Terms and conditions of use of the services www.theclosingclub.com (definition below for the sake of brevity the "TUS") define the general conditions of the contract that is stipulated in Italy between TCC SRL, (hereinafter "TCC"), VAT 04602240279, with registered office in Via Baseggio, 9 (VE) ITALY, in person of the Legal pro tempore and the Customer (jointly the "Parties"), identified with the data by filling in the appropriate form registry, which through its Legal Representative or in any case of an authorized attorney to stipulate this TUS in the name and on behalf of the subject, adheres to this TUS (hereinafter, the "Customer")

Preconditions

- TCC is a Startup specialized in IT and software development;
- TCC has developed and designed an online digital platform accessible via the Internet in "Software As A Service" mode (Platform www.theclosingclub.com) which allows the user to access a database (the Database) composed by professionals and in general by people working in the world of corporate finance, and receive prior information about direct contacts;
- The Platform www.theclosingclub.com is a tool reserved for users who undertake to use it exclusively in relation to their professional activity and in any case for needs connected to it;
- In consideration of the premises mentioned above, the Parties agree and stipulate the following TUS for the non-exclusive use of the Platform www.theclosingclub.com;
- The Customer declares to possess the requisites of reliability, organization and capacity necessary to guarantee the execution of the activities considered for the use of the service and to have the means and equipment suitable to carry out independently the activities considered in the agreement.

All this premised the use of the Platform www.theclosingclub.com is regulated by the present TUS that the Customer is bound to respect by accepting to use this service:

- The premises of the TUS, in particular the Conditions of Use constitute an integral and substantial part of the TUS itself.


Section 1. Definitions

In relation to this TUS, the meanings to be attributed to recurring terms and expressions are indicated below:

Activation date: the date communicated by the TCC to the Customer upon activation of the service or subscription to the service following remote online ordering (E-commerce), via an Internet connection;

TUS: indicates the present integrated document from the Conditions of use and the Disclaimer that can be consulted at the links shown above;

Intellectual Property: The term "Intellectual Property" identifies any intellectual property right regulated, from time to time, by patent laws, the protection of semiconductor chips, copyright, trade secrets, trademarks and any other registered and unregistered intellectual property rights, as well as any applications, renewals, extensions, reintroductions and restorations, currently in force or enforceable in the future, worldwide.

Database: these are the databases that TCC has legitimately licensed for themselves and for third parties, and the public databases to which TCC has legitimate access as well as those that it has independently elaborated as data controller and owner.

Partner: An entity, organization, or individual with whom an agreement is established for sharing of information to enhance the service level provided by theclosingclub.com and the visibility of opportunities uploaded by the client on the platform.

Services: these are the services provided by TCC through the website www.theclosingclub.com. and any other instrument prepared by TCC itself or by its partners.


Section 2. Object of the service and terms of use of the platform

2.1 - Object of the Service and License to use the Platform.
The Service www.theclosingclub.com provided by TCC has as its object the right granted to the Customer to access the Databases and to use, within the limits allowed by law, for the duration and under the conditions set out in the Contract, the Services provided. With reference to the object of the Service, the customer declares to know the content and the technical characteristics of the service offered and recognizes it as suitable, in the terms specified in section 6 of these Terms of Use of the service. The TCC, in compliance with the terms and conditions of this TUS, undertakes to provide the Customer with a limited, non-exclusive license to use the Platform www.theclosingclub.com which directly allows the Customer to access a database composed of direct contacts the professional and economic and commercial data relating to companies, to generate lists of business contacts (leads) and receive economic and commercial information relating to the companies themselves. The Customer is aware and expressly accepts that the Platform www.theclosingclub.com is an instrument reserved for professional users, with the consequence that this TUS is not subject to the regulation of consumer contracts. When using the www.theclosingclub.com platform, the customer undertakes to comply with the instructions defined by TCC on the basis of indications in any way deriving from laws, regulations, provisions of Authorities or self-regulatory codes in force in the countries of origin and destination of messages or in the process of transposition to which TCC intends to follow. It is understood that the processing of data related to the use of the platform will be in any case in compliance with current regulations, provided that the customer assumes the role of Data Controller and the impression, using for this purpose of its organizational structure, assumes the role of data controller as better specified in paragraph 2.3 below. Due to the nature and functioning of the Platform www.theclosingclub.com, the Parties acknowledge that, pursuant to and within the limits of the provisions of this TUS, the Customer will directly and autonomously manage the IT tools provided by L 'fingerprint and will be the same Customer, under his sole responsibility, to manage, as Data Controller, the data extracted independently from the Platform www.theclosingclub.com thus defining the purposes of processing such data.

2.2 - Customer access to the platform.
The Customer will have access to the Platform www.theclosingclub.com through an area reserved through authorization and authentication credentials attributed to the Customer, kept and used by them under his sole responsibility. Access to the platform and use of the platform must comply with the provisions of this TUS and in the Terms of Use. In particular, the Customer undertakes to keep the alphanumeric access codes (called "username" and "password") referred to above and therefore also to be kept in the strictest confidence and declares to be aware that the use of the codes is reserved for the subject identified by the Customer as a user. Therefore, it is not allowed to use the same codes by multiple users, and the Customer will therefore be solely responsible for any damage caused by the use of login and password by unauthorized third parties. It is the Client's responsibility to keep the authorization and authentication credentials in an accurate and exclusive manner and to take every precaution to avoid improper use.

2.3 - Processing of personal data.
The TCC undertakes to provide the Customer with all the information and collaboration necessary for the latter to fulfill the obligations of EU Regulation no. 679/2016 (GDPR). In particular, TCC guarantees that the personal data being processed will be kept and checked, also in relation to the knowledge acquired on the basis of technical progress, the nature of the data and the specific characteristics of the treatment, so as to minimize, through the adoption of suitable and preventive security measures, the risks of destruction or loss, even accidental, of the data itself, of unauthorized access or treatment not allowed or not in accordance with the purposes of the collection. The processing of data is done by manual, computerized and telematic tools with logic strictly related to the purposes themselves and, in any case, in such a way as to guarantee the security and confidentiality of the data, in addition to compliance with the specific obligations established by the law. The data are processed in compliance with the principle of lawfulness, correctness, relevance and non-excess, in accordance with the provisions on personal data protection.
TCC if it is found to carry out data processing (whether personal data or data referring to legal entities, bodies, associations or mere general or statistical information contained in documents or processed in databases) of which it is the Client will proceed to the treatment following the instructions given by the Customer who, even through periodic checks previously agreed with the appointed manager, will be able to monitor the timely observance of the provisions of law and contract. In this sense, TCC will provide its officers with all the instructions and procedures in writing required for compliance with the law and the TUS.
TCC is in no way responsible for the data contained in the pdf uploaded to the portal by users.
The designation of the person responsible for the TCC has a duration equal to the duration of the present TUS and will be considered revoked when the TUS is dissolved, for whatever reason this occurs.
Upon termination of the contractual relationship, the customer's personal data and copies thereof will be permanently deleted from the information system of TCC (including any paper archives), subject to legal obligations, as provided for in the subsequent art. 2.7 of this TUS.


2.4 - Consent of the recipients of the messages.
The Customer expressly declares to be aware that, to use the data extracted independently from the Platform www.theclosingclub.com in order to send messages in automated mode, it is necessary to have the consent of the recipients to receive the same messages, except in cases expressly provided for by law where consent is not necessary. The consent collection concerns both the recipients of the messages by e-mail and the recipients of SMS messages. The consent must necessarily present the requirements established by the current legislation and therefore be preventive, expressed, free, informed and referred to specific treatments, this constitutes an essential obligation for the Customer. In case of non-compliance, even for a single time, of this essential obligation, the TCC reserves the right to terminate the TUS pursuant to art. 8.7 of the same and no registration or subscriptionn fee will be returned. It is understood that for a correct use of the data present on the platform www.theclosingclub.com the user is obliged to refer to the additional operational information available at any time at the following link: https://www.theclosingclub.com.io/faq . The Customer is obliged to verify any updating of such operational information that may be changed without prior notice from the TCC according to the organizational requirements and any regulatory changes that may occur.

2.5 - How to delete Customer data.
After 10 (ten) days from the expiry date or the dissolution of the TUS for any reason, TCC will have the right to delete the data stored on behalf of the Customer on the Platform www.theclosingclub.com. These data will be available for consultation and freely downloadable by the Customer within the deadline indicated above using the normal functionality of the Www.theclosingclub.com platform. In case of suspension of access to the Platform for administrative irregularities (see Article 4.2), the Customer will be able to access only after having removed the cause that caused the blockage. Without prejudice to this faculty of cancellation, longer storage times may also be dictated by needs other than those indicated in this TUS, in particular in the event of investigations by the Judicial Police or bodies responsible for possible checks.

2.6 - Customer assistance.
In a purely accessory and instrumental to the use of the Platform www.theclosingclub.com, TCC undertakes to provide the Customer with technical assistance for reports related to the correct functioning of the Platform www.theclosingclub.com in compliance with the provisions of section 5 Guarantee of the minimum level of functionality.


Section 3. Entitlements and Trademarks; Third party licensees

3.1 - Ownership of the Platform www.theclosingclub.com.
TCC SRL has the exclusive license of the platform and all the rights and interests relating to www.theclosingclub.com, including the developments deriving from it.
Unauthorized copying and use and disclosure in violation of intellectual property rights is prohibited.
In particular, the Customer declares to be aware that the data obtained from this service are contained in a protected database pursuant to and for the purposes of copyright law. It is therefore forbidden, inter alia, to reproduce and transfer, in whole or in part, by any means of the aforesaid data.
In any case, the operations of extraction and re-utilization of all or a substantial part of the same database are prohibited, as well as the extraction or reuse of non-substantial parts of its contents if such activities are repeated and systematic.
It is therefore forbidden to practice any automatic data collection (so-called scraper) and it is not allowed to make screenshots of the platform or to make automatic calls using the account assigned to the Customer.
It is understood that all the information that the customer will insert into the platform by integrating, modifying and updating their company cards may be published by TCC, after verification of adequacy with respect to their quality standards and verification of the correctness of the data. Therefore TCC SRL due to the insertion of the data by the customer in the platform, acquires the full intellectual property of the information that will decide to publish and has the right to use without the customer can plead exclusive rights of use on the data themselves.

Section 4. Economic terms and duration of the contract.
With regard to economic terms and contractual duration, except as may be provided for by specific sales conditions, which may be applied by individual distributors www.theclosingclub.com, the provisions set forth in this Section 4 apply.

4.1 - Start, duration and cancellation of the license to use the Platform.
The Service is licensed for the period of one year starting from the moment of activation which coincides with the date of acceptance of the TUS,and the actual collection of the subscription. The contract is automatically renewed for a further year and so from year to year in the absence of termination that the Parties may exercise until the expiration date by sending an email to info@theclosingclub.com. In case of cancellation within the deadline the fee for the renewal of the service will not be due.

4.2 - Fee, billing and payments.
For the provision and use of the Platform www.theclosingclub.com, as well as for the provision and performance of the ancillary and instrumental services provided for in this TUS and for the use of any further options offered by the Platform www. theclosingclub.com, the Customer undertakes to pay a fee in the time and manner indicated in the "Online" order. The provisions of art. 7.1 and 7.2 that follow. Payment can be made by credit card or PayPal, subject to collection. In the event that the Customer fails to pay the fee as agreed above, TCC SRL may, at its sole discretion and at any time, disable the use of the Platform, upon notice to the Customer. After 10 (ten) calendar days without the Customer having made the balance of the agreed amount, the impression will be authorized to block the Client's access to the Platform and / or declare the termination of the contract right pursuant to art. . 8.7 of this TUS and subsequently to delete all the data present, without prejudice to the right of TCC to demand in any case the payment of the entire fee under the TUS. The payment of all sums due to TCC SRL under this TUS can not be delayed or suspended for any reason, even in the presence of pending disputes, being understood - also by way of derogation from art. 1460 of the Civil Code - that the Customer can assert its rights only through a separate procedure and only after full compliance with its obligation to pay the fee. In the case of payment by credit card, the recurring payment method will be activated, which envisages, at the renewal date, the automatic pre-authorized charge of the amount corresponding to the use of the Platform www.theclosingclub.com and the options already activated for a period of the same duration, unless canceled by the customer to exercise with communication expressed in compliance with the procedures and timelines referred to in point 4.1. If the automatic renewal of the TUS the pre-authorized charge is not successful for any reason (as an example and not exhaustive: expired credit card or the necessary funds) this will cause the immediate blocking of the sending functions and the simultaneous notification failure to pay the Customer's Administrative Contacts selected for receiving administrative information. After further 10 (ten) calendar days without the Client having made the payment, the impression may block access to the Platform and / or declare the termination of the contract right pursuant to art. 7.7 of the TUS and proceed to the subsequent cancellation of the Customer's data, without prejudice to the right of TCC SRL to the collection and / or to the final detention of the fees for the entire contractual period. The Parties agree that in the event of delay in payment of the aforesaid fee, default interest will be due pursuant to Legislative Decree no. 231 of 9 October 2002 and subsequent amendments. The fee for the Service www.theclosingclub.com, the related options, the accessory services and assistance may be subject to annual variation from the following renewal. In the event of an increase, TCC will inform the Customer, with advance notice of at least 60 (sixty) days before the chosen expiration date, by e-mail to the Customer's e-mail address used when registering for the service. The new tariffs will be applied from the date of renewal of the TUS and will be maintained unaltered for at least the next contractual period. If the Customer does not intend to accept the new tariffs, he must, pursuant to article 4.1, exercise the cancellation in the terms and modalities envisaged; failure to cancel in the terms set out in this TUS, to be understood as forfeiture, will be considered as unconditional acceptance by the Customer of the new tariffs, which will therefore be legitimately applied from the date of renewal.

Section 5. Guarantee of the minimum level of functionality

5.1 - Availability of the Platform www.theclosingclub.com.
With this TUS TCC is obliged to make available the Platform www.theclosingclub.com with an up-time availability rate of 99%, for 24 hours per day and 365 days a year. The Parties acknowledge that in any case the unavailability of the Platform www.theclosingclub.com can not be attributed to TCC SRL due to facts and circumstances attributable to subjects whose TCC SRL can not be answered, to the Customer or to subjects whose Behavior the Customer is obliged to respond, such as, by way of example and not exhaustively, the availability of a suitable Internet network at the Customer or at TCC SRL, hardware problems, software, networks within the Customer's organizational structure or third party suppliers. It is understood that for its part TCC will take every care based on its availability to ensure the correct use of the Service and ensure the smooth operation of all the functions provided by the Service. In the event that it is necessary to carry out maintenance operations, ordinary and / or extraordinary, in order to ensure the correct access to the service TCC reserves the right to proceed, prior communication to the Customer (ordinary electronic mail), to suspension Temporary services by committing to reactivate you as soon as possible depending on the nature of the maintenance intervention that will be necessary.

5.2 - Customer assistance.
On an instrumental and accessory basis to ensure the correct use and full functionality of the Platform www.theclosingclub.com, TCC undertakes to provide technical assistance for reports on problems related to the proper functioning of the Platform www.theclosingclub.com.

5.3 - List of contacts authorized to request assistance.
Technical assistance by e-mail via Email, referred to in paragraph 5.2 above, will be provided by TCC exclusively through the contacts (Email addresses) previously entered by the Customer in the appropriate section of the Platform www.theclosingclub.com. It will be the exclusive responsibility of the Customer to keep this data constantly updated. TCC will not in any case be held responsible for technical assistance provided as a result of failure / delayed updating or incorrect or negligent completion by the Customer of the aforementioned Contacts.

Section 6. Prohibitions, Obligations, declarations, warranties, liabilities and limitations borne by the Customer.

6.1 - Prohibitions and obligations of the Customer. The customer is obliged to enter into the platform only concrete and real deal data or which he has sent direct. The customer is also required to respond to any requests for information from other members of the club. Otherwise, TCC at its sole discretion can cancel the customer from the platform www.theclosingclub.com notifying the reasons via email to the customer.

6.2. - Guarantee of correctness of customer information. The Customer declares and guarantees:
(i) that all information provided by the Customer to TCC is complete, correct and updated, including the data entered in the appropriate section, available on the Platform www.theclosingclub.com;
(ii) to be entitled to insert and disclose such data, and to authorize TCC to exercise all the rights necessary for the complete execution of this TUS. Nothing in this article is to limit or exclude the liability of any of the Parties for willful misconduct or gross negligence, without prejudice to the exceptions provided for in this TUS.

6.3 - Liability for customer failures. The Client undertakes to keep TCC indemnified and indemnified in full from all damages, losses, liabilities, costs, charges and expenses, including any legal fees, that may be incurred or sustained by TCC or of which the same were subject to payment request, and that would not have been so suffered or incurred or required if (i) the Customer had fulfilled the obligations assumed with the signing of this TUS and (ii) the representations and guarantees given by the Customer with the signing of the present TUS were true, correct, complete and not misleading. The Client also undertakes to keep the indemnity fully protected and free from all damages, losses, liabilities, costs, charges and expenses, including any legal expenses that may be incurred or sustained by TCC or of which the same was the subject of a request for payment, in any case connected to the sending of information contained in the Customer's messages, even in the event of compensation for damages claimed by third parties for any reason whatsoever excluded.

6.4 - Responsibility for using the platform.
The Customer acknowledges and acknowledges that the use of the Platform www.theclosingclub.com will take place, in compliance with this TUS, in full autonomy and that, consequently, the Customer will be exclusively and directly responsible. The Customer undertakes to communicate and let its employees and collaborators, and to all those who will have access to the Platform www.theclosingclub.com under the existing relationship with the Customer, commit to comply with the obligations arising from this TUS, ensuring in any case that they are aware of it and undertaking to do everything possible so that these obligations are promptly observed. TCC and its employees and / or collaborators do not assume any responsibility in relation to the use of the Platform www.theclosingclub.com by the Customer and for this purpose the Customer irrevocably obliges himself, expressly dispensing the third beneficiaries from the burden of declaring wanting to profit, to keep TCC and its employees and collaborators totally harmless or prejudicial, both on a contractual and non-contractual basis, deriving directly or indirectly from the methods of use of the Platform www.theclosingclub.com and of execution of this TUS by the Customer. These provisions remain valid and effective even after the termination of the effects of this TUS, for any reason intervened, including expiry of the terms, termination or withdrawal of the same.

6.5 - Failures due to external events.
TCC will not be held responsible in any way for the malfunctioning of the Platform www.theclosingclub.com or the impossibility or difficulty of performing the ancillary services deriving from the responsibilities of the telephone, electrical, and global and national network operators, by way of example. , but not exhaustive, as a result of failures, overloads, interruptions, etc.

6.6 - Causes of force majeure.
TCC can not be held responsible in any way for the inexecution of this TUS that derive from causes beyond its sphere of reasonable control or from force majeure or fortuitous events, such as, by way of example, non-exhaustive, popular riots , acts of terrorism and war, strikes, riots, tornadoes, hurricanes, floods, fires, landslides and landslides.

6.7 - Interruptions for exceptional events.
TCC is committed to maintaining the efficiency and functionality of the Platform www.theclosingclub.com; if it is forced to interrupt its use for exceptional events or maintenance, it will contain as soon as possible such interruptions or suspensions, providing timely updates to the customer. TCC will define the appropriate access procedures and reserves the right to improve them at any time.

6.8 - Requirements for third parties.
TCC will not be responsible for any behavior or omissions of third parties that affect the operation of the Platform www.theclosingclub.com, including, by way of example and not exhaustively, speeding down or failure of the telephone lines and computers that manage the electronic traffic between the Customer and the Platform www.theclosingclub.com.

6.9 - Third-party services.
In the event that the Customer uses the platform www.theclosingclub.com made available by third parties, including network operators, the following forecasts will apply: TCC allows access to these functionalities, provided that they are subject to to terms, conditions and limitations imposed by the relative suppliers and that in any case TCC will not be responsible for the failure or incorrect operation of the same. In case the third parties change, suspend or stop the provision of these features, TCC may consequently change, suspend or terminate access to these services without notification. Furthermore, TCC will be authorized to suspend the use of the Platform www.theclosingclub.com which is directly dependent on services offered by such third parties. In any case, the faculty for TCC remains, where necessary, to use different suppliers in order to guarantee the functionality of the Platform www.theclosingclub.com. In this regard, the Customer authorizes TCC to provide these third parties with all necessary information.

6.10 - Limitation of liability.
Except in cases of willful misconduct or gross negligence, the eventual responsibility of TCC due to non-fulfillment under this TUS can in no case exceed the amount equal to 20% of the amount paid by the Customer to TCC during the period between the date of the last renewal / expiry of the platform use license, or between the Activation Date if no subsequent renewal / expiry has occurred, and the date on which, under the contract, it was verified for the first time the damage, comparing the periodic fee referred to above proportionally to the aforementioned period, up to a maximum of 12 months.

Section 7. Ownership of data relating to the use of the platform by customers and terms of use of the platform itself

7.1 - Limits on the use of data.
The use of data accessed by the customer through the Service is allowed only for internal use. Therefore, it is not permitted to make data available to third parties, except for express prior written authorization from TCC. In accordance with the prohibitions set forth in section 6 above, in no case is it permitted to the Customer or its partners, to resell and / or to grant free use or in general to make data obtained through the www.theclosingclub.com service accessible.

7.2. - Data generated by use of the Service.
As established between the Parties, TCC holds all rights to the use of statistical information, data and related analyzes in aggregate form, resulting from the use of the Platform www.theclosingclub.com by its Customers. These data in aggregate form do not include personal data and the Customer expressly authorizes TCC to use the same in order to improve the functionality of the Platform www.theclosingclub.com or in order to provide statistical information that can be published in aggregate form.

7.3 - Advertising.
The Customer authorizes the use of TCC of his name and logo in presentations, marketing materials, customer lists, financial reports. Except as provided for in the previous articles 3.1 and 3.2 of this TUS, the use by the Customer of the logo, of the commercial name and of any other distinctive sign relating to the Platform www.theclosingclub.com must be previously requested by the Customer in written and authorized form, always in written form , from TCC.

7.4 - Free Trial.
www.theclosingclub.com can offer free trial periods of the www.theclosingclub.com Platform to new customers.

7.5 - Processing of Customer data.
As far as necessary, provided that according to current personal data legislation is any information relating exclusively to an individual, the Customer acknowledges that TCC will process the data under the current legislation only and exclusively for the performance of services to implement this TUS.

7.6 - Validity of amendments and / or additions.
TCC can unilaterally modify the Terms of Use and the TUS of the user license. Each modification will be effective from the moment in which the new version of the same Terms of Use and / or TUS of use license is accepted online and the subsequent use of the Platform www.theclosingclub.com is to be considered as explicit acceptance of the same modifications and / or additions by the Customer. In the event that the Customer does not intend to accept the changes and / or additions referred to above, the same must communicate it to TCC, which reserves the right to terminate the TUS.
7.7 - Express termination clause.
This TUS will be automatically terminated pursuant to Article 1456 of the Italian Civil Code, with a simple written communication to be sent also by e-mail and / or PEC, in cases of non-fulfillment of the essential obligations contained in articles 2.4 - Consent of recipients messages, 4.2 - Fee, billing and payments. In any case, the right of TCC to demand payment of the fee for the entire agreed period and / or to keep it in full even if not fully used remains in any case. Furthermore, the actions or omissions of the Customer that determine the failure to comply with the prohibitions and obligations set forth in this TUS, such as failure to comply with the limitations on the use of data accessible through the Service, are the cause of express resolution. It is also considered as a serious breach of the contract which gives rise to the immediate termination of the contract by the Customer or by subjects appointed by BOT / scraper or the creation by the Customer of apparent situations that cause confusion between the activities of TCC and of the Customer as well as the re-publication of the data acquired through the Service unless expressly authorized.

7.8 - Validity of the contractual clauses.
The provisions of this TUS are fully in force and accepted by the Customer even in the case of non-burdensome and / or temporary use of the features provided for any purpose by TCC.

7.9 - Tax charges.
Any tax burden deriving from the execution of the TUS, including any taxes for advertising activities, is charged to the Customer.

7.10 - Applicable law and jurisdiction.
This TUS is regulated and interpreted according to the Italian law, and the Parties expressly agree that for any dispute regarding the validity, effectiveness, interpretation and execution of this TUS will be submitted to the exclusive jurisdiction of the Court of Venezia in compliance with current legislation.

7.11 - Final clauses.
This TUS, repeals and replaces any agreement, understanding, negotiation, written or oral, possibly intervened previously between the Parties and concerning the object referred to in this TUS. The fact that one of the Parties does not promptly assert the rights granted to him by one or more clauses of this TUS, can never be understood as a general and tacit renunciation of the rights and duties in the established clause, nor will it prevent that party from claiming subsequently the punctual and rigorous observance of every and every contractual clause. Should one or more of the clauses referred to in this TUS be declared null or ineffective by the competent court, the remaining TUS will continue to have validity between the Parties, unless such clause constituted a decisive motive in the conclusion of this contract.

OUR COMMITMENT TO YOU

At The Closing Club, your privacy is a top priority. Your privacy is at the core of the way we design and build the services and products you know and love, so that you can fully trust them and focus on building meaningful connections.

We appreciate that you put your trust in us when you provide us with your information and we do not take this lightly.

We do not compromise with your privacy. We design all of our products and services with your privacy in mind. We involve experts from various fields, including legal, security, engineering, product design and others to make sure that no decision is taken without respect for your privacy.

We strive to be transparent in the way we process your data. Because we use many of the same online services you do, we know that insufficient information and overly complicated language are common issues in privacy policies. We take the exact opposite approach: we have written our Privacy Policy and related documents in plain language. We actually want you to read our policies and understand our privacy practices!

We work hard to keep your information secure We have teams dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your information.


PRIVACY POLICY

Welcome to The Closing Club's Privacy Policy. Thank you for taking the time to read it.

We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.

This Privacy Policy applies beginning Sep 10, 2018. The previous version of this Privacy Policy, available here, will apply until then.

EFFECTIVE DATE: September 10, 2018

1. WHO WE ARE
2. WHERE THIS PRIVACY POLICY APPLIES
3. INFORMATION WE COLLECT
4. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES
5. HOW WE USE INFORMATION
6. HOW WE SHARE INFORMATION
7. CROSS-BORDER DATA TRANSFERS
8. YOUR RIGHTS
9. RESIDENTS OF CALIFORNIA
10. HOW WE PROTECT YOUR INFORMATION
11. HOW LONG WE RETAIN YOUR INFORMATION
12. CHILDREN'S PRIVACY
13. PRIVACY POLICY CHANGES
14. HOW TO CONTACT US

1. WHO WE ARE
The company that is responsible for your information under this Privacy Policy (the "data controller") is:

TCC SRL
Via Baseggio 9
30174 Venezia
Italy


2. WHERE THIS PRIVACY POLICY APPLIES
This Privacy Policy applies to websites, apps, events and other services operated by The Closing Club. For simplicity, we refer to all of these as our "services" in this Privacy Policy. To make it extra clear, we've added links to this Privacy Policy on all applicable services.

Some services may require their own unique privacy policy. If a particular service has its own privacy policy, then that policy -- not this Privacy Policy -- applies.

3. INFORMATION WE COLLECT
It goes without saying, we can't help you develop meaningful connections without some information about you, such as basic profile details and the types of people you'd like to meet. We also collect information generated as you use our services, for example access logs, as well as information from third parties, like when you access our services through a social media account. If you want additional info, we go into more detail below.

Information you give us
You choose to give us certain information when using our services. This includes:

When you create an account, you provide us with at least your login credentials, as well as some basic details necessary for the service to work.
When you complete your profile, you can share with us additional information, such as interests. Some of the information you choose to provide us may be considered "special" or "sensitive" in certain jurisdictions, by choosing to provide this information, you consent to our processing of that information.
When you subscribe to a paid service or make a purchase directly from us (rather than through a platform such as iOS or Android), you provide us or our payment service provider with information, such as your debit or credit card number or other financial information.
When you participate in surveys or focus groups, you give us your insights into our products and services, responses to our questions and testimonials.
When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.
If you contact our customer care team, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.
If you ask us to communicate with or otherwise process information of other people, we collect the information about others that you give us in order to complete your request.
Information we receive from others
In addition to the information you provide us directly, we receive information about you from others, including:

Other Users
Other users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you.

Social Media
You may be able to use your social media login (such as Facebook Login) to create and log into your The Closing Club account. This saves you from having to remember yet another user name and password and allows you to share some information from your social media account with us.

Other Partners
We may receive info about you from our partners, for instance where The Closing Club ads are published on a partner's websites and platforms.

Information collected when you use our services
When you use our services, we collect information about which features you've used, how you've used them and the devices you use to access our services. See below for more details:

Usage Information
We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you've been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive).

Device information
We collect information from and about the device(s) you use to access our services, including:

hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google's AAID and Apple's IDFA, both of which are randomly generated numbers that you can reset by going into your device' settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address);
information on your wireless and mobile network connection, like your service provider and signal strength;
information on device sensors such as accelerometers, gyroscopes and compasses.
Other information with your consent
If you give us permission, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you're using, including GPS, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren't using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it.
Similarly, if you consent, we may collect your photos and videos (for instance, if you want to publish a photo, video or streaming on the services).

4. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES
We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s). You may read our Cookie Policy for more information on why we use them (such as authenticating you, remembering your preferences and settings, analyzing site traffic and trends, delivering and measuring the effectiveness of advertising campaigns, allowing you to use social features) and how you can better control their use, through your browser settings and other tools.

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a "Do Not Track" ("DNT") feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser's user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including The Closing Club, do not currently respond to DNT signals.

5. HOW WE USE INFORMATION
The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.

To administer your account and provide our services to you
Create and manage your account
Provide you with customer support and respond to your requests
Complete your transactions
Communicate with you about our services, including order management and billing
To help you connect with other users
Analyze your profile and that of other users to recommend meaningful connections
Show users' profiles to one another
To ensure a consistent experience across your devices
Link the various devices you use so that you can enjoy a consistent experience of our services on all of them. We do this by linking devices and browser data, such as when you log into your account on different devices or by using partial or full IP address, browser version and similar data about your devices to help identify and link them.
To provide new The Closing Club services to you
Register you and display your profile on new The Closing Club features and apps
Administer your account on these new features and apps
To serve you relevant offers and ads
Administer sweepstakes, contests, discounts or other offers
Develop, display and track content and advertising tailored to your interests on our services and other sites
Communicate with you by email, phone, social media or mobile device about products or services that we think may interest you
To improve our services and develop new ones
Administer focus groups and surveys
Conduct research and analysis of users' behavior to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users' behavior)
Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).
To prevent, detect and fight fraud or other illegal or unauthorized activities
Address ongoing or alleged misbehavior on and off-platform
Perform data analysis to better understand and design countermeasures against these activities
Retain data related to fraudulent activities to prevent against recurrences
To ensure legal compliance
Comply with legal requirements
Assist law enforcement
Enforce or exercise our rights, for example our Terms
To process your information as described above, we rely on the following legal bases:

Provide our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us.
Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users' behavior on our services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection and other legal purposes.
Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

6. HOW WE SHARE INFORMATION
Since our goal is to help you make meaningful connections, the main sharing of users' information is, of course, with other users. We also share some users' information with service providers and partners who assist us in operating the services and in some cases, legal authorities. Read on for more details about how your information is shared with others.

With other users
You share information with other users (and in the case of any sharing features available on The Closing Club, the individuals or apps with whom a The Closing Club user may choose to share you with) when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is stuff that you're comfortable being publically viewable since neither you nor we can control what others do with your information once you share it.

We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations.

We may also share information with partners who distribute and assist us in advertising our services.

We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations.

For corporate transactions
We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

When required by law
We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

To enforce legal rights
We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

With your consent or at your request
We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.

We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources. More information on our use of cookies and similar technologies can be found in our Cookie Policy

7. CROSS-BORDER DATA TRANSFERS
Sharing of information laid out in Section 6 sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. As an example, where the service allows for users to be located in the European Economic Area ("EEA"), their personal information is transferred to countries outside of the EEA. We use standard contract clauses approved by the European Commission or other suitable safeguard to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data

8. YOUR RIGHTS
We want you to be in control of your information, so we have provided you with the following tools:

Access / Update tools in the service. Tools and account settings that help you to access, rectify or delete information that you provided to us and that's associated with your account directly within the service. If you have any question on those tools and settings, please contact our customer care team for help here.
Device permissions. Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.
Deletion. You can delete your account by using the corresponding functionality directly on the service.
We want you to be aware of your privacy rights. Here are a few key points to remember:

Reviewing your information. Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or variations of those terms). You can request a copy of your personal information by putting in such a request here.
Updating your information. If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us here.
For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.

Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. If you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service, the other user will have to contact our Privacy Officer to provide their written consent before the information is released.

Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth.

Accountability. In certain countries, including in the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.

10. HOW WE PROTECT YOUR INFORMATION
We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.

We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.

We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately

11. HOW LONG WE RETAIN YOUR INFORMATION
We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Section 5) and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of three months following account deletion. During this period, account information will be retained although the account will of course not be visible on the services anymore.

In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window) or after five years of continuous inactivity, unless:

we must keep it to comply with applicable law (for instance, some "traffic data" is kept for one year to comply with statutory data retention obligations);
we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years);
there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.
Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.

12. CHILDREN'S PRIVACY
Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available through the service.

13. PRIVACY POLICY CHANGES
Because we're always looking for new and innovative ways to help you build meaningful connections, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.

14. HOW TO CONTACT US
If you have questions about this Privacy Policy, here's how you can reach us:

By post:
TCC SRL
Via Baseggio 9
30174 Venezia
Italy




Cookie Policy

Introduction

The Closing Club is committed to protecting your privacy. We aim to provide trustworthy, industry-leading products and services so that you can focus on building meaningful connections. Our approach to privacy is to provide you with clear information about our data practices. That's why we've tried to keep legal and technical jargon to a minimum.

This Cookie Policy explains what cookies are, what types of cookies are placed on your device when you visit our website and how we use them.

This Cookie Policy does not address how we deal with your personal information generally. To learn more about how we process your personal information, please see our Privacy Policy here.

What are cookies?

Cookies are small text files that are sent to or accessed from your web browser or your device's memory. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the "lifetime" of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your device, such as user settings, browsing history and activities conducted while using our services.

Are there different types of cookies?

First-party and third-party cookies

There are first-party cookies and third-party cookies. First-party cookies are placed on your device directly by us. For example, we use first-party cookies to adapt our website to your browser's language preferences and to better understand your use of our website. Third-party cookies are placed on your device by our partners and service providers. For example, we use third-party cookies to measure user numbers on our website or to enable you to share content with others across social media platforms.

Session and persistent cookies

There are session cookies and persistent cookies. Session cookies only last until you close your browser. We use session cookies for a variety of reasons, including to learn more about your use of our website during one single browser session and to help you to use our website more efficiently. Persistent cookies have a longer lifespan and aren't automatically deleted when you close your browser. These types of cookies are primarily used to help you quickly sign-in to our website again and for analytical purposes.

What about other tracking technologies, like web beacons?

Other technologies such as web beacons (also calls pixel tags or clear gifs), tracking URLs or software development kits (SDKs) are used for similar purposes. Web beacons are tiny graphics files that contain a unique identifier that enable us to recognise when someone has visited our service or opened an e-mail that we have sent them. Tracking URLs are custom generated links that help us understand where the traffic to our webpages comes from. SDKs are small pieces of code included in apps, which function like cookies and web beacons.

For simplicity, we also refer to these technologies as "cookies" in this Cookie Policy.

What do we use cookies for?

Like most providers of online services, we use cookies to provide, secure and improve our services, including by remembering your preferences, recognizing you when you visit our website and personalizing and tailoring ads to your interests. To accomplish these purposes, we also may link information from cookies with other personal information we hold about you.

When you visit our website, some or all of the following types of cookies may be set on your device.

Cookie type

Description

Essential website cookies

These cookies are strictly necessary to provide you with services available through our website and to use some of its features, such as access to secure areas.

Analytics cookies

These cookies help us understand how our website is being used, how effective marketing campaigns are, and help us customize and improve our websites for you.

Advertising cookies

These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, selecting advertisements that are based on your interests and measuring the number of ads displayed and their performance, such as how many people clicked on a given ad.

Social networking cookies

These cookies are used to enable you to share pages and content that you find interesting on our website through third-party social networking and other websites. These cookies may also be used for advertising purposes too.

How can you control cookies?

There are several cookie management options available to you. Please note that changes you make to your cookie preferences may make browsing our website a less satisfying experience. In some cases, you may even find yourself unable to use all or part of our site.

Browser and devices controls

Some web browsers provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer. The procedure for managing cookies is slightly different for each internet browser. You can check the specific steps in your particular browser help menu.

You also may be able to reset device identifiers by activating the appropriate setting on your mobile device. The procedure for managing device identifiers is slightly different for each device. You can check the specific steps in the help or settings menu of your particular device.

Interest-based advertising tools

You can opt out of seeing online interest-based advertising from participating companies through the Digital Advertising Alliance, the Interactive Digital Advertising Alliance or Appchoices (apps only).

Opting out does not mean you will not see advertising - it means you won't see personalized advertising from the companies that participate in the opt-out programs. Also, if you delete cookies on your device after you opted out, you will need to opt-out again.

Social Cookies

To allow you to share content on social media, some features of this website use social media plug-ins (e.g., Twitter(tm) "Share to Twitter" or LinkedIn(tm) "in" buttons). Depending on your social media account settings, we automatically receive information from the social media platform when you use the corresponding button on our website.

To learn more about social media cookies, we suggest you refer to your social media platform's cookie policy and privacy policy.

Adobe Flash Player(tm) Flash cookies

Adobe Flash Player(tm) is an application for viewing and interacting with dynamic content using the Flash platform. Flash (and similar applications) use a technology akin to cookies to memorize parameters, preferences and uses of this content. However, Adobe Flash Player manages this information and your choices via an interface separate from that supplied by your browser.

If your terminal is likely to display content developed using the Flash platform, we suggest you access your Flash cookie management tools directly via https://www.adobe.com.

Google(tm) Cookies

Stuff Google Wants to Make Sure You Know about Google's Data Collection Technology

Google(tm) Maps API Cookies

Some features of our website and some The Closing Club services rely on the use of Google(tm) Maps API Cookies. Such cookies will be stored on your device.

When browsing this website and using the services relying on Google(tm) Maps API cookies, you consent to the storage, collection of such cookies on your device and to the access, usage and sharing by Google of the data collected thereby.

Google(tm) manages the information and your choices pertaining to Google(tm) Maps API Cookies via an interface separate from that supplied by your browser. For more information, please see https://www.google.com/policies/technologies/cookies/.

Google Analytics

We use Google Analytics, which is a Google service that uses cookies and other data collection technologies to collect information about your use of the website and services in order to report website trends.

You can opt out of Google Analytics by visiting www.google.com/settings/ads or by downloading the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout.

How to contact us?

If you have questions about this Cookie Policy, here's how you can reach us:


tccstaff@theclosingclub.com
By post:
TCC SRL
Via Baseggio 9
30174 Venezia
Italy