Privacy Policy

1. Overview

ClientCloser operates as an AI-powered sales agent on behalf of its business clients ("Clients"): clinics and professional practices, including hair restoration clinics, med spas, physical therapy practices, and law firms. In doing so, we process three distinct categories of data: information about our Clients (firms that subscribe to ClientCloser), information about End Users (prospective clients who interact with a Client's AI agent), and information about visitors to our website.

Our Clients are data controllers for End User personal data collected through their AI agents. TNETIC, Inc. acts as a data processor in that context. For data collected directly through our website and business operations, TNETIC, Inc. is the data controller.

The AI functionality of the Service is built on models and infrastructure licensed from a third-party AI technology provider ("Technology Provider"). TNETIC, Inc. remains your point of contact for all privacy matters relating to the Service; see Section 7 for more detail on this arrangement.

2. Who We Are

ClientCloser is a product of TNETIC, Inc., a software company incorporated in the State of Illinois, United States. Our registered business address is in South Elgin, Illinois 60177.

For questions about this Privacy Policy or your personal data, contact us at [email protected] or call (312) 970-9589.

3. Information We Collect

3.1 Information Provided by Clients

When a firm subscribes to ClientCloser, we collect:

• Firm name, contact name, email address, and phone number;
• Billing information (processed by our payment processor; we do not store raw card numbers);
• Firm information used to configure the AI agent, including practice areas and service lines, fee structures, intake and qualification criteria, conflicts-screening criteria, policies, and sales scripts ("Client Content");
• Account credentials and access logs.

3.2 Conversation Data from End Users

When End Users interact with an AI agent powered by ClientCloser on a Client's channels (Instagram DM, Facebook Messenger, WhatsApp, Telegram, SMS, Email, or Website Chat), we process:

• The content of messages sent and received through the AI agent;
• Timestamps, channel identifiers (e.g., Instagram or Messenger thread ID, phone number for SMS, email address), and session metadata;
• Information End Users voluntarily share during conversations, such as name, email, the nature of the matter or service sought, party or entity names provided for conflicts screening, and consultation scheduling details;
• AI-generated responses and classification data (e.g., lead qualification status, intent classification).

3.3 Website Visitor Information

When you visit clientcloser.ai, we may collect:

• IP address, browser type, operating system, and referring URL;
• Pages visited, time on page, and click behavior (via analytics tools);
• Information you submit through contact or inquiry forms, including name, email, and firm type.

3.4 Information from Third-Party Platforms

To enable our Service, we receive data from third-party messaging platforms, including Meta's Messenger and Instagram APIs, WhatsApp, Telegram, SMS carriers, and email service providers, in accordance with those platforms' developer policies. This data is limited to what is necessary to operate the AI agent on the Client's behalf.

4. How We Use Information

4.1 To Provide and Operate the Service

• Process and deliver AI-generated responses on behalf of Clients;
• Configure, deploy, and maintain AI agents per Client instructions;
• Route conversations, send configured staff alerts, and log interactions;
• Follow up on inquiries using Client-approved messages, cadence, consent rules, and stopping conditions;
• Process billing and manage Client accounts.

4.2 To Improve the Service

• Analyze aggregated, de-identified conversation patterns to improve AI response quality;
• Monitor for errors, hallucinations, or inappropriate AI outputs;
• Conduct internal research and development on AI sales agent performance.

4.3 To Communicate with Clients

• Send onboarding materials, service updates, and support communications;
• Provide billing notifications and account alerts;
• Share product news and feature announcements (Clients may opt out at any time).

4.4 Legal and Safety Purposes

• Comply with applicable legal obligations and respond to lawful requests from government authorities;
• Enforce our Terms of Use and protect the rights, property, and safety of TNETIC, Inc., our Clients, and the public;
• Detect and prevent fraud, abuse, or security incidents.

We do not sell personal data. We do not use End User conversation data for advertising targeting.

5. Sharing and Disclosure

5.1 With Clients

Conversation Data generated through a Client's AI agent is accessible to that Client through their ClientCloser dashboard. Clients are responsible for their own data practices with respect to this information.

5.2 With Service Providers

We share data with trusted third-party service providers who assist us in operating the Service, subject to data processing agreements requiring them to protect the data and use it only for specified purposes. These include:

• Cloud hosting and infrastructure providers;
• Our Technology Provider, which hosts and operates the underlying AI models and infrastructure that power the Service (see Section 7.2 for detail on this relationship);
• Messaging and telephony carriers (Meta, WhatsApp, Telegram, SMS, and email delivery providers) used to deliver conversations;
• Payment processors (who handle billing data independently under their own privacy policies);
• Analytics and monitoring tools (using de-identified or aggregated data where possible).

Configured Staff Alerts

Clients can choose keywords that trigger notifications to their team by text, email, or Slack and can configure a different reply to the End User. Depending on the configured workflow, alert recipients and the providers delivering those notifications may receive information from the conversation. Clients choose recipients, including after-hours recipients, and are responsible for ensuring they are authorized to receive that information. Keyword alerts prompt human review; they do not assess urgency or deadlines and are not guaranteed to match every relevant message or to be delivered successfully.

5.3 Legal Requirements

We may disclose information if required to do so by law, regulation, legal process, or government request, or if we believe in good faith that disclosure is necessary to protect the rights, property, or safety of TNETIC, Inc., our users, or others.

5.4 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of all or substantially all of our assets, data we hold may be transferred to the acquiring entity. We will provide notice before any such transfer takes effect.

5.5 No Sale of Personal Data

We do not sell, rent, or trade personal data to third parties for their own marketing or commercial purposes.

6. Conversation Data and AI Processing

6.1 How Conversations Are Processed

When an End User sends a message to a Client's AI agent (over Instagram DM, Facebook Messenger, WhatsApp, Telegram, SMS, Email, or Website Chat), that message is transmitted to ClientCloser's systems, including systems operated by our Technology Provider, for AI processing. The AI model generates a response based on the message content and the Client Content provided by the Client. Both the incoming message and the AI-generated response are logged as Conversation Data.

6.2 AI Training

ClientCloser does not itself develop or train AI models. Conversation Data is processed using AI models operated by our Technology Provider. Our Technology Provider does not use Client Content or Conversation Data to train its AI models, and its own AI sub-processors are contractually prohibited from training on that data, unless a separate written agreement expressly permits it. ClientCloser will not enter into any such agreement without the Client's prior written consent. If you have questions about this, contact us at [email protected].

6.3 AI Output Accuracy

AI-generated responses may not always be accurate. We do not represent that AI Output is free from errors or hallucinations. End Users interacting with an AI agent should verify important information, such as fees, availability, or appointment confirmations, directly with the firm. AI Output is never legal, tax, financial, engineering, or other professional advice, and no professional relationship is formed by interacting with an AI agent.

6.4 Client Responsibility for End Users

Clients are responsible for providing appropriate privacy notices to their End Users and for obtaining any consents required under applicable law before using ClientCloser to communicate with those End Users.

6.5 Healthcare Use and BAA Availability

ClientCloser does not currently offer a Business Associate Agreement (BAA). Do not use the Service to process protected health information on behalf of a covered entity where a BAA is required. Pre-consultation or cash-pay use does not by itself establish that a BAA is unnecessary, and encryption does not replace a required BAA. Clients should evaluate their intended inquiry workflow before using the Service and contact us if that workflow requires a BAA.

6.6 Inquiry Follow-Up and Opt-Outs

The Service supports follow-up on inquiries through connected channels, using the Client’s approved content, cadence, and eligibility rules. Automated inquiry follow-up stops when the person books or opts out. Clients must obtain and maintain any required consent, honor opt-outs and other withdrawal requests, and configure the Service accordingly. Receipt of an inquiry is not blanket consent for unrelated promotional messages or outreach on every channel.

ClientCloser does not currently support reactivation campaigns to a database of old leads. Inquiry follow-up is distinct from that unsupported use. End Users can direct messaging preferences or opt-out requests to the Client whose agent contacted them. They may also contact us at [email protected] for assistance identifying the relevant Client.

7. Third-Party Platforms & Technology Provider

7.1 Messaging Platforms

ClientCloser connects to third-party messaging platforms, including Meta (Facebook Messenger, Instagram Direct), WhatsApp, Telegram, SMS carriers, and email providers, to deliver AI agent conversations. Your use of those platforms is also governed by their own privacy policies and terms of service:

• Meta Privacy Policy: facebook.com/privacy/policy
• WhatsApp Privacy Policy: whatsapp.com/legal/privacy-policy
• Telegram Privacy Policy: telegram.org/privacy

TNETIC, Inc. is not responsible for the data practices of these third-party platforms. We access only the data those platforms make available through their approved APIs and use it solely to operate the Service.

7.2 AI Technology Provider

Our Technology Provider relies on its own approved AI sub-processors to deliver certain conversational and media-processing functionality. Those sub-processors are contractually prohibited from using Client Content or Conversation Data to train their generally available models. Some processing occurs outside the United States, including in the European Union. Where personal data is transferred internationally, our Technology Provider relies on recognized safeguards such as Standard Contractual Clauses. Further detail is available upon written request.

8. Data Retention

Automatic deletion of contact and conversation history is off by default. Conversation Data remains in the conversation history unless it is deleted. Sensitive details that an End User volunteers are stored in that same history; they do not have a separate retention period or automatic-deletion policy.

• Contact and conversation history: no automatic deletion by default. Clients can configure an auto-deletion window for inactive contacts under Settings > Data Export;
• Server logs: retained for twelve (12) months;
• Financial records: retained for seven (7) years.

The inactive-contact auto-deletion setting is separate from the retention periods for server logs and financial records. For questions about deletion or to request deletion of Conversation Data, contact us at [email protected], subject to any applicable legal retention obligations.

9. Security

We implement commercially reasonable technical and organizational measures to protect data against unauthorized access, loss, alteration, or disclosure. These measures include:

• Encryption of data in transit (TLS) and at rest;
• Access controls and authentication requirements for personnel accessing production systems;
• Regular security reviews and monitoring for anomalous activity;
• Contractual security requirements for third-party service providers, including our Technology Provider.

No security system is impenetrable. Our Technology Provider is contractually required to notify us promptly of any security incident affecting Client Content or Conversation Data. In the event of a data breach that affects your personal data, including one occurring at our Technology Provider, we will notify affected parties without undue delay and as required by applicable law.

10. Your Rights

Depending on your location and applicable law, you may have the following rights regarding your personal data:

• Access: Request a copy of the personal data we hold about you;
• Correction: Request that inaccurate or incomplete data be corrected;
• Deletion: Request that we delete your personal data, subject to legal retention obligations;
• Portability: Request your data in a structured, machine-readable format;
• Objection: Object to certain processing activities, including direct marketing;
• Withdrawal of consent: Where processing is based on consent, withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at [email protected]. We will respond within thirty (30) days. If you are an End User (a prospective client) of a Client's AI agent, your rights requests regarding Conversation Data should be directed to the relevant Client firm, as they are the data controller for that data.

11. California Privacy Rights (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) provides you with additional rights:

Categories of Personal Information Collected

We collect identifiers (name, email, phone, IP address), commercial information (subscription details, billing records), and internet activity information (website usage). We do not sell or share personal information as defined under the CCPA.

Your California Rights

• Right to Know: Request disclosure of the categories and specific pieces of personal information collected about you in the past 12 months;
• Right to Delete: Request deletion of personal information we have collected from you, subject to exceptions;
• Right to Correct: Request correction of inaccurate personal information;
• Right to Opt-Out of Sale/Sharing: We do not sell or share personal information for cross-context behavioral advertising;
• Right to Limit Use of Sensitive Personal Information: We do not use or disclose sensitive personal information beyond what is necessary for operating the Service;
• Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

To submit a CCPA request, email [email protected] with "California Privacy Request" in the subject line. We will verify your identity before processing the request.

12. Children's Privacy

ClientCloser is a business-to-business service and is not directed at children under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13 without verifiable parental consent, we will take steps to delete that information promptly.

If you believe a child under 13 has provided personal information to us, please contact us at [email protected].

13. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to improve user experience and analyze site performance.

Types of Cookies We Use

• Essential cookies: Required for the website and dashboard to function. Cannot be disabled.
• Analytics cookies: Help us understand how visitors interact with our site (e.g., pages visited, time on site). We use aggregated data only.
• Preference cookies: Remember your settings and preferences for a better experience.

Your Cookie Choices

You can control cookies through your browser settings. Disabling non-essential cookies will not prevent you from using the ClientCloser Service, but may affect certain website features. We honor browser-level Do Not Track signals where technically feasible.

14. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or for other reasons. When we make material changes, we will:

• Update the "Last Updated" date at the top of this Policy;
• Notify active Clients by email and/or through the Service dashboard;
• Where required by law, obtain your consent before applying material changes to how we process your data.

We encourage you to review this Policy periodically. Your continued use of the Service following notice of changes constitutes acceptance of the updated Policy.

15. Contact Us

For questions, concerns, or requests related to this Privacy Policy or your personal data, please contact us: