1. Who We Are

ClosingFox is a product of Habitat Haven LLP, a limited liability partnership registered in Mumbai, Maharashtra, India.

ClosingFox (“we”, “our”, “us”) is a mobile-first CRM platform designed for the Indian real estate industry, accessible via our web application at app.closingfox.com, our Android application, and our website at closingfox.com.

This Privacy Policy explains how we collect, use, store, and protect information when you use our website, applications, and services.

2. What Data We Collect

2.1 Information You Provide

• Account information: Name, email address, phone number, company/organization name when you create an account or request a demo.
• Business data: Lead information, contact details, project data, notes, call logs, site visit records, and other CRM data you enter into the platform.
• Payment information: Billing details processed through our payment partner Razorpay. We do not store your full credit card or bank account numbers on our servers.
• Communication: Messages you send us via WhatsApp, email, contact forms, or in-app support.

2.2 Information Collected Automatically

• Device information: Device type, operating system, browser type, screen resolution.
• Usage data: Pages visited, features used, time spent, click patterns.
• Log data: IP address, access timestamps, referring URLs.
• Location data: GPS coordinates during site visit tracking (only when you actively start a site visit in the app — we do not track location in the background).
• Call data: On Android, with your explicit permission, we detect call events (incoming/outgoing, duration, phone number) to auto-log calls against leads. We do not record call audio.

2.3 Information from Third Parties

• Lead sources: When you connect portals like 99acres, Housing.com, MagicBricks, Meta Lead Ads, or website forms, we receive lead data (name, phone, email, enquiry details) via webhooks configured by you.
• Authentication: If you sign in via Google, we receive your name, email, and profile picture from Google OAuth.

3. How We Use Your Data

We use the data we collect to:

• Provide the service: Operate the CRM platform, manage leads, track calls and site visits, generate dashboards and reports.
• Improve the product: Understand usage patterns, identify bugs, and prioritize features.
• Communicate with you: Send service updates, respond to support queries, send transactional emails (account confirmation, password reset, subscription receipts).
• Process payments: Manage subscriptions and billing through Razorpay.
• Ensure security: Detect fraud, prevent unauthorized access, enforce our Terms of Service.
• Comply with law: Meet legal obligations under applicable Indian law.

We do not sell your data. We do not use your business data (leads, contacts, deals) for advertising, marketing to your contacts, or any purpose other than providing you the ClosingFox service.

4. Data Storage & Security

Your data is stored on cloud infrastructure provided by Supabase (backed by AWS), with servers located in secure data centers. We implement the following security measures:

• Encryption: Data is encrypted in transit (TLS/SSL) and at rest.
• Row-Level Security (RLS): Each organization’s data is isolated at the database level. Users in one organization cannot access another organization’s data.
• Authentication: JWT-based authentication with secure session management.
• Access control: Role-based permissions with 14-module granular access control (View/Create/Edit/Delete per module, per pipeline).
• Data masking: Phone numbers and email addresses can be masked based on user permissions.

While we take reasonable measures to protect your data, no method of electronic storage is 100% secure. We cannot guarantee absolute security.

5. Data Sharing

We do not sell, rent, or trade your personal or business data. We share data only in these limited circumstances:

• Service providers: We use trusted third-party services to operate ClosingFox (see Section 9). These providers are bound by confidentiality agreements and process data only on our behalf.
• Within your organization: Data is shared among users within your ClosingFox organization based on the permissions and roles you configure.
• Legal requirements: We may disclose data if required by law, regulation, court order, or governmental request under Indian law.
• Business transfer: In the event of a merger, acquisition, or sale of assets, your data may be transferred as part of that transaction. We will notify you before your data becomes subject to a different privacy policy.

6. Cookies & Tracking

Our website (closingfox.com) uses:

• Essential cookies: Required for the website to function (session management, security).
• Analytics: We may use Google Analytics or similar tools to understand website traffic and user behavior. This data is aggregated and does not personally identify you.
• UTM parameters: We capture UTM parameters (source, medium, campaign) from URLs to understand which marketing channels drive traffic. This data is stored in your browser’s session storage and included in demo request forms.

Our CRM application (app.closingfox.com) does not use advertising cookies or third-party tracking pixels.

7. Your Rights

You have the right to:

• Access your data: Request a copy of the personal data we hold about you.
• Correct your data: Update or correct inaccurate information in your account.
• Delete your data: Request deletion of your account and associated data. We will comply within 30 days, subject to legal retention requirements.
• Export your data: Request your data in a portable format.
• Withdraw consent: Revoke permissions (such as call log access or location access) at any time through your device settings.
• Opt out of communications: Unsubscribe from non-essential emails at any time.

To exercise any of these rights, contact us at mail@closingfox.com.

8. Data Retention

• Active accounts: We retain your data for as long as your account is active and you maintain an active subscription.
• After cancellation: We retain your data for 90 days after subscription cancellation, allowing you to reactivate without data loss. After 90 days, data is permanently deleted.
• Free trial accounts: Data from expired trial accounts that did not convert to paid is retained for 60 days, then deleted.
• Website form submissions: Demo request data (name, phone, UTM data) is retained for 12 months.
• Legal obligations: Certain data may be retained longer if required by applicable Indian law (e.g., tax and financial records).

9. Third-Party Services

We use the following third-party services to operate ClosingFox:

• Supabase: Database, authentication, and real-time infrastructure.
• Vercel: Serverless API hosting.
• Razorpay: Payment processing (PCI DSS compliant).
• Google Cloud: OAuth authentication.
• Expo / React Native: Mobile application framework.
• Firebase Cloud Messaging (FCM): Push notifications.

Each of these providers has their own privacy policy governing how they handle data. We encourage you to review their policies.

10. Children’s Privacy

ClosingFox is a business-to-business product designed for real estate professionals. We do not knowingly collect data from individuals under the age of 18. If we become aware that we have collected data from a minor, we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time. When we make significant changes, we will notify you via email or through a notice on our website. The “Last updated” date at the top of this page indicates when the policy was last revised.

Your continued use of ClosingFox after changes are posted constitutes your acceptance of the updated policy.

12. Contact Us

13. Compliance with Indian Data Protection Laws

ClosingFox is a product of Habitat Haven LLP, registered in Mumbai, Maharashtra, India. We are committed to complying with the Digital Personal Data Protection (DPDP) Act, 2023 and all applicable Indian data protection regulations.

13.1 Lawful Basis for Processing

We process your personal data based on:

• Consent — You provide explicit consent when signing up, accepting our Terms of Use, and enabling features like GPS site visit tracking and call detection.
• Contractual necessity — Processing required to deliver the CRM service you subscribed to (lead management, pipeline tracking, team management).
• Legitimate interest — Service improvement, security monitoring, and fraud prevention.
• Legal obligation — Compliance with Indian tax, corporate, and regulatory requirements.

13.2 Data Localization

Your primary CRM data (leads, contacts, call logs, notes, pipeline data) is stored on Supabase infrastructure backed by AWS. While we endeavour to keep data processing within India where possible, some of our service providers (Vercel for hosting, Firebase for push notifications, Google Cloud for analytics) may process limited data outside India. All such transfers are governed by appropriate contractual safeguards and data processing agreements.

13.3 Consent Withdrawal

You may withdraw your consent for data processing at any time by:

• Disabling specific permissions (GPS, call detection) in your device settings
• Contacting us at mail@closingfox.com to request data deletion
• Deleting your account through the app settings

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal. Some data may be retained where required by law or legitimate business interest (e.g., billing records for tax compliance).

13.4 Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights, we will:

• Notify the Data Protection Board of India as required under the DPDP Act
• Notify affected users within 72 hours of becoming aware of the breach
• Provide details of the breach, potential impact, and remedial steps taken

14. Grievance Officer

In accordance with the Digital Personal Data Protection Act, 2023, we have appointed the following Grievance Officer to address your concerns regarding data processing:

If you are unsatisfied with our response, you may file a complaint with the Data Protection Board of India as established under the DPDP Act, 2023.

15. Data Retention Schedule

We retain different types of data for different periods based on business necessity and legal requirements:

After the retention period, data is permanently deleted and cannot be recovered. You may request earlier deletion by contacting us at mail@closingfox.com.