CloseIQ

Privacy Policy

Last updated: 18 August 2026

This Privacy Policy explains how Samuel Smyth, trading as CloseIQ ("CloseIQ", "we", "us", "our") collects, uses, stores and protects your personal data when you join our waitlist, use our website, or become a member. We are committed to protecting your privacy and handling your data in line with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Who we are

For the purposes of data protection law, the data controller is Samuel Smyth, trading as CloseIQ, based in the United Kingdom. If you have any questions about this policy or your data, contact us at [email protected].

2. The data we collect

Depending on how you interact with us, we may collect:

  • Information you give us when you join the waitlist or sign up, such as your name, email address and phone number.
  • Account and payment information if you become a paying member, such as billing details (payments are processed by our payment provider; we do not store your full card details).
  • Communications you send us, for example by email or reply.
  • Technical and usage data collected automatically, such as IP address, browser type, device information, and how you use our website, gathered via cookies and similar technologies.

3. How we use your data and our lawful basis

We use your personal data for the following purposes, relying on the following lawful bases under the UK GDPR:

  • To add you to the waitlist and contact you about CloseIQ launching, including updates and related emails and messages, on the basis of your consent.
  • To provide, manage and deliver the CloseIQ membership and any services you purchase, on the basis of performance of a contract with you.
  • To process payments and manage subscriptions, on the basis of performance of a contract and our legitimate interests in running our business.
  • To respond to your enquiries and provide support, on the basis of our legitimate interests.
  • To improve our website and services and keep them secure, on the basis of our legitimate interests.
  • To comply with our legal and regulatory obligations, on the basis of legal obligation.

4. Marketing communications

Where you have joined the waitlist or otherwise consented, we will send you emails and/or SMS messages about CloseIQ. You can withdraw your consent and unsubscribe at any time by using the unsubscribe link in any email, replying STOP to a text where offered, or emailing us at [email protected]. Withdrawing consent does not affect the lawfulness of processing carried out before you withdrew it.

5. Who we share your data with

We do not sell your personal data. We share it only with trusted third parties who help us operate, including:

  • Our CRM, forms and messaging provider (HighLevel / LeadConnector), which stores your details and sends our emails and texts on our behalf.
  • Payment processors that handle membership payments securely.
  • IT, hosting and analytics providers that support our website and systems.
  • Professional advisers, regulators or authorities where required by law.

These providers act as our data processors and are only permitted to process your data on our instructions and in line with data protection law.

6. International transfers

Some of our providers are based outside the United Kingdom, including in the United States. Where your personal data is transferred outside the UK, we ensure appropriate safeguards are in place, such as the UK International Data Transfer Agreement or Addendum, or transfers to countries the UK has deemed adequate.

7. How long we keep your data

We keep your personal data only for as long as necessary for the purposes set out in this policy. Waitlist and marketing data is kept until you unsubscribe or ask us to delete it, or where it is no longer needed. Member and payment records are kept for the duration of your membership and for as long afterwards as required to meet our legal, accounting and tax obligations.

8. Cookies

Our website and embedded forms may use cookies and similar technologies to make the site work, remember your preferences, and understand how it is used. You can control cookies through your browser settings. Disabling some cookies may affect how the site functions.

9. How we protect your data

We use appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, misuse or alteration. No method of transmission over the internet is completely secure, but we take reasonable steps to keep your data safe.

10. Your rights

Under the UK GDPR you have the right to:

  • Be informed about how your data is used.
  • Access a copy of the personal data we hold about you.
  • Have inaccurate data corrected.
  • Have your data erased in certain circumstances.
  • Restrict or object to processing in certain circumstances.
  • Data portability.
  • Withdraw consent at any time where we rely on consent.

To exercise any of these rights, email us at [email protected]. We will respond within one month.

11. Complaints

If you are unhappy with how we have handled your data, please contact us first so we can try to resolve it. You also have the right to complain to the Information Commissioner's Office (ICO), the UK supervisory authority, at ico.org.uk.

12. Children

Our services are intended for adults aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you believe a child has provided us with personal data, please contact us and we will delete it.

13. Changes to this policy

We may update this Privacy Policy from time to time. The latest version will always be posted on this page with an updated date. Please review it periodically.

14. Contact us

For any questions about this policy or your personal data, contact Samuel Smyth, trading as CloseIQ at [email protected].