These Data Processing Terms describe how Cleared2Close processes customer workspace data for customers using the service in a business capacity. They are intended to support the customer-controller and service-provider relationship for CRM data.
Roles
For CRM contacts, leads, borrowers, applicants, referral partners, clients, signers, prospects, campaign recipients, videos, files, reports, and other workspace data submitted by a customer, the customer is generally the business, controller, or equivalent party that decides why and how the data is processed. Cleared2Close acts as a service provider, processor, or equivalent party by processing that data to provide the service.
Processing Instructions
We process customer data according to the customer's use of the service, product settings, integrations, these terms, the Privacy Policy, support requests, legal requirements, security needs, and documented product behavior. Customers are responsible for ensuring their instructions are lawful.
Subprocessors and Integrations
We may use service providers and subprocessors for hosting, storage, email delivery, billing, support, security, monitoring, AI processing, mapping, video, calendar, OAuth, and other functions needed to operate the service. Customer-directed integrations may send data to third parties chosen or authorized by the customer.
Security Measures
We use reasonable technical and organizational safeguards appropriate for a small-business SaaS CRM, including HTTPS, authentication, team scoping, application-level encryption for new borrower/contact document uploads, selected encryption for secrets and OAuth tokens, hashed new API keys, upload controls, private media access checks, audit logging, backups, and security monitoring. Customers remain responsible for user access, endpoint security, exported data, access-code sharing, and content they send or share outside the service.
Data Subject Requests
Customers are responsible for responding to requests from their clients, borrowers, applicants, leads, referral partners, signers, prospects, and recipients. We will provide reasonable assistance through export, deletion review, and support workflows where required and technically feasible.
Deletion and Return
Upon customer request or account termination, we will review deletion or export requests according to legal, billing, security, signed-document, audit, backup, and transaction-retention requirements. Some records may be retained when needed for legitimate business, legal, tax, fraud-prevention, security, dispute, or compliance purposes.
Restricted Use
We do not sell customer workspace data. We do not use customer pipeline, contact, report, document, or workspace content to train Cleared2Close's own generalized AI models. We may use aggregated or de-identified operational information to monitor reliability, capacity, feature adoption, security, and product performance.