Closedata
Privacy Policy
Last updated: 17 August 2026
This Privacy Policy describes how Closedata processes personal data in connection with the website closedata.co, the Closedata platform and the business information databases it makes available, in accordance with Regulation (EU) 2016/679 (GDPR) and Portuguese Law no. 58/2019 of 8 August.
Controller: Summer Agreement, Lda, the company that operates the Closedata brand and platform ("Closedata"), corporate tax number 518 817 717, with registered office in Lisbon, Portugal.
Data protection contact: legal@closedata.co. Data Protection Officer (where appointed): legal@closedata.co.
1. Who this applies to
This Policy applies to the following data subjects:
- visitors to and users of the website;
- people who request demos or information, or who contact Closedata;
- users of the Closedata platform acting on behalf of clients;
- data subjects whose professional information appears in the business information databases made available through the platform, in particular board members, partners, shareholders and company contact persons.
2. Categories of personal data processed
- Browsing data: IP address, device identifiers, usage data and cookies.
- Contact and commercial data: name, email address, company, job title, phone number and the content of communications.
- Platform user data: access credentials, activity logs and usage preferences.
- Third-party data in the business information databases: name, role or function, shareholding, estimated age, association with companies and professional contact details (email, phone and public professional profiles).
3. Purposes and legal bases
| Purpose | Description | Legal basis (GDPR) |
|---|---|---|
| Demo and contact requests | Responding to and following up on requests and enquiries | Pre-contractual steps and legitimate interests, Art. 6(1)(b) and (f) |
| Commercial communications | Sending information about products and services | Consent or legitimate interests, Art. 6(1)(a) and (f) |
| Service provision to clients | Making the platform available and operating it | Performance of a contract, Art. 6(1)(b) |
| Business information databases | Building and providing information about companies and the people responsible for them | Legitimate interests, Art. 6(1)(f) |
| Security and fraud prevention | Protecting systems and information | Legitimate interests, Art. 6(1)(f) |
| Compliance with legal obligations | Accounting, tax and other obligations | Legal obligation, Art. 6(1)(c) |
| Website analytics | Measuring and improving the experience | Consent, Art. 6(1)(a) |
4. Processing based on legitimate interests
A significant part of the processing, in particular building and providing information about companies and the people responsible for them, is based on the legitimate interest of Closedata and its clients in access to reliable business information. It concerns professional data and not the private sphere of data subjects.
Closedata balances that legitimate interest against the rights and freedoms of data subjects, adopting minimization and safeguard measures. Data subjects may object to this processing at any time, as described in section 9.
5. Source of the data
Personal data is collected directly from data subjects (for example, through the website forms) and obtained from external sources, in particular registries and public sources, licensed data providers such as Informa D&B, and web and press sources. Wherever applicable, the platform indicates the source and the date of the information presented.
6. Recipients and processors
Closedata may use service providers that process personal data on its behalf, subject to contractual confidentiality and security obligations, in particular in the following categories:
- hosting and technology infrastructure;
- email, communication and customer relationship management (CRM);
- analytics and usage measurement;
- data providers and information enrichment.
The list of processors is available on request to the data protection contact. Data may also be disclosed to public authorities where legally required. Closedata does not sell personal data.
7. International transfers
Whenever processing involves transferring data outside the European Economic Area, Closedata ensures that appropriate safeguards are in place under the GDPR, in particular adequacy decisions or standard contractual clauses. Further information is available through the data protection contact.
8. Retention periods
- Lead data and commercial communications: until consent is withdrawn or three years after the last contact.
- Client and contract data: for the duration of the contractual relationship and for the applicable legal periods, including tax periods.
- Browsing records and logs: for the period strictly necessary and no longer than twelve months, unless a legal obligation applies.
- Business information database data: for as long as it remains relevant to the purpose, kept continuously up to date.
9. Rights of data subjects
Data subjects may exercise, under the GDPR, their rights of access, rectification, erasure, restriction of processing, portability and objection, and may withdraw consent at any time, without affecting the lawfulness of processing carried out beforehand.
The right to object to processing based on legitimate interests is particularly relevant, including the right to object to direct marketing communications, which may be exercised at any time.
These rights may be exercised through legal@closedata.co. Closedata responds within the legally prescribed period. Data subjects may also lodge a complaint with the Portuguese Data Protection Authority (CNPD).
10. Profiling and automated decisions
The platform generates classifications and signals, including the Deal Score and succession signals, which result from a deterministic methodology applied to available data. These elements support client decision making and do not constitute decisions based solely on automated processing that produce legal effects or similarly significant effects for data subjects. The final decision always rests with the client, with human involvement.
Personal data of data subjects and client data are not used to train third-party public models.
11. Security
Closedata adopts technical and organizational measures appropriate to protect personal data against loss, disclosure, alteration or unauthorized access, including access control, encryption where applicable and system monitoring.
12. Cookies
The use of cookies and equivalent technologies is governed by the Cookie Policy.
13. Minors
The website and the platform are aimed at professionals and not at minors, and data relating to minors is not intentionally collected.
14. Changes
This Policy may be updated at any time, and the version in force takes effect upon publication. The date of the last update appears at the top of this document.