Privacy Notice
Last updated: May 19, 2026
This Privacy Notice explains how Kenneth A Holm III (“Cloze”, “we”, “us”) collects, uses, and shares personal data when you use the Cloze website and service (the “Service”).
1. Who we are
The data controller is Kenneth A Holm III, trading as Cloze. If you have any questions about this notice or your personal data, contact us at support@cloze.online.
2. Personal data we collect
- Account data: email address, password (hashed), display name, and optional profile information.
- Content you create: quizzes, passages, items, and practice data you submit to the Service.
- Usage and telemetry: pages viewed, features used, view counts, streaks, stats, device and browser identifiers, IP address, approximate location derived from IP.
- Support communications: messages you send us and our responses.
- Cookies and similar technologies: essential cookies for authentication and preferences (e.g. theme, session identifier for view de-duplication).
Payment data (card details, billing address, tax information) is collected directly by our payment provider, Paddle, and is not stored by us. See “Data sharing” below.
3. Purposes and legal bases
- Provide the Service — create your account, store your quizzes, run practice sessions. Legal basis: performance of a contract.
- Security and fraud prevention — detect abuse, rate-limit requests, secure accounts. Legal basis: legitimate interests.
- Service improvement and analytics — understand how the Service is used and improve it. Legal basis: legitimate interests.
- Customer support — respond to your inquiries. Legal basis: legitimate interests / contract.
- Legal compliance — comply with applicable laws and respond to lawful requests. Legal basis: legal obligation.
- Marketing communications (only if you opt in) — send product updates. Legal basis: consent, which you can withdraw at any time.
4. Data sharing
We share personal data with the following categories of recipients:
- Merchant of Record — Paddle.com Market Limited: Paddle is our reseller and Merchant of Record. Paddle handles payments, subscription management, tax compliance, invoicing, refunds, and related customer service for purchases.
- Service providers / subprocessors: cloud hosting and database providers, authentication providers, analytics, and customer support tooling, each acting under our instructions.
- Professional advisers: legal, accounting, and similar advisers when necessary.
- Authorities: where required by law, court order, or to protect rights, property, or safety.
5. International transfers
Some recipients may be located outside your country, including in the United States and the United Kingdom. Where required, we rely on appropriate safeguards such as Standard Contractual Clauses or adequacy decisions.
6. Data retention
We retain account data and content for as long as your account is active. If you delete your account, we will delete or anonymize associated personal data within a reasonable period, except where we are required to retain it for legal, tax, accounting, or fraud prevention purposes. Backup copies may persist for a limited additional period before being overwritten.
7. Your rights
Depending on your jurisdiction, you may have the right to: access your personal data; have it corrected or deleted; restrict or object to its processing; receive a portable copy; withdraw consent at any time; and lodge a complaint with a data protection supervisory authority. To exercise these rights, contact support@cloze.online. We aim to respond within one month.
8. Security
We use appropriate technical and organizational measures to protect personal data, including encryption in transit, access controls, hashed passwords, and least-privilege access for staff and subprocessors. No system is perfectly secure, but we work to continually improve our safeguards.
9. Cookies
We use strictly necessary cookies and local storage entries to keep you signed in, store your theme preference, and de-duplicate view counts. We do not use third-party advertising cookies. You can clear cookies at any time through your browser.
10. Changes to this notice
We may update this notice from time to time. Material changes will be communicated through the Service or by email where appropriate.
11. Contact
Kenneth A Holm III — support@cloze.online