Privacy Policy



Global Closing Room Limited, a private company limited by shares formed in the Republic of Ireland (d/b/a "Global Closing Room™"), ("we", "our" and "us") is committed to protecting your privacy.

This privacy policy describes what personal information we collect about you, how we may collect, use and share your personal information, our legal bases for using your personal information, how long we keep your personal information, how we protect your personal information, the countries to which we may transfer your personal information, and your rights regarding your personal information.

The types of personal information we collect about you may include:

  • Your personal contact details such as name, title, postal addresses, email addresses, and telephone numbers.
  • The company you work for and your position.
  • Identification and background information we may collect about you as part of our business acceptance procedures.
  • Financial information, such as your bank account details.
  • Technical information, such as information from your visits to our website or relating to marketing materials and other communications we send to you electronically.
  • Your communication preferences regarding marketing materials.
  • Any other personal information you provide to us during your relationship with us, such as your views and comments.

How we collect your personal information

The ways in which we collect personal information about you may include the following:

  • In the course of our business acceptance procedures.
  • In the course of running our business and providing the services you have hired us for.
  • Through your general use of our website. In particular, we collect personal information about you if you complete forms on our website.
  • Through your responses to our emails asking that you confirm and update information we maintain about you, or that you provide your consent for us to communicate with you.
  • Through information you may provide to our representatives at conferences and similar events.

How we use your personal information

We may use your personal information for the following purposes:

  • To manage, administer and improve the services that you hired us to provide.
  • To provide information requested by you.
  • To provide, administer, monitor the use of, and improve this website.
  • To promote our services, including by sending to you personalized event invitations, updates and other marketing materials.

Our legal bases for using your personal information

We use your personal information on the following bases:

  • To perform a contract, such as to provide services.
  • To comply with a legal obligation.
  • For our legitimate interests, as summarized above under the heading "How we use your personal information."

Cookies

By using our website without changing your browser settings, you consent to our use of cookies as set out below.

Cookies are text files which are stored on your computer or other device when you visit our website. They allow us to distinguish you from other users of our website. This helps us to provide you with a positive experience when you browse our website and to improve our website.

Our website uses a single first-party session cookie and persistent cookies. Session cookies are stored temporarily on your device whilst you browse our website and should be deleted from your device when you finish browsing.

First party cookies are set by us; third party cookies are set by a third party’s website. Our website uses these cookies:

Name Source Purpose Expiry
Test Cookie AIC Title Service The cookie tests the User's browser to ensure that the digital signature functionality will operate correctly Session cookie
OneSpan OneSpan Allows the OneSpan digital signature website and software to function within the Global Closing Room™ Session cookie

We use OneSpan to provide the digital signature functionality within the Global Closing Room™ (see OneSpan's Privacy Policy).

If you wish to restrict, block, or delete the cookies which are set by our website and third parties, you can do this using your browser settings. If you set your browser preferences to block all cookies, you may not be able to access all or parts of our website. If you delete cookies relating to our website, including your cookie preferences, you will be treated as a first-time visitor the next time you visit our website.

How we share your personal information

We may share your personal information with others in the following circumstances:

  • Our related entities in order to provide you with our services and in accordance with our business administrative practices.
  • Our third-party service providers in order to provide us with services, including our professional advisers, know-your-customer/anti-money laundering diligence providers, our information technology service providers, and our bankers.
  • Government or regulatory authorities, courts, tribunals, or other third parties, if we consider it, in our sole discretion, necessary or appropriate under applicable laws.
  • Any new entity or other third party if we decide to re-organize or transfer all or any part of our business.

We do not sell your personal information to anyone.

How long we keep your personal information

We retain your personal information in accordance with our document retention policy. Our retention periods are based on the requirements of applicable data protection laws, other legal and regulatory requirements to retain information for a minimum period and limitation periods for taking legal action.

How we protect your personal information

We have in place technical and organizational measures to protect the personal information we collect about you from unauthorized, improper or unlawful access, use, disclosure, alteration or destruction consistent with applicable data protection laws.

We maintain a proprietary information security management system. The system is inclusive of policies, procedures, and technical controls.

Countries to which we transfer your personal information

We may need to transfer your personal information to locations outside the jurisdiction in which you provide it, or from where you are viewing this website, in order to use it on the bases set out above. By using our website, you acknowledge and agree that it is hosted in the United States. If you are attempting to access our website from a physical location within any region with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that through your continued use of the website you are transferring information that may include personal information to the United States, and you consent to such transfer.

If you are an EU citizen or reside in the EU we will transfer your personal information outside the EU in accordance with EU data protection laws to ensure that it remains protected and secure. We have in place EU standard contractual clauses between us and the relevant third-party.

Your rights regarding your personal information

If you reside in the EU, you may have the following rights under EU data protection laws:

  • To request access to your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • To correct any incomplete or inaccurate personal information that we hold about you.
  • To request us to delete or remove from our systems your personal information where there is no legal basis for us continuing to process it.
  • To request us to suspend processing of your personal information, for example, if you want us to establish its accuracy or the reason for processing it.
  • To request the transfer of your personal information to a third party.
    To withdraw any consent that you have provided to us for processing your personal information.
  • To make a complaint to a local supervisory authority about how we are processing your personal information.

If you reside in a jurisdiction outside the EU, you may also have rights under applicable laws in connection with your personal information that we collect, hold, and process.

It is important that the personal information we hold about you is accurate and up to date. Please advise us of any changes to your personal information by contacting us at Privacy@GlobalClosingRoom.com.

Data controller

For the purposes of EU data protection laws, we are the data controller of your personal information.

Updates to this policy

We may change this privacy policy from time to time by updating this page. Please check this policy regularly to ensure that you are familiar with its content.

Contact information

If you have any questions about this privacy policy or you would like to exercise any of your rights relating to your personal information, please contact us at Privacy@GlobalClosingRoom.com.