Privacy Policy

1) Scope & Compliance

This Privacy Policy is intended to comply with Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA), and reflects our practices with respect to U.S. customers, including compliance with the California Consumer Privacy Act (CCPA/CPRA) and other applicable U.S. privacy laws. It applies to all users of our Services in Canada and the United States unless otherwise specified.

This Policy applies only to data collected by SmartClose.AI through the Site and Services and does not apply to our privacy practices regarding data we process on behalf of other companies (“Clients”). For information about Client data, please review the relevant Client’s privacy policy.

2) Changes to This Policy

We may update this Policy to reflect changes to our products, Services, or legal requirements. When we post changes, we revise the “Last Updated” date above. Your continued use of the Site or Services after any changes means you accept the updated Policy.

3) Conflicts with Local Laws

Where local laws require a higher level of protection for your Personal Information, those laws take precedence. The specific requirements of this Policy apply when local laws permit.

4) Information We Collect

Personal Information. We may collect information that identifies, relates to, describes, or can reasonably be associated with you (“Personal Information”), including:

• Identifiers (name, mailing address, service address, email, phone number, SmartClose.AI account login information).
• Commercial information (payment card or bank account information; subscribed service type).
• Internet/network activity (browsing and search history on our Site, IP address, cookie data, device IDs, device/OS information).
• Geolocation data (non-precise location indicators from devices/websites).
• Audio, electronic, visual, or similar information (call recordings, chat transcripts, emails, voice AI interactions).
• Professional/employment information (employer, occupation).
• Inferences drawn about your preferences, interests, or behavior.
• Personal information as described in Cal. Civ. Code § 1798.80(e) (for U.S. customers).

Some Personal Information may be considered Sensitive Personal Information under applicable laws (e.g., certain account credentials or precise geolocation if ever collected).

5) Usage Data & Site Activity

We automatically collect information about your interactions with the Site (“Usage Data”), including browser type, device type and ID, operating system, IP address, pages viewed, referring/exit pages, timestamps, clickstream data, and visit duration. If Usage Data can reasonably be linked to you, we treat it as Personal Information.

6) Communication Recordings & AI Interactions

We may record calls and retain the content of text messages, chat transcripts, voice AI interactions, and other written/electronic communications between you and us. By clicking “Accept,” and each time you interact with our AI agent, you consent to the recording, storage, and sharing of your communications with third-party service providers, and as described in this Privacy Policy. If you do not wish to have your conversations recorded, please refrain from using this service.

7) Cookies & Similar Technologies

We use cookies, pixels, SDKs, and similar technologies to operate the Site, remember your preferences, analyze usage, and improve the Services. We also use third-party analytics and, where allowed, advertising tools. For more information, including how to manage your choices, please review our Cookie Policy.

8) How We Use Personal Information

We may use Personal Information to:

• Provide, operate, maintain, and improve the Site and Services.
• Set up and service accounts; process payments.
• Communicate with you (including service, transactional, and marketing messages).
• Perform research, analytics, and measurement.
• Ensure security and integrity; prevent fraud and abuse.
• Comply with applicable laws, regulations, industry standards, and contractual obligations.
• Respond to governmental, regulatory, and legal requests or orders.

9) How We Disclose Personal Information

We may disclose Personal Information in accordance with Canadian and U.S. privacy laws, including:

• Service providers/processors that host, support, analyze, secure, record/transcribe communications (including voice infrastructure providers), process payments, or help deliver the Services.
• Business transfers (e.g., merger, acquisition, financing, or sale of assets).
• Legal compliance and protection (to comply with law; protect rights, safety, and property of SmartClose.AI, users, or others; enforce our terms; detect, prevent, or address fraud, security, or technical issues).

We do not sell or “share” your Personal Information for cross-context behavioral advertising as those terms are defined under the CCPA/CPRA.

We may disclose aggregated or de-identified information that cannot reasonably be used to identify you.

10) International Transfers

We may store and process Personal Information in Canada, the United States, and other countries where we or our service providers maintain facilities. These locations may have privacy laws that differ from those in your jurisdiction. We take steps to protect your information consistent with this Policy and applicable law.

11) Data Retention

We retain Personal Information for as long as necessary to fulfill the purposes described in this Policy, comply with legal and accounting obligations, resolve disputes, and enforce our agreements. Retention periods may vary by data type and use case (e.g., call recordings and transcripts related to AI interactions).

12) Security

We use commercially reasonable administrative, technical, and physical safeguards to protect Personal Information. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

13) Your Privacy Rights (Canada & U.S.)

A. Canada (PIPEDA)

Subject to exceptions, Canadian residents may request access to, correction of, or deletion of Personal Information, and may withdraw consent to processing where consent is the legal basis. You also have the right to complain to the Office of the Privacy Commissioner of Canada (OPC) or your provincial privacy regulator.

B. United States (including California CCPA/CPRA)

Depending on your state, you may have the right to: (i) know/access the categories and specific pieces of Personal Information we collect, use, and disclose; (ii) request deletion; (iii) request correction; (iv) opt out of sales or sharing (we do not sell or share for cross-context behavioral advertising); (v) limit the use and disclosure of Sensitive Personal Information (we use Sensitive Personal Information only for permitted, service-related purposes); and (vi) not be discriminated against for exercising your rights.

C. Submitting Requests & Verification

To exercise your rights, contact us at [email protected]. We will verify your request by reasonably necessary means (e.g., matching information you provide with information already on file). Authorized agents may submit requests where permitted by law, subject to verification of the agent’s authority and your identity.

D. Appeals

Where required by law, you may appeal our decision regarding a privacy request by replying to our response and stating “Appeal.” If you remain unsatisfied, you may contact your regulator.

14) Children’s Privacy

Our Site and Services are not directed to children, and we do not knowingly collect Personal Information from children. If you believe we have collected information from a child, please contact us so we can take appropriate action.

15) Third-Party Sites & Services

The Site may contain links to third-party websites, applications, or services. Their privacy practices are governed by their own policies. We are not responsible for the privacy practices of third parties.

16) Do Not Track

Some browsers offer a “Do Not Track” (DNT) signal. Because there is no common industry standard for DNT, our Site does not respond to DNT at this time.

17) Contact Us

If you have questions or comments about this Privacy Policy or our privacy practices, please contact us at:
[email protected]