Overview

CLOSW Construction LLC (“CLOSW,” “we,” “us,” or “our”) is committed to protecting your personal information and your right to privacy. Furthermore, as a company operating in both the United States and the European Union, we are subject to multiple privacy frameworks and take our obligations under each of them seriously.

This Privacy Policy explains what information we collect, why we collect it, how we use it, with whom we share it, and what rights you have with respect to your personal data. It applies to all information collected through our website at closw.com, our contact forms, our email communications, and any other interactions you have with CLOSW Construction.

Who We Are

CLOSW Construction operates as two legal entities. For the purposes of this privacy policy the data controller is:

For users in the European Union or United Kingdom, CLOSW  Group INC  acts as the data controller and is responsible for compliance with the General Data Protection Regulation (GDPR). For users in the United States, CLOSW Construction LLC is the data controller and is responsible for compliance with applicable US state privacy laws including the California Consumer Privacy Act (CCPA).

Data We Collect

We collect different types of personal information depending on how you interact with us. The following table sets out the categories of data we collect and the purpose for each:

How We Collect Your Data

We collect personal data through the following methods:

DIRECT INTERACTIONS

You provide data directly when you complete a contact form on our website, submit a consultation request, apply for a job through our careers page, email us directly, call our office, or message us via WhatsApp or LinkedIn.

AUTOMATED TECHNOLOGIES

As you interact with our website we automatically collect Technical Data and Usage Data using cookies, server logs, and similar technologies. Furthermore, we use Google Analytics to understand website traffic and user behaviour in aggregate. We also use the Facebook Pixel to measure the effectiveness of our advertising campaigns. For more information see Section 8 on Cookies.

THIRD PARTIES

We may receive data about you from third parties including Google Analytics, Facebook Business Manager, LinkedIn, and our hosting provider. In addition, if you apply for a role at CLOSW through a job board such as Indeed or LinkedIn we receive the information you submitted through that platform.

How We Use Your Data

We use the personal data we collect for the following purposes:

• To respond to consultation requests— when you submit a project enquiry we use your contact and project data to prepare and deliver a scope assessment and cost range
• To manage client relationships— we use your data to communicate about your project, send updates, and manage the ongoing relationship throughout a construction engagement
• To process job applications— we use CV and application data solely to evaluate candidates for open positions at CLOSW Construction
• To improve our website— we analyze Technical and Usage Data in aggregate to understand which content is useful and where our site can be improved
• To measure advertising effectiveness— we use the Facebook Pixel and Google Analytics to understand which advertising campaigns are generating relevant enquiries
• To send relevant project updates— where you have given consent or we have a legitimate interest, we may send you updates about construction industry topics relevant to your project type
• To comply with legal obligations— we may process your data where required by law, court order, or regulatory requirement in the US or EU

Legal Basis for Processing

Under the GDPR, we are required to identify our legal basis for processing your personal data. We rely on the following legal bases depending on the purpose of processing:

• Contractual necessity— processing required to take steps at your request prior to entering a contract, or to perform a contract with you. This covers consultation responses, project communications, and client management.
• Legitimate interests— where processing is necessary for our legitimate business interests, provided those interests are not overridden by your rights. This covers website analytics, security monitoring, and fraud prevention.
• Consent— where you have given clear, specific, informed consent to processing. This covers marketing communications and non-essential cookies. You may withdraw consent at any time.
• Legal obligation— where we are required to process data to comply with a legal obligation in the US or EU, such as tax records, contract requirements, or regulatory reporting.

Sharing Your Data

We do not sell, trade, or rent your personal data to third parties. However, we may share your data with the following categories of recipients in limited circumstances:

• Service providers— companies that provide services on our behalf including website hosting (cPanel/LiteSpeed), email delivery, CRM software, and accounting systems. These providers process data only on our instructions and are bound by data processing agreements.
• Google LLC— we use Google Analytics to analyse website traffic. Google processes usage data in accordance with Google’s own privacy policy. You can opt out at tools.google.com/dlpage/gaoptout
• Meta Platforms Inc (Facebook)— we use the Facebook Pixel to measure advertising effectiveness. Data processed by Meta is governed by Meta’s Data Policy.
• Legal and regulatory authorities— where required by law, court order, or regulatory requirement in the United States or the European Union.
• Professional advisors— lawyers, accountants, and insurers where necessary in connection with the services they provide to us.
• Business transfers— in the event of a merger, acquisition, or sale of all or part of our business, your data may be transferred to the acquiring entity. We will notify you before this occurs.

In all cases where we share your data with third parties we ensure appropriate safeguards are in place through contractual data processing agreements, standard contractual clauses approved by the European Commission, or other legally recognised transfer mechanisms.

Cookies

Our website uses cookies — small text files stored on your device — to improve your experience and help us understand how our site is used. Furthermore, some cookies are necessary for the website to function correctly while others are optional and require your consent.

You can manage your cookie preferences at any time through your browser settings. However please note that disabling certain cookies may affect the functionality of our website. Furthermore, most browsers allow you to refuse cookies, delete existing cookies, and set preferences for specific websites.

For more information about cookies and how to manage them visit allaboutcookies.org.

Data Retention

We retain your personal data only for as long as necessary for the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

• Consultation enquiries that did not result in a contract— 2 years from the date of your last communication with us
• Client project data— 7 years from project completion to comply with US and EU contractual and tax record requirements
• Job application data— 12 months from the date of application for unsuccessful candidates. Successful candidates’ data is retained as part of their employment record.
• Website analytics data— 26 months as per Google Analytics default settings, after which data is automatically deleted
• Email correspondence— 3 years from the date of last communication
• Marketing consent records— retained until you withdraw consent plus 1 year for compliance documentation

After the applicable retention period expires we will securely delete or anonymise your personal data. As a result, once data is anonymised it can no longer be attributed to you and is therefore no longer subject to this privacy policy.

Your Rights

Depending on your location and the applicable privacy laws, you have the following rights with respect to your personal data. Furthermore, we are committed to responding to all valid rights requests within the timeframes required by law.

To exercise any of these rights please contact our privacy team at privacy@closw.com. We will respond within 30 days. Furthermore, we will never charge a fee for exercising your rights unless a request is manifestly unfounded or excessive.

GDPR — EU and UK Users

If you are located in the European Union, European Economic Area, or United Kingdom, the General Data Protection Regulation (GDPR) or UK GDPR applies to our processing of your personal data. As a result, the following additional provisions apply to you:

• Data controller— CLOSW Group INC, Borysa Hrinchenka St, 9, Kyiv, Ukraine, 01034, Ukrainian is the data controller for EU/UK users
• Supervisory authority— you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at autoriteitpersoonsgegevens.nlor with the supervisory authority in your country of residence
• International transfers— where your data is transferred to the United States it is protected by Standard Contractual Clauses approved by the European Commission
• Legal basis— as described in Section 6, we always identify a valid legal basis under Article 6 GDPR before processing your personal data
• Data Protection Officer— for GDPR-related enquiries contact our DPO at privacy@closw.com

CCPA — California Users

If you are a California resident, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) provides you with specific rights regarding your personal information. Furthermore, these rights are in addition to the general rights described in Section 10.

• Right to Know— you have the right to request disclosure of the categories of personal information we have collected about you, the sources of that information, and the business purposes for which it was collected
• Right to Delete— you have the right to request deletion of personal information we have collected from you, subject to certain exceptions
• Right to Opt-Out of Sale— we do not sell personal information. Therefore this right is technically not applicable, but we commit to never selling your data regardless
• Right to Non-Discrimination— we will not discriminate against you for exercising any of your CCPA rights
• Right to Correct— you have the right to request correction of inaccurate personal information we maintain about you

To exercise your CCPA rights contact us at privacy@closw.com with the subject line “CCPA Rights Request.” We will respond within 45 days as required by California law.

Security

We implement appropriate technical and organisational security measures to protect your personal data against accidental loss, unauthorised access, alteration, or disclosure. Furthermore, these measures are regularly reviewed and updated in line with industry best practices.

• SSL/TLS encryption— all data transmitted between your browser and our website is encrypted using SSL/TLS technology
• Access controls— access to personal data is restricted to CLOSW staff who need it to perform their job functions
• Password security— all systems containing personal data require strong authentication credentials
• Regular backups— data is backed up regularly to prevent loss in the event of a system failure
• Security monitoring— our website is monitored for security threats using Wordfence Security and LiteSpeed server-level protections

Children’s Privacy

Our website and services are directed exclusively at business professionals and are not intended for use by children under the age of 16. Furthermore, we do not knowingly collect personal data from children under 16. If you believe a child has provided us with personal information please contact us at privacy@closw.com and we will delete that information promptly.

Third-Party Links

Our website contains links to third-party websites including OSHA, USGBC LEED, ISO, and other authoritative sources. These links are provided for your reference and convenience. However, once you leave our website we have no control over the content or privacy practices of those sites. As a result we are not responsible for the privacy policies or data handling practices of any third-party website. We recommend reading the privacy policy of every website you visit.

International Data Transfers

CLOSW Construction operates in both the United States and the European Union. As a result, your personal data may be transferred between these jurisdictions in the course of our operations. Furthermore, data may be transferred to service providers located in countries outside your country of residence.

Where we transfer personal data from the EU or UK to the United States or other third countries, we ensure appropriate safeguards are in place including Standard Contractual Clauses (SCCs) approved by the European Commission, adequacy decisions where available, or other lawful transfer mechanisms recognised under the GDPR.

For more information about the specific safeguards in place for any particular transfer contact us at privacy@closw.com.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. Furthermore, when we make material changes we will update the “Last Updated” date at the top of this page and, where required by law, notify you by email or through a prominent notice on our website.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of our website after any changes constitutes your acknowledgement of the updated policy. However, where changes require your consent we will seek that consent before the changes take effect.

Contact Us

If you have questions about this Privacy Policy, wish to exercise your rights, or want to make a complaint about how we have handled your personal data, please contact us through any of the following channels:

We aim to respond to all privacy enquiries within 30 days. For urgent matters or data breach notifications please mark your email as urgent. Furthermore, if you are not satisfied with our response you have the right to lodge a complaint with the relevant supervisory authority in your country.