Privacy Policy.

1. Introduction

Closr ("Closr", "we", "us", or "our") is committed to protecting the privacy and personal data of individuals whose information we collect and process in the course of our recruitment and talent advisory services. This Privacy Policy explains how we collect, use, disclose, store, and protect personal data, and the rights individuals have in relation to their personal data.

This Privacy Policy applies to individuals in all jurisdictions where Closr operates, including the United States, United Kingdom, European Economic Area (EEA), India, and other regions globally. California residents may refer to the section titled "California Privacy Rights" below.

2. Who This Policy Applies To

We collect and process personal data relating to the following categories of individuals:

• Candidates and prospective candidates
• Client representatives and business contacts
• Website visitors and recipients of our communications
• Employees, contractors, and consultants

3. Personal Data We Collect

Depending on your interaction with Closr, we may collect the following categories of personal data:

Identification and Contact Information

• Name, email address, phone number, postal address
• Nationality, citizenship, place of birth

Professional and Employment Information

• Employment history, CVs, education and qualifications
• Skills, experience, compensation history, benefits information
• References and referee feedback

Recruitment and Compliance Information

• Availability and start dates
• Immigration or work authorization status
• Government-issued identification (where required)
• Criminal background information (only where legally required for a role)

Diversity and Equal Opportunity Data

• Information related to race, ethnicity, gender, disability, or health (collected only where permitted or required by law and handled with strict safeguards)

Website and Communication Data

• IP address, browser type, device information
• Website usage data collected via cookies
• Email interaction data (opens, clicks)

Additional Information

• Information you voluntarily provide to us
• Information provided by clients, referees, or public professional sources (e.g., LinkedIn)

4. How We Collect Personal Data

• Directly from you, when you apply for roles, submit your CV, or contact us
• From third parties, including clients, referees, job boards, and professional networking platforms
• Automatically, through cookies and similar technologies when you visit our website or interact with our emails

5. Why We Collect and Use Personal Data

Closr processes personal data primarily to deliver recruitment and talent advisory services. This includes:

• Identifying, assessing, and presenting candidates to clients
• Managing recruitment processes and candidate pipelines
• Communicating with candidates and clients
• Supporting candidates' career opportunities
• Maintaining business relationships and operational records
• Improving our website, services, and communications
• Complying with legal, regulatory, and contractual obligations

6. Legal Basis for Processing

• Consent
• Performance of a contract or steps prior to entering into a contract
• Legitimate business interests (e.g., recruitment activities)
• Compliance with legal obligations

7. How We Share Personal Data

We may share personal data with:

• Clients and prospective employers for recruitment purposes
• Closr group entities and affiliated companies
• Service providers supporting IT, recruitment operations, or compliance
• Regulatory or legal authorities, where required by law

8. International Data Transfers

Closr operates globally, and personal data may be transferred outside the country in which it was collected, including to the United States, UK, EEA, India, and other jurisdictions. Where required, we implement appropriate safeguards such as:

• Standard Contractual Clauses (SCCs)
• Data processing agreements
• Other lawful transfer mechanisms permitted under applicable law

9. Data Retention

We retain personal data only for as long as necessary to fulfil recruitment and business purposes, comply with legal requirements, or resolve disputes. Retention periods are determined based on applicable laws and legitimate business needs.

10. Your Rights

Depending on your location, you may have the right to:

• Access your personal data
• Request correction or deletion
• Restrict or object to processing
• Withdraw consent (where applicable)
• Request data portability
• Lodge a complaint with a supervisory authority

Requests can be made by contacting us using the details in section 15 below.

11. Data Security

Closr implements appropriate technical and organizational measures to protect personal data against unauthorized access, loss, misuse, or alteration. Access to personal data is restricted to authorized personnel with a legitimate business need.

12. Cookies

Our website uses cookies to improve functionality, analyse traffic, and enhance user experience. You can manage cookie preferences through your browser settings. Disabling cookies may impact website functionality.

13. California Privacy Rights (CCPA/CPRA)

California residents have the right to request disclosure of:

• Categories of personal information collected
• Sources and purposes of collection
• Categories of third parties with whom data is shared
• Specific personal information collected

They may also request deletion of personal data and are protected from discrimination for exercising these rights.

14. Updates to This Policy

We may update this Privacy Policy periodically. Any changes will be posted on this page and, where appropriate, communicated directly.

15. Contact Us

For questions, requests, or concerns regarding this Privacy Policy or your personal data, please contact: