Privacy and Data Policy

Last updated: January 12, 2021

HarkinsHill LLC (“us”, “we”, or “our”) operates the Closing Commander™ mobile application (the “Service”).

This page informs you of our policies regarding the collection, use and disclosure of Personal Information when you use our Website or Service.

We will not use or share your information with anyone except as described in this Privacy Policy.

We use your Personal Information for providing and improving the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Information Collection And Use

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to, your email address, name, phone number, postal address, other information (“Personal Information”).

We collect this information for the purpose of providing the Service, identifying and communicating with you, responding to your requests/inquiries, servicing your purchase orders, and improving our services.

Log Data

When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use and other statistics (“Log Data”).

In addition, we may use third party services such as Google Analytics that collect, monitor and analyze this type of information in order to increase our Service’s functionality. These third party service providers have their own privacy policies addressing how they use such information.

Cookies

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and transferred to your device. We use cookies to collect information in order to improve our services for you.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help feature on most browsers provide information on how to accept cookies, disable cookies or to notify you when receiving a new cookie.

If you do not accept cookies, you may not be able to use some features of our Service and we recommend that you leave them turned on.

Behavioral Remarketing

HarkinsHill LLC uses remarketing services to advertise on third party web sites to you after you visited our Service. We, and our third party vendors, use cookies to inform, optimize and serve ads based on your past visits to our Service.

• GoogleGoogle AdWords remarketing service is provided by Google Inc.You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/adsGoogle also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
• FacebookFacebook remarketing service is provided by Facebook Inc.You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/about/ads/#568137493302217Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

Do Not Track Disclosure

We support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Service Providers

We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services and/or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Information only to perform specific tasks on our behalf and are obligated not to disclose or use your information for any other purpose.

Your Email Account Data

Closing Commander’s use and transfer to any other app of information received from Google Accounts will adhere to Google API Services User Data Policy, including the Limited Use requirements.

In order to provide the service to you, which includes the ability to automatically compose, send, and track emails to your recipients on your behalf, certain email account data is accessed and recorded via the authorized connection to your email provider, established during signup for your Closing Commander™ account. This data is enumerated below:

• Recipient name, email address, and phone number
• Recipient events, including email open, link click, and reply actions
• Recipient email reply content
• Your reply content

This data is collected for you, and in the following limited conditions, may be accessed by Closing Commander and its employees and contractors:

• To solve an issue or perform an action requested directly by you, and with your express permission, through our secure support channels
• To investigate security or abuse, or comply with applicable law.

In addition, for the purposes of improving the service, researching and solving bugs or issues with the Service, this data may be accessed or analyzed in an anonymized, abstracted, aggregated, and non-personally identifiable manner.

We will not share or sell your data with any third party, and will secure such data using reasonable commercial means.

Data Retention

To comply with data retention policies and security guidelines from third-party email services such as Google, Microsoft, and others, we only retain certain data and email content for 15 months before it is removed from our system and backups. This pertains only to our system and backups, and will not remove any original data from your connected email accounts.

You may also manually request deletion of your account and its data using the process described in our Terms of Service.

Communications

We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

Marketing

Our goal as a Service is to help you increase your business success and visibility. We may use your business name and/or company logo in our own marketing materials, identifying you as a user of the Service, but not as an endorsement or testimonial. If you do not wish to be identified as a user of the Service, you may expressly request to be excluded by emailing success@closingcommander.com.

In our user research, we may reach out to you for information about how you are using the Service, and learn if you think it has been successful for you. If you are an exceptional use case, we may ask for permission to use specific details as part of a user case study and testimonial in our marketing. If contacted, you will have the opportunity to accept or decline at that time.

Compliance With Laws

We will disclose your Personal Information where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Service.

Business Transaction

If HarkinsHill LLC is involved in a merger, acquisition or asset sale, your Personal Information may be transferred as a business asset. In such cases, we will provide notice before your Personal Information is transferred and/or becomes subject to a different Privacy Policy.

Security

The security of your Personal Information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure.

However, please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the Personal Information we have collected from you.

International Transfer

Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the information, including Personal Information, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

Only persons age 18 or older have permission to access our Service. Our Service does not address anyone under the age of 13 (“Children”).

We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you learn that your Children have provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a children under age 13 without verification of parental consent, we take steps to remove that information from our servers.

Changes To This Privacy Policy

This Privacy Policy is effective as of June 30, 2017 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

Contact Us

If you have any questions about this Privacy Policy, please contact us.