Data processing agreement

Roles

For the subscriber and contact lists a customer imports into Closed Loop Enrich or connects from its email platform, the customer is the controller and Closed Loop is the processor (GDPR Art. 28). These terms apply to that processing; they are part of the agreement for every Enrich workspace.

Subject matter, nature and purpose

Matching the customer’s contacts to public professional profiles and company websites, deriving professional fields, grading the contacts against the customer’s own rubric, and writing fields and segments back to the customer’s email platform when the customer asks. Processing lasts as long as the workspace exists.

Data subjects and personal data

• Data subjects: the subscribers and contacts on the lists the customer imports or connects.
• Personal data: email address, the columns the customer imports (for example a name or a country), engagement from the email platform (open and click rates), and the derived fields (company, industry, company size, job title, seniority band, job function, country and the public profile link, grade and reasons).
• No special categories of data. The customer must not import them.

Instructions

Closed Loop processes the data only to run what the customer starts in its workspace, and for no purpose of its own. It does not sell the data, does not combine it into a people database across customers, and keeps contacts in the EU, the EEA and the UK to company-level fields unless the customer records a documented legitimate-interest basis.

Confidentiality and security

• Every table is scoped to its workspace by row-level security; members of other workspaces cannot read it.
• Data is encrypted in transit (TLS) and at rest. Provider keys a customer saves are sealed with a server-side key and never shown again.
• People at Closed Loop access a workspace’s data only to answer the customer’s own support request, and are bound by confidentiality.
• Logs carry hashes and ids, never email addresses or keys.

Sub-processors

The customer authorises the sub-processors on the Sub-processors page. Each is bound by data protection terms at least as protective as these. A change is listed there, with its date, before it takes effect.

Helping with requests

Closed Loop helps the customer answer data subjects: the public remove-me form stops enrichment of an address for every customer and deletes what was derived from it; in Settings → Privacy the customer’s owners and admins delete one person from every list at once (with the lookup answers, grades and write-back log about them, and optionally a suppression for good), and an owner deletes all of the workspace’s Enrich data; anything else goes to privacy@getclosedloop.io, answered within 30 days.

Retention and deletion

Raw lookup answers are reduced to company, seniority band, job function and country after 30 days. Derived fields stay until the customer deletes the person or all its Enrich data (Settings → Privacy), or the person asks to be removed. Each deletion is logged with who asked and when, never with the address. Database backups age out on the hosting provider’s schedule.

Breaches, transfers and audits

• Closed Loop tells the customer about a personal data breach affecting its workspace without undue delay after becoming aware of it, with what is known and what is being done.
• Transfers outside the EU, the EEA and the UK use the European Commission’s Standard Contractual Clauses (2021/914, module 2 controller to processor, module 3 processor to processor) and the UK Addendum.
• On request Closed Loop gives the customer the information needed to show these terms are met.