Privacy Policy
Introduction
iCloser Ltd. ("iCloser," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform and services.
We comply with the Colorado Privacy Act (CPA), the General Data Protection Regulation (GDPR), and other applicable privacy laws. This policy applies to all users of our services, regardless of location.
Information We Collect
Personal Information
- Identity Information: Name, date of birth, government-issued ID numbers, photographs
- Contact Information: Email address, phone number, mailing address
- Financial Information: Bank account details, payment card information, transaction history
- KYC/AML Data: Identity verification documents, source of funds documentation
Technical Information
- Device identifiers and IP addresses
- Browser type and operating system
- Usage data and interaction patterns
- Cookies and similar tracking technologies
Sensitive Personal Data
We may collect sensitive personal data only with your explicit consent, including:
- Biometric data for identity verification
- Government identification numbers
Biometric Data Protection (Colorado HB24-1130)
Effective July 1, 2025, we comply with Colorado's enhanced biometric data protections under House Bill 24-1130. When we collect biometric identifiers (such as fingerprints, facial recognition data, or voiceprints), we:
- Obtain your informed, written consent before collection
- Clearly disclose the specific purpose and duration of collection
- Maintain a publicly available retention schedule and destruction policy
- Permanently destroy biometric data within 3 years of last interaction or upon request
- Never sell, lease, or trade biometric data to third parties
- Store biometric data using industry-standard security measures
You may withdraw your consent for biometric data processing at any time by contacting privacy@icloser.xyz.
Your Privacy Rights (Colorado Privacy Act)
Under the Colorado Privacy Act (CPA), Colorado residents have the following rights:
Right to Access
Confirm whether we process your data and access your personal data
Right to Correct
Correct inaccuracies in your personal data
Right to Delete
Request deletion of your personal data
Right to Portability
Obtain a copy of your data in a portable format
Right to Opt-Out
Opt out of targeted advertising and data sales
Right to Appeal
Appeal our decision regarding your privacy request
Universal Opt-Out Mechanism: We honor Global Privacy Control (GPC) signals. If your browser sends a GPC signal, we will treat it as a valid opt-out request for the sale of personal data and targeted advertising.
Response Time: We will respond to your privacy requests within 45 days. If we need additional time, we will notify you of the extension and the reason.
Minor Privacy Protections (CPA Amendment 2025)
Effective October 1, 2025, we implement enhanced protections for users under 18 years of age, including:
- Prohibition on processing personal data for targeted advertising without consent
- Prohibition on selling personal data of minors
- Default opt-out settings for profiling activities
How We Use Your Information
- Provide, maintain, and improve our services
- Process transactions and send related information
- Verify your identity and comply with KYC/AML requirements
- Detect and prevent fraud, unauthorized access, and other illegal activities
- Communicate with you about products, services, and promotional offers
- Comply with legal obligations and regulatory requirements
Data Protection Assessments
In compliance with the Colorado Privacy Act, we conduct and document Data Protection Assessments (DPAs) for processing activities that present a heightened risk of harm to consumers, including:
- Targeted advertising activities
- Sale of personal data
- Processing for profiling that may result in legal or significant effects
- Processing of sensitive data, including biometric identifiers
These assessments evaluate the benefits of processing against potential risks to consumer privacy and are made available to the Colorado Attorney General upon request.
Data Sharing and Disclosure
We may share your information with:
- Service Providers: Third parties who perform services on our behalf
- Financial Partners: Banking partners for card issuance and payment processing
- Regulatory Authorities: When required by law or to comply with legal obligations
- Business Transfers: In connection with mergers, acquisitions, or asset sales
We do not sell your personal information to third parties for monetary consideration.
Data Security
We implement industry-standard security measures to protect your personal information, including:
- 256-bit AES encryption for data at rest
- TLS 1.3 encryption for data in transit
- Multi-factor authentication
- Regular security audits and penetration testing
- SOC 2 Type II compliance
Data Retention
We retain your personal information for as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required by law. For financial records, we typically retain data for 7 years to comply with regulatory requirements.
International Data Transfers
Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place for such transfers, including Standard Contractual Clauses approved by relevant authorities.
Children's Privacy
Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we learn that we have collected personal information from a child, we will take steps to delete such information.
Contact Us & Appeals
To exercise your privacy rights or if you have questions about this policy:
Appeals Process
If you are not satisfied with our response to your privacy request, you may appeal by contacting us at appeals@icloser.xyz. We will respond to your appeal within 45 days.
If you are still not satisfied after the appeals process, you may contact the Colorado Attorney General:
Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the "Last Updated" date. Your continued use of our services after such modifications constitutes your acknowledgment of the modified policy.