Closer Health LTD Customer Privacy Notice
At Closer, we take your privacy seriously. We want to assure you that we will never sell or share your personal information regarding your cycle, symptoms, productivity, or any other sensitive data with individuals, organizations, or employers, neither now nor in the future. We prioritize confidentiality, and you can trust that we will never provide any information that could identify you. This privacy notice tells you what to expect us to do with your personal information.
Contact Details
Post: Entrepreneurship Lounge, Bright Building, University of Bradford, Bradford, West Yorkshire, BD7 1DB, GB
Email: support@closer.health
What Information We Collect, Use, and Why
To Provide Services, we collect your:
- Health information (menstrual health data)
- Racial or ethnic origin
- Payment details (including card or bank information for transfers and direct debits)
- Website user information (including user journeys and cookie tracking)
For Service Updates or Marketing Purposes, we collect your:
- Location data
- Email address
For Research Purposes Consented by you, we collect your:
- Location data
- Health information (menstrual health data)
Lawful Bases
Our lawful bases for collecting or using personal information to provide services and goods are:
- Consent
- Legitimate Interest:
- Personalized Cycle Tracking and Predictions: To offer accurate cycle tracking and predictions, helping users manage symptoms and avoid surprises.
- Symptom Management and Recommendations: To provide tailored recommendations for managing menstrual-related issues.
- Health Monitoring and Early Detection: To monitor changes in menstrual health for early detection of potential health issues.
- Educational Insights and Empowerment: To offer relevant educational content, empowering users with knowledge about their own bodies.
Our lawful bases for collecting or using personal information for service updates or marketing purposes are:
- Consent
- Legitimate Interest: To allow users to manage their accounts, renew passwords, and add an extra layer of data protection.
Our lawful bases for collecting or using personal information for research or archiving purposes are:
- Consent
Where We Get Personal Information From
- People Directly
Closer does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13 years of age. If we discover that a child under 13 has provided us with personal information, we will delete this from our servers immediately. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we can take necessary actions.
How Long We Keep Information
We retain your personal data only for as long as necessary to provide you with the services you have requested and for legitimate and essential business purposes, such as maintaining the performance of our services, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. After deleting your account, we DO NOT retain or transfer your data, ALL YOUR DATA IS DELETED.
Retention Periods:
- Account Data: We’re not obligated by law to retain your data after account deletion so immediately your account is deleted, we completely delete your data on our database..
- Health Data: Data deletion includes your health data you’ve provided on Closer while you’re a user. We do not retain or transfer your data for any reason at all.
You have the right to request the deletion of your data at any time. Please login to you account, go to ‘profile’, then scroll down and click on ‘delete’. Once you delete your account, you cannot access your data again.
Who We Share Information With
Others We Share Personal Information With:
- Academic and health care researchers (only anonymized data and with user consent)
We only share anonymized data for research purposes if the user gives consent. This allows us to understand menstrual trends and provide evidence for women’s health. We might transfer this data internationally outside of the United Kingdom and Europe, ensuring compliance with GDPR.
Adherence to Local Data Laws
Closer adheres to the data protection laws of the country in which it operates. We ensure compliance with local regulations to protect your personal information.
Use for Understanding Ovulatory Phase
While Closer may be used to understand users’ ovulatory phases, it is not designed for fertility purposes. Consequently, Closer will not accept or process any legal requests related to fertility or abortion laws in jurisdictions where abortion is illegal.
Your Data Protection Rights
Under data protection law, including the General Data Protection Regulation (GDPR), you have rights including:
- Your right of access: You have the right to ask us for copies of your personal data.
- Your right to rectification: You have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure: You have the right to ask us to erase your personal data in certain circumstances.
- Your right to restriction of processing: You have the right to ask us to restrict the processing of your personal data in certain circumstances.
- Your right to object to processing: You have the right to object to the processing of your personal data in certain circumstances.
- Your right to data portability: You have the right to ask that we transfer the personal data you gave us to another organization, or to you, in certain circumstances.
- Your right to withdraw consent: When we use consent as our lawful basis you have the right to withdraw your consent.
You don’t usually need to pay a fee to exercise your rights. If you make a request, we have one calendar month to respond to you. To make a data protection rights request, please contact us using the contact details at the top of this privacy notice or email at hello@closer.health.
How to Complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice. If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address: Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint
Last updated: 30 June 2024
