This is a translation provided for convenience. The French version prevails in case of discrepancy.

Data processing agreement (DPA)

Last updated October 18, 2026.

This agreement is the appendix of the terms of use. It applies as soon as a workspace is created, with nothing to do. If your company needs a signed copy, write to contact@clozer.club.

For prospect data, the Customer is the controller and Clozer its processor. This appendix forms part of the terms.

Subject matter and duration

Clozer processes the data needed to track the documents sent by the Customer (identity and contact details of recipients, reading data, approximate location, device, messages, voice comments, replies), for as long as the service is used. The data subjects are the recipients of the links.

Instructions

Clozer processes this data only on the Customer's instructions, as set out in these terms and in their settings. If an instruction appears to us to infringe the GDPR, we inform the Customer.

Confidentiality and security

• Authorized personnel at Clozer are bound by confidentiality.
• Encrypted communications, documents stored with private access, IP addresses kept only as a hash, encrypted secrets, workspaces isolated from one another.
• Automatic deletion of reading data 12 months after a link's last activity.

Sub-processors

The Customer authorizes the providers listed on the subprocessors page. We notify them 30 days before any addition; they may object and, failing agreement, terminate. Each provider is bound by obligations equivalent to these.

Data subject rights

The Customer handles requests from their prospects, using the export and deletion available in Settings › Data. If a request reaches us directly, we forward it to them without delay.

Data breaches

We notify the Customer of any personal data breach affecting them as soon as possible and no later than 48 hours after becoming aware of it, with the information needed for their own notification to the CNIL.

Assistance and audit

We assist the Customer, to a reasonable extent, with their impact assessments and their dealings with the CNIL, and make available to them the information needed to demonstrate compliance with this agreement.

End of processing

When the workspace is deleted, the data is erased, files included. The Customer can export it beforehand. Only the data we are required by law to keep remains.

Security measures are detailed on the security page. Questions: contact@clozer.club.