Closing Folders Privacy Notice

Date: 23 July 2019

This Privacy Notice describes how we collect, use and otherwise process your personal information when you use our website ( or our platform. We are continually evolving our products and services, which may require changes to this Privacy Notice. Please check back frequently for changes. We will provide a summary of any changes at the end of this Privacy Notice.

This Privacy Notice does apply to data that our customers upload to and use within the Closing Folders platform, such as information that is contained in legal transaction documentation. Our customers control that data and use our services to process their legal transaction documentation. The privacy policy of our customer applies to that data.

Personal Information We Collect

We collect personal information from the following sources:

  • information you provide to us when you subscribe to or purchase our services, register or attend an event hosted by or sponsored by Closing Folders, complete a support ticket, questionnaire, or communicate with us by phone, email or in person
  • information that we collect automatically when you use our website or our platform or interact with our marketing messages, such as the date of access or interaction, your IP address, device information used to access our website or platform, the location of your device, and usage metrics. We may collect some of this information through third party cookies. Please see Cookies, Pixels and Similar Technologies
  • information we collect from other sources, such as our customers if they make a referral, co-sponsors or co-hosts of events that you have registered for or attended and permitted your information to be shared with us, and third parties that assist us with marketing, sales generation and recruitment

Depending on how you interact with us and what services you use, we might collect the following types of information:

  • contact information, such as your name, email address, mailing address, and phone number
  • marketing preferences, and how you interacted with our marketing messages
  • information about your colleagues at your company and other information about your company, including organizational jurisdiction and tax identifiers
  • the services you have used, subscription purchase history, billing history, payment history, and payment information, such as credit card or bank account information
  • information in your inquiries, support tickets, and other communications with us
  • authentication credentials and assigned role-based-access settings to use our services
  • information about the device used to connect to our website or platform, the IP address used to connect to the internet, and your internet service provider
  • browsing history on our site and usage history on our platform

Why We Collect, Use and Retain Your Information

We use your information to provide you with our products and services, to manage our business operations, and to innovate. For example, we use your information in order to:

  • provide you with the platform services and manage and process billing and payments
  • measure and analyze the use of our services to troubleshoot errors, provide support, improve and develop our services, and personalize our products
  • communicate with you about our services and your support requests
  • promote our services and make recommendations
  • detect and prevent fraud and enforce our policies and legal rights
  • comply with our legal obligations such as to maintain auditable tax records
  • We retain your personal information in accordance with applicable laws. We may retain your personal information for as long as it is required for the purposes for which it was collected. We may also retain your personal information to comply with legal requirements such as for tax and accounting purposes or to enforce our legal rights.

Your Rights and Choices

Subject to applicable law, you have the right to:

  • request that we advise you whether we hold personal information about you and allow you to access that personal information
  • request corrections to the personal information we hold
  • withdraw consent or request the deletion of personal information that is no longer necessary for the purposes for which we collected it
  • make a complaint to us about our personal information handling if you believe we have not complied with our legal obligations
  • You may exercise any of these rights by contacting the Closing Folders Privacy Officer at: [email protected].

Security of Your Personal Information

We use administrative, technical and physical measures to safeguard your personal information against unauthorized access, unauthorized disclosure, theft and misuse. This includes limiting access of employees to, and the use of, your personal information through the use of passwords and graduated levels of clearance.

We do not publish all of our security measures online because this may reduce their effectiveness. We educate our employees with respect to their obligations to protect your personal information and we use contractual and other means to manage our third-party service providers so that your personal information has comparable protections when it is in their custody.

Although we take precautions against possible breaches of our security systems, no company can fully eliminate the risks of unauthorized access to your personal information.

Use of Third-Party Service Providers

We use third parties who assist us in our operations, including cloud-based service providers located in Canada, the United States and other regions who provide us with cloud computing infrastructure, customer relationship management systems, customer feedback, cloud-based ticket systems and cloud-based email/push notification systems.

When We May Disclose Your Personal Information

We may also disclose your personal information if it is necessary for us to collect a debt from you or where we have reason to believe that it is relevant to the investigation or decision to investigate a breach of the laws of Canada, a province or territory of Canada, or a foreign jurisdiction, and we are legally permitted to do so.

We may transfer any information we have about you in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of our business or as part of a corporate reorganization or stock sale or other change in corporate control.

Subject to applicable law, we will disclose personal information without your knowledge or consent if we receive an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of your personal information.

Special Information for the European Economic Area

This section only applies to visitors to our website and users of our platform who are located in the European Economic Area.

Legal Basis. Our legal basis to collect, use and otherwise process your personal information are:

  • To provide you with the service that you have requested, including performing our agreement with you if you have subscribed for our platform or have been invited to participate on the platform by one of our customers
  • For legitimate business interests such as to manage our relationship with you and improve your customer service experiences
  • For optional or secondary uses of your personal information, with your consent

International Transfers. When we transfer your personal information outside of the European Economic Area, we may do so in accordance with the adequacy decision of the European Commission with respect to Canada or pursuant to data transfer agreements that incorporate the Standard Contractual Clauses approved by the European Commission.

Cookies, Pixels and Similar Technologies

We use cookies, pixels and similar technologies to recognize your browser or device as you interact with our website and use our online services. In addition, we use the following cookies provided by our third-party partners.


Cookie Type Partner Purpose
Default Google Analytics Web analytics and customer journey analysis to improve the site based on where, when and what our customers use on website. Deleting or disabling these cookies will not limit the functionality of the site.
Default Matomo (formerly Piwik) Web analytics when customers log into the platform or Zendesk. Used for site analytics. Deleting or disabling these cookies will not limit the functionality of the site.


We may also use cookies and similar technologies to track referrals from our LinkedIn or Google Adwords advertisements. You can control how LinkedIn uses your information for advertising by adjusting your advertising preferences in your account. To learn more about Google Adwords and how you can opt-out, visit About Google Ads.

How to Contact Us

If you have a privacy question or concern, please contact us at: [email protected].