Last updated: 15 April 2026
CLOS ("CLOS", "we", "us") is the data controller for personal data collected through the CLOS web application at clos.coach and the CLOS Chrome Extension (together, the "Service"). You can contact us at info@clos.coach.
Account data. Email address, name, authentication tokens, subscription and billing status.
Usage data. Deal notes, sales scripts, cold-call prospects and logs you create in the app, coaching session metadata (duration, call type, XP, streaks), and diagnostic logs.
Live coaching audio (Chrome Extension and Live Coaching page). While a coaching session is active, your microphone audio is streamed to our speech-to-text provider (Deepgram) and transcribed in real time. Transcripts are sent to our coaching API solely to generate suggestions. Live-session audio and transcripts are not stored on our servers after the session ends — only short-term session metadata (duration, stage, scores) is retained.
Film Room recordings (opt-in). If you choose to record a call using the "Film Room" feature, the resulting audio/video file is stored in our Supabase storage bucket under your account so you can review it and generate AI analysis. Recordings remain stored until you delete them, or until your account is deleted. Film Room is entirely opt-in — no recording is ever uploaded unless you start it.
Cookies & analytics. We use essential cookies (session/auth), PostHog for product analytics, and Sentry for error tracking. See section 7.
We process your personal data on the following legal bases: (a) performance of a contract — to deliver the Service you've subscribed to; (b) legitimate interest — to secure, debug and improve the Service; (c) consent — for non-essential cookies, for starting the microphone on live coaching, and for uploading Film Room recordings; and (d) legal obligation — to comply with tax, accounting and law-enforcement requests.
To provide real-time coaching; to render your deals, scripts and cold-call data back to you; to bill you; to send service emails (password resets, receipts); to secure the Service against abuse; to produce anonymised, aggregated statistics about product usage. We do not sell your data, and we do not use your call content to train public AI models.
We share data with the following providers strictly to deliver the Service:
All sub-processors are bound by data-processing agreements. Where processors are outside the UK/EEA, transfers are protected by Standard Contractual Clauses (SCCs) or the UK International Data Transfer Addendum.
Account data is retained while your account is active and for up to 90 days after deletion to allow recovery from accidental deletion. Billing records are retained for 7 years for tax purposes. Live-session transcripts are not retained. Film Room recordings are retained until you delete them or your account is deleted. Rate-limit and security logs are retained for 30 days.
We use (a) strictly necessary cookies for authentication and CSRF protection — these cannot be disabled; (b) analytics cookies (PostHog) and error tracking (Sentry) — controlled via the cookie banner shown on first visit. We do not use advertising or tracking cookies.
Under UK/EU GDPR you have the right to: access a copy of your personal data; rectify inaccurate data; erase your data; restrict or object to processing; data portability; and withdraw consent at any time. Under the California Consumer Privacy Act (CCPA), California residents additionally have the right to know, delete, correct, and opt out of any "sale" or "sharing" of personal information — CLOS does not sell or share personal information.
To exercise any right, email info@clos.coach or use the "Delete account" action in Settings. We will respond within 30 days. If you are unhappy with our response, you have the right to lodge a complaint with the UK Information Commissioner's Office at ico.org.uk or your local EU/EEA supervisory authority.
Call recording laws vary by country and state. The UK, Ireland, Canada, Australia and 11 US states require all-party consent before recording. When you start a live coaching session or Film Room recording, you are shown a consent notice and are responsible for obtaining consent from all parties on the call as required by your jurisdiction. CLOS cannot and does not verify that consent has been obtained.
Data is encrypted in transit (TLS 1.2+) and at rest (AES-256 on Supabase). Access to production systems is restricted to authorised staff and protected by multi-factor authentication. Row-Level Security is enforced on every database table to ensure you can only read your own data. In the unlikely event of a personal-data breach affecting your rights and freedoms, we will notify affected users and the ICO within 72 hours.
CLOS is not directed at children. You must be at least 18 years old to use the Service.
We may update this policy. Material changes will be notified by email or in-app banner at least 14 days before they take effect.
Questions about privacy? Email info@clos.coach.