Privacy Policy

Last updated: 2 October 2026

Closen is a trading name of Roberto Gambarana, Via Belvedere 5, 22029 Uggiate con Ronago (CO), Italy. VAT number: IT04046350130. We decide how and why your personal data is used, which makes us the data controller.

Write to us at privacy@closen.co — or hello@closen.co, it reaches the same inbox.

What you give us when you buy. Your name, email address, and the billing country and postcode Stripe needs to process the payment.

Your payment details go straight to Stripe. We never see or store your card number.

What we collect when you visit. Your IP address, browser and device type, the pages you look at, and how you got here.

What you write to us. Anything in an email you send us, for as long as we keep the thread.

Taking your order, charging you, and sending your files — because that's what we agreed when you bought. Legal basis: performance of a contract.

Answering your emails and handling refunds — the same, and to run the business properly. Legal basis: contract, and our legitimate interests.

Asking how the workbook is going, a week and a month after you buy — to learn what works and what to change. Legal basis: our legitimate interests.

Quoting what you write to us, only if you say yes, with your first name and last initial — to show new customers what real customers say. Legal basis: your consent, which you can withdraw at any time.

Keeping sales and tax records — Italian law requires it. Legal basis: legal obligation.

Measuring our advertising — to see whether people who click our ads go on to buy, and to show the ads to people the workbook suits. Legal basis: your consent, given in our cookie banner. You can withdraw it at any time.

Keeping the site up and safe — to stop fraud and abuse. Legal basis: our legitimate interests.

We use a small number of companies to run the business. They act on our instructions and cannot use your data for themselves — except Meta, explained below.

Systeme.io (France) — the website, the checkout, our customer records, and the emails we send you.

Stripe (Ireland and the United States) — payments.

Cookiebot by Usercentrics (Denmark) — shows the cookie banner and remembers your choice.

Meta Platforms Ireland (Ireland, with processing also in the United States) — advertising measurement, only if you say yes in our cookie banner. If you do, Meta's pixel tells Meta which of our pages you visit and whether you buy, along with identifiers from your browser. For collecting that information and sending it to Meta, Meta and we are joint controllers. We have an agreement with Meta, its Controller Addendum, that sets out who does what: we give you this information, and Meta handles your rights over the data it keeps afterwards. What Meta does with it after that is Meta's responsibility, explained in Meta's privacy policy (facebook.com/privacy/policy), and you can exercise your rights directly with Meta. If you say no, nothing is sent.

Microsoft (Ireland and the United States) — our email inbox.

We do not sell your personal data.

We are in Italy. Some of the companies above process data in the United States. Those transfers are covered either by the European Commission's adequacy decision for the EU–US Data Privacy Framework or by Standard Contractual Clauses. If you want the detail for a specific provider, ask us.

Order and tax records: ten years. Italian tax law sets that, and we cannot shorten it.

Emails you send us: two years after the last message in the thread.

Quotes you've let us use, and the email where you said yes: for as long as we use the quote. Ask us and we'll take yours down.

Your email address for marketing: until you unsubscribe. After that we keep the address on a short suppression list, so that we don't email you again by accident.

Advertising and measurement identifiers: as set out in our Cookie Policy.

You can ask us to show you the data we hold, correct it, delete it, stop using it, or send it to you in a portable form. You can object to us using it, and you can withdraw consent at any time — withdrawing it doesn't undo what we did before.

Write to privacy@closen.co. We answer within 30 days, and there's no charge.

If you think we've got it wrong, you can complain to a regulator. Ours is the Italian Garante per la protezione dei dati personali (garanteprivacy.it). If you're in the UK it's the Information Commissioner's Office (ico.org.uk). If you're elsewhere in the EEA, your national authority will take the complaint.

In the last twelve months we have collected identifiers (name, email, IP address), commercial information (what you bought), and internet activity (pages you looked at). We collect it for the reasons listed above.

We do not sell personal information. If you say yes to advertising cookies, we share identifiers and the pages you visit with Meta to measure our ads, and under California law that counts as sharing for cross-context behavioural advertising. You can say no in the banner, change your mind at any time from our Cookie Policy page, or write to privacy@closen.co.

You can also ask us what we hold, ask us to delete it, or ask us to correct it. We won't treat you differently for asking.

Closen is for adults. We don't knowingly collect data from anyone under 18. If you think we have, tell us and we'll delete it.

When we change this policy we change the date at the top. If the change matters, we'll say so by email to anyone it affects.