Terms of Service

Version 2.0

1. Introduction and Acceptance of Terms

Welcome to Closina ("Closina," "we," "us," or "our"). Closina is a cloud-based Customer Relationship Management (CRM) platform designed for professional services firms, featuring AI-powered voice interaction, contact management, appointment scheduling, drip campaigns, and business analytics capabilities.

By creating an account, accessing, or using the Closina platform and its related services (collectively, the "Service"), you ("User," "you," or "your") agree to be legally bound by these Terms of Service ("Terms"). If you are using the Service on behalf of an organization, you represent and warrant that you have the authority to bind that organization to these Terms, and "you" refers to both you individually and the organization.

If you do not agree to these Terms, you must not access or use the Service.

2. Eligibility and Account Registration

2.1 Eligibility

You must be at least 16 years of age to use the Service. By using the Service, you represent and warrant that you meet this age requirement and that all registration information you provide is truthful, accurate, and complete.

2.2 Account Creation

To access the Service, you must create an account by providing accurate, current, and complete information including your name, email address, and a secure password. You are responsible for:

• Maintaining the confidentiality of your account credentials;
• All activities that occur under your account, whether or not authorized by you;
• Notifying us immediately at security@closina.com of any unauthorized use of your account or any other breach of security;
• Ensuring that your account information remains accurate and up to date.

2.3 Account Security

You agree to use strong, unique passwords and to enable multi-factor authentication when available. We reserve the right to disable any user account if we reasonably believe that you have failed to comply with these security obligations.

3. Description of the Service

3.1 Platform Features

Closina provides a comprehensive CRM platform that includes, but is not limited to:

• Contact Management: Storage, organization, and management of customer and prospect data;
• AI Voice Interaction: AI-powered voice copilot for call management, transcription, and analytics;
• Appointment Scheduling: Calendar integration, booking management, and automated reminders;
• Communication Tools: Email, SMS, WhatsApp messaging, social media outreach, and drip campaigns;
• Analytics and Reporting: Business intelligence dashboards, performance metrics, and trend analysis;
• Team Collaboration: Multi-user workspaces, task assignment, and activity tracking;
• Integration Services: Connections with third-party calendars, email providers, and business tools.

3.2 Service Availability

We strive to maintain high availability of the Service but do not guarantee uninterrupted access. The Service may be temporarily unavailable due to scheduled maintenance (with reasonable advance notice), emergency maintenance, force majeure events, or circumstances beyond our reasonable control.

3.3 Service Modifications

We reserve the right to modify, update, or discontinue any feature or functionality of the Service at any time. For material changes that negatively affect your use of the Service, we will provide at least thirty (30) days' advance notice via email or in-app notification, except where changes are required by law, regulation, or for security reasons.

4. Acceptable Use Policy

4.1 Permitted Use

The Service is intended for lawful business purposes only. You may use the Service to manage your customer relationships, communications, and business operations in compliance with all applicable laws and regulations.

4.2 Prohibited Conduct

You agree NOT to:

• Use the Service for any unlawful purpose or in violation of any applicable local, state, national, or international law or regulation;
• Upload, transmit, or distribute any content that is defamatory, obscene, fraudulent, harmful, threatening, or that infringes on the rights of others;
• Send unsolicited communications (spam), including bulk emails, SMS messages, or social media messages, in violation of applicable anti-spam laws (including CAN-SPAM, CASL, and GDPR);
• Use the AI voice features to impersonate individuals, create deepfakes, or conduct fraudulent calls;
• Attempt to gain unauthorized access to the Service, other user accounts, or any systems or networks connected to the Service;
• Use automated scripts, bots, crawlers, or similar tools to access or collect data from the Service without our express written permission;
• Interfere with, disrupt, or place undue burden on the Service or its underlying infrastructure;
• Reverse engineer, decompile, disassemble, or otherwise attempt to derive the source code of the Service;
• Circumvent, disable, or interfere with any security features of the Service;
• Upload viruses, malware, or other malicious code;
• Resell, sublicense, or redistribute the Service or any part thereof without our prior written consent;
• Use the Service in a manner that violates the Do Not Call (DNC) registry requirements or any telecommunications regulations.

4.3 Telephony Compliance

When using the communication features of the Service (including AI voice, SMS, and calling), you are solely responsible for:

• Obtaining all necessary consents from recipients before initiating communications;
• Complying with the Telephone Consumer Protection Act (TCPA), Telemarketing Sales Rule (TSR), and all applicable federal, state, and international telecommunications regulations;
• Maintaining and honoring internal Do Not Call lists;
• Complying with all applicable caller identification requirements.

5. Intellectual Property

5.1 Our Intellectual Property

The Service, including its design, text, graphics, logos, icons, images, software, algorithms, AI models, and all related intellectual property, is owned by Closina or its licensors and is protected by copyright, trademark, patent, and other intellectual property laws. These Terms do not grant you any ownership rights in the Service.

5.2 Limited License

Subject to your compliance with these Terms, we grant you a limited, non-exclusive, non-transferable, revocable license to access and use the Service solely for your internal business purposes during the subscription term.

5.3 Your Content

You retain ownership of all data, files, documents, and other materials that you upload, create, or transmit through the Service ("Your Content"). By using the Service, you grant us a limited, non-exclusive license to process, store, transmit, and display Your Content solely as necessary to provide and improve the Service.

5.4 Feedback

If you provide suggestions, ideas, or feedback about the Service ("Feedback"), you grant us an unrestricted, perpetual, irrevocable, non-exclusive, royalty-free license to use, modify, and incorporate such Feedback into the Service without obligation to you.

6. Data Processing and Privacy

6.1 Privacy Policy

Your use of the Service is also governed by our Privacy Policy, which describes how we collect, use, store, and protect your personal data and the data you manage through the Service. The Privacy Policy is incorporated into these Terms by reference.

6.2 Data Processing Agreement

For Users who process personal data of EU/EEA residents through the Service, a Data Processing Agreement ("DPA") governs our role as a data processor. The DPA is available upon request and supplements these Terms.

6.3 Data Ownership

You own the data you input into the Service. We act as a data processor on your behalf and will not access your data except as necessary to provide the Service, comply with legal obligations, or as otherwise described in our Privacy Policy.

6.4 AI Data Processing

Our AI features (voice copilot, transcription, analytics, and content generation) process data to provide functionality. AI-processed data is:

• Used solely to deliver the requested features;
• Not used to train general AI models without your explicit consent;
• Processed in compliance with applicable data protection laws;
• Subject to the same security and retention policies as other Service data.

7. Subscription, Billing, and Payment

7.1 Subscription Plans

The Service is offered through various subscription plans, each with specific features, usage limits, and pricing. Current plans and pricing are available on our website.

7.2 Free Trial

We may offer a free trial period. At the end of the trial, your account will be converted to a paid subscription or downgraded to a limited free tier, depending on the plan selected. We will notify you before any charges are applied.

7.3 Billing and Payment

• Subscription fees are billed in advance on a monthly or annual basis, as selected at the time of purchase;
• All fees are stated in United States Dollars (USD) unless otherwise specified;
• Payment is due upon invoice and is processed through our third-party payment processor (Stripe);
• You authorize us to charge your designated payment method for all applicable fees;
• Failure to pay may result in suspension or termination of your account.

7.4 Price Changes

We may modify subscription pricing at any time. Price changes will take effect at the beginning of your next billing cycle. We will provide at least thirty (30) days' notice of any price increase.

7.5 Refunds

Subscription fees are generally non-refundable. However, if you cancel within the first fourteen (14) days of a new subscription or renewal, you may request a pro-rata refund for the unused portion of your subscription term. Refund requests should be directed to billing@closina.com.

7.6 Taxes

All fees are exclusive of applicable taxes. You are responsible for all taxes, levies, or duties imposed by taxing authorities in connection with your use of the Service, excluding taxes based on our net income.

8. Limitation of Liability

8.1 Disclaimer of Warranties

THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING BUT NOT LIMITED TO IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT.

We do not warrant that the Service will be uninterrupted, error-free, secure, or free of viruses or other harmful components. We do not warrant the accuracy, reliability, or completeness of any data, information, or content provided through the Service.

8.2 Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL CLOSINA, ITS AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, OR LICENSORS BE LIABLE FOR:

• Any indirect, incidental, special, consequential, or punitive damages;
• Any loss of profits, revenue, data, business opportunities, or goodwill;
• Any damages arising from your reliance on the Service or any data processed through it;
• Any damages exceeding the total amount paid by you to Closina in the twelve (12) months preceding the event giving rise to the claim.

These limitations apply regardless of the legal theory (contract, tort, strict liability, or otherwise) and even if Closina has been advised of the possibility of such damages.

8.3 AI Disclaimer

AI-generated content, transcriptions, analytics, and recommendations provided through the Service are for informational purposes only. They should not be relied upon as legal, medical, financial, or professional advice. You are solely responsible for decisions made based on AI-generated outputs.

9. Indemnification

You agree to indemnify, defend, and hold harmless Closina, its affiliates, officers, directors, employees, and agents from and against all claims, damages, losses, liabilities, costs, and expenses (including reasonable attorneys' fees) arising out of or related to:

• Your use of the Service;
• Your violation of these Terms;
• Your violation of any applicable law or regulation;
• Your infringement of any third-party rights;
• The content or data you store, process, or transmit through the Service.

10. Termination

10.1 Termination by You

You may terminate your account at any time through the account settings or by contacting support@closina.com. Upon termination, your right to use the Service will cease immediately.

10.2 Termination by Us

We may suspend or terminate your account at any time if:

• You breach any provision of these Terms;
• Your payment is overdue for more than fifteen (15) days;
• We are required to do so by law or regulation;
• Your use of the Service poses a security risk or may cause harm to other users;
• We discontinue the Service (with at least sixty (60) days' advance notice).

10.3 Effect of Termination

Upon termination:

• All licenses granted to you under these Terms will immediately terminate;
• You must cease all use of the Service;
• You may request an export of your data within thirty (30) days of termination. After this period, we will delete your data in accordance with our data retention policies;
• Sections of these Terms that by their nature should survive termination (including intellectual property, limitation of liability, indemnification, and governing law) will continue to apply.

11. Dispute Resolution

11.1 Governing Law

These Terms shall be governed by and construed in accordance with the laws of the State of Delaware, United States, without regard to its conflict of law provisions.

11.2 Arbitration

Any dispute, controversy, or claim arising out of or relating to these Terms or the Service shall be resolved through binding arbitration administered by the American Arbitration Association (AAA) under its Commercial Arbitration Rules. The arbitration shall be conducted in English and held in a mutually agreed location or via videoconference.

11.3 Class Action Waiver

YOU AGREE THAT ANY DISPUTE RESOLUTION PROCEEDINGS WILL BE CONDUCTED ON AN INDIVIDUAL BASIS AND NOT AS PART OF A CLASS, CONSOLIDATED, OR REPRESENTATIVE ACTION.

11.4 Exceptions

Notwithstanding the arbitration provision, either party may seek injunctive or equitable relief in any court of competent jurisdiction to prevent the actual or threatened infringement, misappropriation, or violation of intellectual property rights.

12. Changes to These Terms

We may modify these Terms at any time. When we make material changes, we will:

• Post the updated Terms on our website;
• Notify you via email or in-app notification at least thirty (30) days before the changes take effect;
• Update the version number and effective date at the top of this document;
• Require re-acceptance if the changes are substantive.

Your continued use of the Service after the effective date of the updated Terms constitutes your acceptance of the changes. If you do not agree to the modified Terms, you must discontinue use of the Service.

13. General Provisions

13.1 Entire Agreement

These Terms, together with the Privacy Policy, any applicable DPA, and your subscription agreement, constitute the entire agreement between you and Closina regarding the Service.

13.2 Severability

If any provision of these Terms is found to be invalid or unenforceable, the remaining provisions shall continue in full force and effect.

13.3 Waiver

Our failure to enforce any provision of these Terms shall not constitute a waiver of that provision or any other provision.

13.4 Assignment

You may not assign or transfer these Terms or your rights under them without our prior written consent. We may assign these Terms without restriction.

13.5 Force Majeure

We shall not be liable for any delay or failure to perform resulting from causes beyond our reasonable control, including natural disasters, war, terrorism, labor disputes, government actions, epidemic or pandemic, or failures of third-party services.

13.6 Notices

Notices to you will be sent to the email address associated with your account. Notices to us should be sent to legal@closina.com.

14. Contact Information

If you have questions about these Terms, please contact us:

• Email: legal@closina.com
• Support: support@closina.com
• Website: https://www.closina.com

Privacy Policy

Version 2.0

1. Introduction

Closina ("Closina," "we," "us," or "our") is committed to protecting the privacy of our users and the individuals whose data is managed through our platform. This Privacy Policy ("Policy") describes how we collect, use, store, share, and protect personal information when you use the Closina CRM platform and related services (the "Service").

This Policy applies to all users of the Service, including account holders, team members, and administrators. It also describes the rights of individuals whose personal data is stored within the Service by our users.

By accessing or using the Service, you acknowledge that you have read and understood this Privacy Policy.

2. Information We Collect

2.1 Account Information

When you create an account, we collect:

• Full name and professional title;
• Email address;
• Phone number;
• Organization or business name;
• Business address and jurisdiction;
• Professional license information (when voluntarily provided);
• Billing and payment information (processed and stored by Stripe; we do not store full credit card numbers).

2.2 Contact Data You Manage

As a CRM platform, you may store information about your customers and business contacts, including:

• Names, email addresses, phone numbers, and mailing addresses;
• Communication history (emails, SMS messages, call transcripts);
• Appointment records and calendar events;
• Custom fields and notes you create;
• Transaction and deal records;
• Social media profiles and interaction history.

You are the data controller for this contact data. We act as a data processor on your behalf and process this data solely as instructed by you and as necessary to provide the Service.

2.3 Usage Data

We automatically collect certain information when you use the Service:

• IP addresses and approximate geolocation;
• Browser type and version;
• Device type, operating system, and screen resolution;
• Pages visited, features used, and time spent on the platform;
• Click patterns and navigation paths;
• Error logs and performance metrics;
• Authentication events and security logs.

2.4 AI-Processed Data

When you use our AI features (voice copilot, transcription, content generation, analytics), we process:

• Audio recordings of voice calls (when transcription or AI copilot features are enabled);
• Text inputs provided to AI content generation tools;
• Communication patterns analyzed for campaign optimization;
• Voice interaction metadata (call duration, sentiment indicators).

2.5 Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Maintain your session and authentication state;
• Remember your preferences and settings;
• Analyze usage patterns to improve the Service;
• Ensure security and detect fraudulent activity.

For more details, see Section 8 (Cookie Policy) below.

3. How We Use Your Information

3.1 Providing the Service

We use your information to:

• Create and maintain your account;
• Deliver the CRM features you have subscribed to;
• Process communications (email, SMS, voice, social media) on your behalf;
• Generate AI-powered insights, transcriptions, and content;
• Manage subscriptions, billing, and payments;
• Provide customer support and respond to inquiries.

3.2 Improving the Service

We use aggregated and anonymized data to:

• Analyze platform usage patterns and feature adoption;
• Identify and fix technical issues;
• Develop new features and improve existing ones;
• Optimize performance and reliability.

3.3 Security and Compliance

We use your information to:

• Detect, prevent, and respond to fraud, abuse, and security incidents;
• Enforce our Terms of Service and Acceptable Use Policy;
• Comply with legal obligations, including lawful requests from governmental authorities;
• Maintain audit trails for regulatory compliance.

3.4 Communications

We may send you:

• Service-related notices (maintenance windows, security alerts, account changes);
• Billing and subscription communications;
• Product updates and feature announcements (you may opt out);
• Responses to your support requests.

We will never sell your contact information to third parties for their marketing purposes.

4. Data Sharing and Disclosure

4.1 We Do NOT Sell Your Data

We do not sell, rent, or trade your personal information or the contact data you manage through the Service. This applies to all categories of data described in this Policy.

4.2 Service Providers

We share data with trusted third-party service providers who assist in operating the Service, including:

| Provider | Purpose | Data Shared | |----------|---------|-------------| | Cloud infrastructure providers | Hosting and storage | All Service data (encrypted) | | Stripe | Payment processing | Billing and payment data | | Email delivery providers | Transactional email | Email addresses, message content | | SMS and voice providers (Twilio) | Communication services | Phone numbers, message content, call audio | | AI processing providers (OpenAI, Azure) | AI features | Text inputs, audio for transcription | | Analytics providers | Usage analytics | Anonymized usage data | | Security services | Threat detection | Security logs, IP addresses |

All service providers are bound by data processing agreements that require them to protect your data and use it only for the specified purposes.

4.3 Legal Requirements

We may disclose your information when required by law, regulation, legal process, or governmental request, including:

• Court orders and subpoenas;
• Requests from law enforcement agencies;
• Regulatory compliance requirements;
• Protection of our rights, property, or safety, or the rights, property, or safety of others.

When legally permitted, we will notify you of such requests before disclosure.

4.4 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred to the successor entity. We will notify you before your information becomes subject to a different privacy policy.

4.5 With Your Consent

We may share your information with third parties when you have given explicit consent.

5. Data Retention

5.1 Active Accounts

We retain your data for as long as your account is active and as necessary to provide the Service. Specific retention periods:

| Data Type | Retention Period | |-----------|-----------------| | Account information | Duration of account + 30 days post-deletion | | Contact data you manage | Duration of account + 30 days post-deletion | | Communication history | Duration of account + 30 days post-deletion | | Voice recordings and transcripts | As configured in your settings (default: 90 days) | | Usage logs and analytics | 24 months (rolling) | | Security and audit logs | 36 months (for compliance) | | Billing records | 7 years (legal requirement) |

5.2 After Account Termination

When you terminate your account:

• You may request a full data export within thirty (30) days;
• Your data will be deleted within thirty (30) days of the export period (or termination, whichever is later);
• Certain data may be retained longer as required by law (e.g., billing records, legal hold data);
• Backups containing your data are purged within ninety (90) days.

5.3 Data Minimization

We regularly review the data we hold and delete data that is no longer necessary for the purposes for which it was collected.

6. Security Measures

We implement comprehensive security measures to protect your data, including:

6.1 Technical Safeguards

• Encryption in transit: All data transmitted between your device and our servers is encrypted using TLS 1.2 or higher;
• Encryption at rest: All stored data is encrypted using AES-256 encryption;
• Access controls: Role-based access control (RBAC) with principle of least privilege;
• Multi-factor authentication: Available for all accounts, required for administrative access;
• Network security: Firewalls, intrusion detection systems, and DDoS protection;
• Vulnerability management: Regular security scanning and penetration testing.

6.2 Organizational Safeguards

• Employee background checks and security training;
• Incident response procedures and disaster recovery plans;
• Regular security audits and compliance assessments;
• Data access logging and monitoring;
• Vendor security assessments for all third-party service providers.

6.3 Breach Notification

In the event of a data breach that affects your personal data, we will:

• Notify affected users within seventy-two (72) hours of becoming aware of the breach;
• Notify relevant supervisory authorities as required by applicable law;
• Provide details of the breach, including the nature of the data affected, the likely consequences, and the measures taken or proposed to address the breach.

7. Your Rights

7.1 General Rights (All Users)

Regardless of your location, you have the right to:

• Access: Request a copy of the personal data we hold about you;
• Correction: Request correction of inaccurate or incomplete personal data;
• Deletion: Request deletion of your personal data ("Right to be Forgotten");
• Data Portability: Receive your data in a structured, commonly used, machine-readable format (JSON, CSV);
• Opt-out: Unsubscribe from marketing communications at any time;
• Withdraw Consent: Withdraw previously granted consent for specific data processing purposes.

7.2 GDPR Rights (EU/EEA Residents)

If you are located in the European Economic Area, you additionally have the right to:

• Restriction: Request restriction of processing in certain circumstances;
• Object: Object to processing based on legitimate interests;
• Automated Decision-Making: Not be subject to decisions based solely on automated processing;
• Lodge Complaint: File a complaint with your local data protection authority.

Our legal bases for processing under GDPR are:

• Contract: Processing necessary to perform our agreement with you;
• Legitimate Interest: Processing necessary for our legitimate business interests (analytics, security);
• Consent: Processing based on your explicit consent (marketing, optional AI features);
• Legal Obligation: Processing required by law.

7.3 CCPA/CPRA Rights (California Residents)

If you are a California resident, you additionally have the right to:

• Know: Know what personal information is collected, used, shared, and sold;
• Delete: Request deletion of personal information;
• Opt-Out of Sale: Opt out of the sale of personal information (we do not sell your data);
• Non-Discrimination: Not be discriminated against for exercising your privacy rights;
• Correct: Request correction of inaccurate personal information;
• Limit Use of Sensitive Personal Information: Limit the use and disclosure of sensitive personal information.

Categories of personal information we collect (per CCPA): Identifiers, professional information, internet/network activity, geolocation data, and commercial information.

7.4 Canadian Privacy Rights (PIPEDA / Quebec Law 25)

If you are a Canadian resident, you have rights under the Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, Quebec's Law 25 (An Act to modernize legislative provisions as regards the protection of personal information):

• Consent: We collect, use, and disclose your personal information only with your consent or as permitted by law;
• Access and Correction: You may request access to and correction of your personal information;
• Withdrawal: You may withdraw consent for non-essential data processing;
• Granular Consent: For Quebec residents, we provide granular consent options for specific data collection purposes;
• Complaint: You may file a complaint with the Office of the Privacy Commissioner of Canada or the Commission d'acces a l'information du Quebec.

7.5 Exercising Your Rights

To exercise any of these rights:

• Use the Privacy Settings in your account dashboard;
• Email our Data Protection Officer at dpo@closina.com;
• Contact support at privacy@closina.com.

We will respond to verified requests within thirty (30) days (or within the timeframe required by applicable law). We may ask you to verify your identity before processing requests.

8. Cookie Policy

8.1 Types of Cookies We Use

| Cookie Type | Purpose | Duration | Required? | |-------------|---------|----------|-----------| | Essential | Authentication, security, session management | Session | Yes | | Functional | Preferences, settings, language | 1 year | No | | Analytics | Usage patterns, feature adoption | 2 years | No | | Performance | Load times, error tracking | 1 year | No |

8.2 Managing Cookies

You can manage cookie preferences through:

• Your browser settings (to block or delete cookies);
• Our in-app cookie preference center;
• Your account privacy settings.

Note that disabling essential cookies will prevent you from using the Service.

8.3 Third-Party Cookies

We may use third-party analytics tools that set their own cookies. These are governed by the respective third parties' privacy policies.

9. International Data Transfers

9.1 Data Location

The Service is hosted on cloud infrastructure in North America. Your data may be processed in the United States and Canada.

9.2 Transfer Safeguards

For transfers of personal data from the EU/EEA, UK, or other jurisdictions with data transfer restrictions, we rely on:

• Standard Contractual Clauses (SCCs) approved by the European Commission;
• Data Processing Agreements with all sub-processors;
• Supplementary technical and organizational measures as needed.

9.3 Data Localization

If you require data to remain within a specific geographic region, please contact us to discuss available options.

10. Children's Privacy

The Service is not intended for individuals under the age of 16. We do not knowingly collect personal information from children under 16. If we become aware that we have collected personal information from a child under 16, we will take steps to delete that information promptly.

If you believe that a child under 16 has provided us with personal information, please contact us at privacy@closina.com.

11. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will:

• Post the updated Policy on our website and within the Service;
• Notify you via email or in-app notification at least thirty (30) days before the changes take effect;
• Update the version number and effective date;
• Require re-acceptance if the changes are substantive.

We encourage you to review this Policy periodically to stay informed about our data practices.

12. Contact Information

If you have questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us:

• Data Protection Officer: dpo@closina.com
• Privacy Inquiries: privacy@closina.com
• General Support: support@closina.com
• Mailing Address: Closina Privacy Team, 100 King Street West, Suite 5600, Toronto, Ontario M5X 1C9, Canada
• Website: https://www.closina.com/privacy

For unresolved privacy concerns, you may also contact the applicable data protection authority in your jurisdiction.