Draft to review — pending legal review before publication. This text is a structured first draft and is not legal advice. Bracketed items [ ] are decisions still to be made.
LAST UPDATED · [DATE] · VERSION [X]Draft

Privacy Policy

What we collect

Account details (name, email), onboarding answers, learning progress, quiz and exercise answers, AI simulation transcripts and evaluations, payment status (we never store card numbers — handled by [payment provider]), device and usage data, marketing attribution (UTM parameters, ad click identifiers where lawful), and business contact details for B2B inquiries.

Voice & transcripts

During simulations, your voice is processed in real time by our voice provider (OpenAI — GPT-Live or the Realtime API — or Vapi, depending on the engine in use) to generate the conversation and a transcript. We store transcripts to generate reports. When the GPT-Live engine runs with recording on, OpenAI keeps the call audio (your voice and the AI's, on separate channels) for 30 days; we download it once, right after the call, to produce an accurate transcript, and we don't keep the audio ourselves. With recording off, or on the other engines, no audio is kept.

How we use data

To provide and personalize training, score simulations, issue certificates, review network applications, provide support, prevent abuse, measure marketing performance, and comply with law.

Network applicants

If you apply to the closer network, we use your academy results and application to evaluate you. With your consent, we may share a professional profile (not your contact details unless agreed) with prospective business clients.

Sharing

Service providers (hosting, database, voice AI, language models, email, analytics, payments, video hosting) under contract; business clients only as described above; authorities when legally required. We do not sell personal information [confirm CCPA/CPRA position].

Cookies & tracking

We use necessary cookies and, with consent where required, analytics and advertising pixels (e.g. Meta Pixel / Conversions API). See Cookie Policy.

Retention

[Account data: duration of account + X; transcripts: X months; payment records: as required for accounting.]

Your rights

Access, correction, deletion, export, and opting out of marketing. US state rights (e.g. California) as applicable. Request via Settings → Privacy & data or [privacy@closedy.com].

Security

Encryption in transit, access controls, role-based permissions, audit logging, MFA for administrators.

Children

Not intended for anyone under 18.

Contact

[privacy@closedy.com · address]

AI & Recording Notice

  • In every simulation you are speaking with an artificial intelligence, not a human. This is stated before each call.
  • Your voice is processed in real time to generate the AI's responses and a transcript.
  • Transcripts are stored to create your performance report and improve scoring quality.
  • With the GPT-Live engine and recording on, the call audio is kept for 30 days by our voice provider, OpenAI, and used once to re-transcribe the call accurately; Closedy never stores the audio. Otherwise, no audio is kept.
  • Only you, and authorized Closedy staff for quality review or support, can access your transcripts.
  • AI prospects are fictional. Any resemblance to real people is coincidental.
  • [Two-party consent considerations for any real-call recording in the managed sales service — counsel review.]
LEGAL REVIEW REQUIRED BEFORE PUBLICATION

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