Privacy Statement

Last updated: March 2025

1. Who we are

Topcloser is an AI-powered sales conversation analysis and coaching platform. For the purposes of this Privacy Statement, Topcloser acts as the data controller in relation to account and usage data, and as a data processor in relation to conversation recordings and transcripts uploaded by customers.

For questions about this Privacy Statement or how we handle your data, please contact us at support@topcloser.io.

2. What personal data we process

We may process the following categories of personal data:

Account data: name, email address, password (hashed), role within your organization;
Billing data: subscription status, payment method details (processed by our payment provider — we do not store full card details);
Conversation data: audio recordings, transcripts, speaker labels, and AI-generated analyses and scores that you upload or that are generated as a result of your uploads;
Usage data: log data, feature usage, session data, timestamps, and IP addresses;
Support communications: messages you send to us via email or support channels.

3. Why we process your data

We process personal data for the following purposes:

To provide, operate, and improve the Topcloser platform;
To manage your account and process payments;
To perform AI transcription and analysis on conversation recordings you upload;
To send transactional communications (account confirmation, invoices, service updates);
To detect, investigate, and prevent fraud, abuse, and security incidents;
To comply with legal obligations.

4. Legal basis for processing (GDPR)

Where GDPR applies, we rely on the following legal bases:

Contract: processing necessary to provide the service you have agreed to;
Legal obligation: where we are required to process data under applicable law;
Legitimate interests: for security, fraud prevention, and product improvement, where these interests are not overridden by your rights;
Consent: where you have given explicit consent for a specific processing activity.

Customers are themselves responsible for identifying and documenting their own legal basis for recording conversations and uploading them to Topcloser.

5. Controller and processor roles

For conversation data (recordings, transcripts, analyses), Topcloser acts as a data processor on your behalf. You, as the customer, are the data controller and are responsible for ensuring that the processing of such data is lawful, including informing participants and obtaining any required consents.

For account data and usage data, Topcloser acts as an independent data controller.

6. Subprocessors

We use trusted third-party subprocessors to operate the platform. These include:

Supabase — database and authentication (EU hosting available);
Vercel — application hosting and delivery;
AssemblyAI — audio transcription;
Anthropic — AI analysis (Claude);
Stripe — payment processing.

All subprocessors are bound by data processing agreements and appropriate safeguards.

7. International data transfers

Some of our subprocessors operate outside the European Economic Area (EEA). Where personal data is transferred outside the EEA, we ensure that appropriate safeguards are in place, such as the European Commission's Standard Contractual Clauses (SCCs) or an adequacy decision.

8. Retention

We retain account data for as long as your account is active and for a reasonable period thereafter to comply with legal obligations. Conversation data is retained for as long as your subscription is active or until you delete it. Upon termination of your account, we will delete or anonymize your data within a reasonable period, unless we are required to retain it by law.

9. Security

We implement appropriate technical and organizational security measures to protect personal data against unauthorized access, loss, destruction, or alteration. These measures include access controls, encrypted data transmission (TLS), and role-based permissions within the platform.

No method of transmission over the internet is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

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;
Rectification: request correction of inaccurate data;
Erasure: request deletion of your data (right to be forgotten);
Restriction: request that we restrict processing of your data;
Portability: receive your data in a structured, commonly used format;
Objection: object to processing based on legitimate interests;
Complaint: lodge a complaint with your national data protection authority.

To exercise your rights, contact us at support@topcloser.io. We will respond within 30 days.

11. Cookies

Topcloser uses only strictly necessary cookies and local storage for authentication and session management. We do not use tracking cookies or third-party advertising cookies.

12. Changes to this statement

We may update this Privacy Statement from time to time. We will notify you of material changes via email or an in-app notification. The most recent version is always available on this page.