Privacy Policy

Closen is a trading name of Roberto Gambarana, Via Belvedere 5, 22029 Uggiate con Ronago (CO), Italy. 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.

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

Measuring our advertising, once we start running it — to find the people the workbook suits. Legal basis: your consent, which we'll ask for in a banner first.

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.

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

Stripe (Ireland and the United States) — payments.

Meta Platforms (Ireland and the United States) — advertising measurement. We aren't sending them anything today, and we won't until you've agreed to it in a banner.

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.

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, and we are not currently sharing it with anyone for advertising. When we start advertising, we'll share identifiers with Meta so that we can measure it, and under California law that counts as sharing for cross-context behavioural advertising. You'll be asked first, in a banner, and you can decline there or by writing 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.