Privacy Policy

1. Introduction

Welcome to Closely.

This Privacy Policy explains how Closely Tech Company (“Closely”, “we”, “us”, or “our”), based in Riyadh, Kingdom of Saudi Arabia, collects, uses, stores, protects, shares and otherwise processes Personal Data when individuals use the Closely mobile applications, services and related features.

Closely respects the privacy of its users and Creators and is committed to handling Personal Data responsibly, transparently and in accordance with applicable laws and regulations in the Kingdom of Saudi Arabia, including the Saudi Personal Data Protection Law (“PDPL”) and its Implementing Regulations.

This Privacy Policy applies to users, Creators and other individuals whose Personal Data is processed through Closely.

By using Closely, you acknowledge that you have been provided with this Privacy Policy and understand how your Personal Data may be processed as described below.

Where consent is required by applicable law for a particular processing activity, Closely will obtain such consent separately where necessary.

2. About Closely

Closely is a digital platform that enables users to discover, subscribe to and interact with Creators and access Creator content through subscriptions, Pay-Per-View (“PPV”) purchases, Tips and other Platform features.

Closely currently operates through:

The Closely landing page is available at Closely.sa.

Closely Tech Company is based in:

Riyadh, Kingdom of Saudi Arabia

General and privacy-related inquiries may be submitted to:

Support@closely.sa

The person currently responsible for privacy and data-protection matters at Closely is:

Saeed Alamr
Saeed@closely.sa

3. Scope of This Privacy Policy

This Privacy Policy applies to Personal Data processed in connection with:

This Privacy Policy does not govern independent websites, applications or services operated by third parties.

4. Age Requirement

Closely is intended exclusively for individuals aged 18 years or older.

Individuals under 18 are not permitted to create or use a Closely account.

We do not knowingly permit individuals under 18 to use Closely.

If we become aware that an individual under the age of 18 has created an account or provided Personal Data to Closely, we may immediately suspend or terminate the account and take appropriate steps to delete or otherwise lawfully handle the associated Personal Data.

Users who believe that an individual under 18 is using Closely should report the account to us.

5. What Is Personal Data?

For purposes of this Privacy Policy, “Personal Data” means information that identifies an individual or makes an individual identifiable, directly or indirectly, in accordance with applicable Saudi law.

Depending on how you use Closely, Personal Data may include account information, identity information, financial information, technical information, transaction information, communications and other information described below.

6. Personal Data We Collect

The Personal Data Closely collects depends on whether you are a regular user, Creator, applicant, purchaser or other individual interacting with Closely.

We seek to collect only Personal Data reasonably necessary for legitimate and specified purposes.

7. Account Information

When you create or maintain a Closely account, we may collect:

Certain information may be mandatory to create or maintain an account.

Other information may be optional.

8. Creator Information

Creators may be required to provide additional Personal Data.

Depending on the applicable verification and payout requirements, this may include:

Closely may request additional documentation when reasonably necessary for verification, fraud prevention, security, payout processing or compliance.

9. Identity Verification and KYC

Closely may verify the identity of Creators and, where necessary, other users.

Identity verification may involve:

At launch, certain verification processes may be performed directly by Closely.

Closely may in the future appoint a specialized third-party Know Your Customer (“KYC”) or identity-verification provider.

If a third-party KYC provider is introduced, Personal Data may be disclosed to or processed by that provider only to the extent reasonably necessary to perform identity, compliance, fraud-prevention and related verification services.

This Privacy Policy may be updated when material new providers or processing arrangements are introduced where required.

10. Bank and Payout Information

Creators who wish to withdraw eligible earnings may be required to provide:

The bank account used for Creator withdrawals must comply with Closely’s verification requirements.

At launch, Closely may process or initiate Creator payouts directly.

Closely may later appoint banks, financial institutions, payout processors or other authorized third-party providers to facilitate Creator withdrawals.

We will disclose only information reasonably necessary to facilitate, verify and record such transactions.

11. Coins and Transaction Information

When you purchase or use Coins, Closely may process information including:

Closely generally does not need to receive your complete payment-card information for transactions processed entirely through Apple or Google.

Payment information processed by Apple or Google is subject to their respective privacy practices and payment systems.

12. Apple and Google Payments

Closely currently intends to process mobile purchases through:

Apple and Google may independently process payment, device, account and transaction information in accordance with their own terms and privacy policies.

Closely may receive information regarding transactions such as:

Closely does not control how Apple or Google independently process Personal Data for their own purposes.

13. Creator Earnings Information

For Creators, Closely may process information concerning:

This information is processed to operate the Creator monetization and payout system.

14. User-Generated Content

Closely processes content that users and Creators voluntarily provide through the Platform.

This may include:

Creators are responsible for ensuring they have appropriate rights and permissions regarding content they upload.

15. Direct Messages and Private Communications

Closely provides messaging functionality between users and Creators where enabled by the Creator.

Closely does not routinely review every private message manually.

However, where a message or conversation is reported, flagged or otherwise reasonably identified as potentially violating Closely’s rules or applicable law, authorized Closely personnel may access and review relevant communications as necessary to:

Access to such information should be limited to authorized persons with a legitimate operational, safety, security or legal need.

16. Comments and Public Interactions

Information you intentionally make visible through public or shared Platform features may be visible to other users according to the applicable feature.

This may include:

Users should consider the information they choose to disclose through interactive Platform features.

17. Device and Technical Information

When you use Closely, we may automatically collect technical information such as:

Closely does not currently request precise device-location access for its ordinary services.

Closely also does not currently request access to a user’s address book or device contacts.

18. Firebase

Closely uses Firebase services for application functionality, analytics, technical monitoring and/or crash reporting.

Depending on the Firebase services enabled by Closely, Firebase may process technical and usage information such as:

Closely will configure third-party services in accordance with applicable privacy requirements and will seek to limit collection to information reasonably necessary for the relevant purposes.

19. AWS Hosting and Infrastructure

Closely uses Amazon Web Services (“AWS”) as part of its cloud infrastructure.

Personal Data and Platform content may therefore be stored or processed using AWS infrastructure.

Closely will configure its cloud infrastructure and access controls with the objective of maintaining appropriate confidentiality, integrity, availability and security of Personal Data.

Because cloud infrastructure and service configurations may evolve, Closely will assess applicable data-location and international-transfer requirements when configuring or changing infrastructure.

20. How We Collect Personal Data

We may collect Personal Data:

Directly from you

For example, when you:

Automatically

Certain technical and usage information may be collected automatically when you use Closely.

Through third parties

We may receive limited information from:

21. Why We Process Personal Data

Closely may process Personal Data for purposes including:

Providing the Platform

To:

Creator services

To:

Security

To:

Content moderation and safety

To:

Customer support

To:

Platform improvement

To:

Personalization

To:

Legal and regulatory compliance

To:

22. Legal Bases for Processing

Closely processes Personal Data only where there is an applicable legal basis under Saudi law.

Depending on the processing activity, this may include:

Where Closely relies on consent and applicable law gives you the right to withdraw that consent, you may withdraw it through the available settings or by contacting Closely.

Withdrawal of consent does not affect processing lawfully carried out before the withdrawal.

23. Mandatory and Optional Information

Certain Personal Data is necessary for Closely to provide particular services.

For example:

If you choose not to provide information that is necessary for a particular service, Closely may be unable to provide that service.

Optional profile information may generally be omitted unless otherwise indicated.

24. Data Minimization

Closely seeks to collect and process only Personal Data reasonably necessary for specified purposes.

We periodically may review our data practices and may discontinue collection of information that is no longer reasonably required.

25. Accuracy of Personal Data

Users and Creators are responsible for providing accurate and up-to-date information.

Where available, you may update certain information directly through your account settings.

Closely may request updated information where reasonably necessary for:

26. Personalized Recommendations

Closely may use information about how you interact with the Platform to personalize your experience.

This may include:

Such information may be used to provide:

Closely does not sell this information to third parties.

27. Marketing Communications

Closely may communicate with users regarding:

Where required, marketing communications will be sent based on the appropriate legal basis or consent.

Users may opt out of eligible promotional communications through available settings or unsubscribe mechanisms.

Opting out of marketing communications will not necessarily prevent Closely from sending important non-promotional communications such as:

28. Closely’s Own Marketing

Closely may use Personal Data to operate and measure its own marketing campaigns where permitted by applicable law.

This may include understanding whether Closely campaigns lead to application installations, account creation or engagement.

Closely will not use a Creator’s identifiable image, likeness, profile or content in Closely advertising or promotional campaigns where separate permission is required without obtaining the appropriate permission.

29. We Do Not Sell Personal Data

Closely does not sell users’ Personal Data.

Closely does not provide Personal Data to third parties in exchange for payment for their independent use.

This does not prevent Closely from using service providers that process Personal Data on Closely’s behalf where necessary to operate, secure or improve the Platform.

30. When We Share Personal Data

Closely may disclose Personal Data only where there is an appropriate purpose and legal basis.

Recipients may include the following categories.

Cloud and infrastructure providers

Including providers used to host, secure and operate Closely.

Analytics and technical providers

Including services used for analytics, diagnostics, application performance and crash reporting.

Apple and Google

Where necessary to validate and manage mobile purchases and Platform transactions.

Banking and payout providers

Where necessary to verify and process Creator withdrawals.

Identity and KYC providers

If and when Closely introduces third-party identity-verification services.

Security and fraud-prevention providers

Where necessary to detect and prevent abuse, unauthorized activity or fraud.

Professional advisers

Including lawyers, accountants, auditors and compliance advisers where reasonably necessary.

Government and regulatory authorities

Where disclosure is required or permitted by applicable law.

31. Legal and Government Disclosures

Closely may disclose Personal Data to:

where required or permitted by applicable law.

Closely may also preserve or disclose information where reasonably necessary to:

Any disclosure will be subject to applicable legal requirements.

32. International Data Transfers

Some of Closely’s technology or service providers may operate infrastructure or process information outside the Kingdom of Saudi Arabia.

Closely does not assume that all Personal Data will necessarily remain within Saudi Arabia.

Where Personal Data is transferred, accessed, disclosed or processed outside the Kingdom, Closely will seek to ensure that such activity complies with applicable Saudi data-protection requirements, including requirements concerning:

Closely will review international data-transfer implications when appointing or materially changing relevant service providers.

33. Content Moderation

Closely uses human and automated methods to maintain Platform safety and enforce its policies.

Automated systems may analyze content or activity to identify potential:

Automated systems may flag potentially problematic activity for review.

Closely does not intend to rely solely on automated systems to make material enforcement decisions where human review is appropriate.

Authorized personnel may review flagged information before significant enforcement action is taken, subject to safety, legal and operational considerations.

34. Automated Processing

Closely may use automated technologies to:

Such systems are generally intended to flag activity for human review, rather than independently make material decisions concerning users.

Where applicable law provides rights relating to automated processing, Closely will respect those rights.

35. Screenshot and Screen-Recording Protection

Closely seeks to protect Creator content against unauthorized capture, copying and redistribution.

Where supported by the relevant operating system and technically feasible, Closely may use technologies designed to:

Information generated through such security measures may be processed for:

Closely does not guarantee that technical measures will prevent every unauthorized screenshot, screen recording, copy or leak.

Unauthorized capture or distribution of content may result in enforcement action under Closely’s Terms and applicable law.

36. Fraud Prevention

Closely may process account, device, transaction, identity and behavioral information to detect and prevent:

Transactions or accounts identified as potentially suspicious may be temporarily restricted or flagged for human review.

37. Security

Closely implements technical, administrative and organizational measures designed to protect Personal Data from:

Measures may include, where appropriate:

No electronic system can be guaranteed to be completely secure.

Users are responsible for protecting their passwords, authentication credentials and devices.

38. Personal Data Breaches

Closely maintains procedures intended to identify, assess, contain and respond to suspected Personal Data breaches.

Where a Personal Data breach occurs, Closely will assess:

Where required by applicable Saudi law, Closely will notify the competent authority and/or affected Data Subjects within the applicable requirements and timeframes.

39. Data Storage

Personal Data may be stored through Closely’s systems and authorized service providers, including AWS infrastructure.

Closely will seek to maintain appropriate technical and organizational protections for stored Personal Data.

The exact infrastructure and storage architecture may evolve as Closely develops.

Any material changes will be assessed against applicable Saudi data-protection requirements.

40. Data Retention

Closely retains Personal Data only for as long as reasonably necessary for the purposes for which it was collected or as otherwise required or permitted under applicable law.

Retention periods may vary depending on the type of information.

Relevant considerations may include:

Personal Data that is no longer required will be deleted, destroyed, anonymized or otherwise handled in accordance with applicable law.

41. Account Deletion

Users may request deletion of their Closely account.

Following a valid deletion request, the account will generally enter a 30-day deletion period.

During this period, Closely may retain the account and associated information as necessary to:

After the applicable deletion period, Personal Data associated with the account will be deleted or otherwise lawfully handled, except where Closely is required or permitted to retain particular information for longer.

Certain records may therefore remain after account deletion, including where necessary for:

42. Creator Account Deletion

Creator accounts may involve additional financial, transaction, identity and compliance records.

Accordingly, deletion of a Creator account does not necessarily result in immediate deletion of all Creator information.

Closely may retain information necessary to:

43. Data Subject Rights

Subject to the PDPL, its Implementing Regulations and applicable exceptions, individuals may have rights concerning their Personal Data.

These may include the right to:

Certain rights may be subject to statutory limitations or exceptions.

44. Exercising Your Privacy Rights

Users may submit eligible privacy requests through:

Support@closely.sa

or through available privacy/account tools within the Closely application.

Closely intends to provide appropriate in-app mechanisms such as:

Settings → Account & Security → Privacy

Available functionality may include:

Closely may verify your identity before processing a privacy request.

This is necessary to prevent unauthorized individuals from obtaining, modifying or deleting another person’s Personal Data.

45. Response to Privacy Requests

Closely will process valid privacy requests in accordance with applicable Saudi law.

We may request information reasonably necessary to verify the identity of the requester.

Where a request cannot be fulfilled, is subject to a lawful exception, or requires additional time as permitted by law, Closely will handle the request in accordance with applicable legal requirements.

46. Withdrawal of Consent

Where Closely relies on consent to process Personal Data, you may withdraw your consent where applicable.

Withdrawal may be available through:

Withdrawal of consent does not affect the lawfulness of processing that occurred before withdrawal.

Some services may no longer be available where the relevant Personal Data is necessary to provide them.

47. User Choices and Controls

Depending on the applicable feature, Closely may provide controls relating to:

Creators may additionally control certain Creator-specific interactions.

48. Third-Party Services

Closely may contain integrations, links or functionality involving third-party services.

Third parties may have their own privacy policies and terms.

Where a third party independently determines how it processes Personal Data, its privacy practices are governed by its own policies.

Closely encourages users to review applicable third-party privacy notices.

49. Business Transactions and Corporate Changes

If Closely undergoes a merger, acquisition, restructuring, financing, sale of assets, corporate reorganization or similar transaction, Personal Data may be disclosed or transferred as part of that transaction where permitted by applicable law.

Any recipient of Personal Data will be required to process it in accordance with applicable legal requirements.

Where legally required, affected individuals will be appropriately informed.

50. Complaints

If you have a concern about how Closely processes your Personal Data, please contact us first so that we can investigate and attempt to resolve the matter.

Privacy concerns may be submitted to:

Saeed Alamr
Saeed@closely.sa

or:

Support@closely.sa

Nothing in this Privacy Policy limits any right you may have to submit a complaint to a competent authority under applicable Saudi law.

51. Changes to This Privacy Policy

Closely may update this Privacy Policy from time to time to reflect:

When this Privacy Policy is updated, the “Last Updated” date will be revised.

Where changes materially affect the processing of Personal Data, Closely will provide appropriate notice and obtain additional consent where required by applicable law.

52. Relationship With Closely’s Terms

This Privacy Policy should be read together with:

The Terms govern the contractual use of Closely.

This Privacy Policy governs Closely’s processing of Personal Data.

53. Contact Closely

For questions regarding this Privacy Policy, Personal Data, privacy rights or Closely’s privacy practices, contact:

Closely Tech Company
Riyadh, Kingdom of Saudi Arabia

General Support:
Support@closely.sa

Privacy Contact:
Saeed Alamr
Saeed@closely.sa