email address provided by you will be processed by the Controller for the purpose of sending you a free newsletter that will contain commercial information within the meaning of Act on the provision of electronic services. You have the right to withdraw the consent referred to in this document if you do not want to receive such a newsletter.

7. What rights do Users have?

a) You have the right to access your personal data and correct it.

b) You have the right to request the Controller to access personal data, the right to rectify it, delete or limit processing, the right to object to the processing, the right to transfer data, the right to withdraw consent at any time. You can make changes to your personal data by sending an appropriate declaration of will to the Data Controller’s e-mail address, i.e., and if you want to send such a statement in writing, you can send it to the Data Controller’s address: Aleja 3 maja 9, 30-062 Kraków.

c) If you feel that your personal data is being processed by the Controller contrary to legal requirements, you have the right to lodge a complaint with the competent supervisory body (the President of the Office for Personal Data Protection).

d) You have the right to withdraw your consent by sending an email to:

8. For what period do we store Users’ personal data?

Users’ personal data will be stored for the duration of the obligations arising from legal provisions, including in particular:

a) tax and accounting,

b) pursuing claims in connection with the performance of the contract,

c) statistical and archiving purposes,

d) preventing abuse and fraud.

9. Is there an obligation for Users to provide personal data?

Providing personal data by Users is voluntary, but failure to do so will result in the inability to conclude and perform the contract and use of the Website – service. If you post other people’s personal information on the Website, you can do so if you do not violate the rights of such people and you can use them in advance with their consent.

10. Do we transfer Users’ personal data outside the European Economic Area (EEA)?

Users’ personal data will not be transferred outside the EEA or international organizations.

11. Does our Website use cookies?

1. This site uses cookies. Cookies are small information files (data), in particular text files, saved and stored on devices through which the user uses websites, which allows in particular:

a) maintain sessions (after logging in) so that you do not have to re-enter your login and password on each page of the site,

b) adapt and optimize the Website to meet the needs of Website Users,

c) create statistics on the number of page views,d) personalize marketing communication,

e) ensure the security and reliability of operations on the Website.

2. Cookies are stored by the server on your computer. The website uses session cookies, which are deleted after closing the browser window, and persistent cookies that are saved for a specified period of time on the devices through which you use the website.

3. Cookies are not used to collect personal data. Cookies can be deleted using tools in the browser. Cookies do not use computer configuration, are not used to install or uninstall software, and do not interfere with system or data integrity.

12. How to change your browser settings and disable cookies?

As part of cookie settings, the User may decide whether he consents to the use of such cookies or not. During the first visit to the website, information about the use of cookies is displayed to the User. Thanks to a special tool, Users can manage cookies by changing cookie settings from their browser level or delete cookies altogether. Browsers manage cookie settings in different ways. The support menu of the web browser explains how to change cookie settings. Remember that disabling or limiting the use of cookies may cause difficulties in using the Website.

13. What types of cookie files do we use?

We use two types of Cookie files – first-party cookies and third-party cookies. We use our own cookies to ensure the proper functioning of the Website, in particular handling the User’s account, the order process. Third-party cookies – our Website uses functions provided by third parties, which involve the use of cookies from third parties. The data controller reserves the right to use third-party services in the field of compiling statistics on the use of the Website. We ensure that in such a case no data identifying our Users will be provided to such entities. Ads placed on websites may use third-party cookies so that the advertiser can analyze the effectiveness of the advertising campaign. We also use analytical tools and tools such as Hubspot, Google Analytics and Google Tag Manager, Google ads, Microsotf ads, Quora, Capterra, Facebook cookies, Linkedin cookies. The use of third-party cookies is described below.


Cookies collect data on user behavior on our pages. This data is used in analysis and to improve our website. Cookies collect anonymous data, such as the number of visitors to the site, the way they came to the site, and the pages they visited. More information about Hubspot cookies can be found in the Hubspot privacy policy.

Google Analytics

We also use Google Analytics on the website. to analyze user behavior. This tool collects data about cookies. We need them primarily for statistical purposes to check how often individual websites are visited. We also use this data to optimize and develop the website. More information about Google Analytics cookies can be found in the Google Analytics privacy policy.

Google Tag Manager

The website uses Google Tag Manager. This service allows page tags to be managed through the interface. Google Tool Manager only implements tags. This means that no cookies are used and no personal data is collected. Google Tool Manager activates other tags, which in turn collect data when needed. However, Google Tool Manager does not access this data. If the deactivation was done at the domain or cookie level, it remains valid for all tracking tags if they are implemented in Google Tag Manager. More information about GTM cookies can be found in the GTM privacy policy.


This website uses the remarketing function. We use Google ads, Microsoft ads, Quora, Capterra technologies to make our website more interesting. This technology allows you to conduct remarketing activities. Remarketing is used to display Website ads to users who have previously visited the Website while visiting other websites. More information about cookies can be found in the Google ads, Microsoft ads, Quora and Capterra privacy policies.

Social Networks

Our website contains references to social networking sites Facebook, LinkedIn. Only after clicking the corresponding button the data (original page, or username, if logged in to the appropriate service, IP address) will be sent to the platform operator. Information on the collection and use of data can be found in the privacy policy of the relevant platform operator. More information about cookies can be found in the privacy policies of Facebook and LinkedIn.

14. IP address

The data controller reserves the right to collect users’ IP addresses, which can be helpful when it comes to diagnosing technical problems with the server or developing statistical analyzes (e.g. determining which regions most often visit us). In addition, they may also be useful for administering and improving the Website. These data are not associated with specific persons using the website and are not used by us for their identification. The IP address is only auxiliary material used to administer the site, and their content is not disclosed to anyone except persons authorized to administer the server.

15. Security and protection of personal data

The data Controller declares that he processes personal data in accordance with the Act on the protection of personal data and the GDPR and uses technical and organizational measures to ensure the protection of processed data corresponding to the risks and categories of protected data, in particular that he protects personal data against unauthorized access, loss or damage.

16. Contact

Any additional questions concerning the Privacy Policy should be sent to the e-mail address of the Data Controller, i.e.:

17. Amendments to the Privacy Policy

The Data Controller reserves the right to amend the Privacy Policy from time to time. The following date is the date of the latest version of the Privacy Policy: [18th March 2020].