Privacy Policy
Last updated: December 27, 2025
At Qloser, we deeply value your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, and safeguard your data when you use the Qloser mobile application ("App") and our associated services.
By using Qloser, you agree to the collection and use of information in accordance with this policy. We designed our App with privacy in mind – Qloser does not require account creation, and your interactions with question cards remain on your device.
1. Information We Collect
1.1 Information You Provide
Qloser does not require you to create an account or provide any personal information such as your name, email address, or phone number. This applies to use of the app. If you apply to the Qloser Creator Programme, we do collect personal information from you — see section 12 below. The App contains pre-made conversation cards, and you cannot add your own content to the App.
1.2 Automatically Collected Information
When you use Qloser, we automatically collect certain technical information:
- Device Information: Device model, manufacturer, operating system and version, unique device identifiers
- Usage Data: App features used, session duration, interaction patterns with question categories and cards
- Technical Data: IP address, crash logs, performance data
1.3 Locally Stored Data
Your favorited questions, game progress, and preferences are stored locally on your device. We do not have access to this information, and it is not transmitted to our servers.
2. How We Use Your Information
We use the collected information for the following purposes:
- To provide, maintain, and improve the App
- To understand how users interact with our App and which features are most valuable
- To detect, diagnose, and fix technical issues and crashes
3. Third-Party Services
We use the following third-party services to operate and improve Qloser:
3.1 Firebase Analytics (Google LLC)
We use Firebase Analytics to understand how users interact with our App. This service collects anonymized usage data such as session information, feature usage, and general location (country level).
Privacy Policy3.2 Firebase Crashlytics (Google LLC)
We use Crashlytics to identify and fix bugs and crashes. When a crash occurs, Crashlytics collects device information and crash logs to help us diagnose the issue.
Privacy Policy3.3 RevenueCat Inc.
We use RevenueCat to manage in-app purchases and subscriptions. RevenueCat processes transaction data provided by Apple App Store and Google Play Store.
Privacy Policy4. International Data Transfers
Your information may be transferred to and processed in countries other than your own, including the United States, where our third-party service providers operate. These countries may have different data protection laws than your country of residence.
When we transfer data internationally, we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission where applicable.
5. Data Retention
Since Qloser does not require account creation, we do not store personal data that directly identifies you. Anonymized analytics and crash data are retained for up to 14 months to help us understand long-term usage trends and improve the App.
6. Data Security
We take the security of your data seriously and implement appropriate technical and organizational measures to protect it. However, no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.
7. Your Rights
Depending on your location, you may have the following rights regarding your personal data:
For Users in the European Economic Area (EEA), United Kingdom, and Switzerland:
Under the General Data Protection Regulation (GDPR), you have the right to:
- Access: Request a copy of the data we hold about you
- Rectification: Request correction of inaccurate data
- Erasure: Request deletion of your data ("right to be forgotten")
To exercise these rights, please contact us at [email protected].
You also have the right to lodge a complaint with your local data protection authority if you believe we have violated your privacy rights.
For Users in California:
Under the California Consumer Privacy Act (CCPA), you have the right to know what personal information we collect, request deletion of your data, and opt out of the sale of personal information. We do not sell personal information.
8. Children's Privacy
Qloser is not intended for use by children under the age of 13 (or 16 in the European Economic Area). We do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at [email protected], and we will take steps to delete such information.
9. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy within the App and updating the "Last updated" date at the top of this page.
We encourage you to review this Privacy Policy periodically for any changes. Your continued use of the App after any modifications indicates your acceptance of the updated Privacy Policy.
10. Contact Us
Qloser is operated by:
Wisefy OÜ
Registry code: 14466953
Mai tn 24-100 80045 Pärnu linn, Pärnu maakond Estonia
If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us at the email address above.
11. Legal Basis for Processing (EEA Users)
For users in the European Economic Area, we process your data based on the following legal grounds:
| Purpose | Legal Basis |
|---|---|
| App functionality and performance | Legitimate interest |
| Analytics and improvement | Legitimate interest |
| Crash reporting and bug fixes | Legitimate interest |
| Processing payments | Contract performance |
| Legal compliance | Legal obligation |
You have the right to object to processing based on legitimate interest by contacting us at [email protected].
12. Qloser Creator Programme
This section applies only if you apply to or take part in the Qloser Creator Programme. It does not apply to ordinary use of the app, which is covered by the sections above.
12.1 What We Collect
- Name, email address and country of residence
- Date of birth, to confirm you are 18 or over
- Social media handles and links to content you submit with your application
- Your answers to the application questions
- Videos you submit, which contain your image, voice and likeness
- Payment details and, where required, tax information
We do not collect or store copies of identity documents. Identity is verified by our payment provider as part of setting up payment to you.
12.2 Why We Use It
To assess your application, decide who joins the programme, communicate with you, commission and review content, make payments, prevent fraud, and meet our accounting and tax obligations.
12.3 Legal Basis
| Purpose | Legal Basis |
|---|---|
| Reviewing your application | Steps prior to entering a contract |
| Running the programme and paying you | Contract performance |
| Using your content in advertising | Contract performance (Creator Agreement) |
| Fraud prevention | Legitimate interest |
| Accounting and tax records | Legal obligation |
12.4 Who We Share It With
- Tally — hosts the application form and stores your submitted answers
- Wise — processes payments to you and verifies your identity
- TikTok and Meta — where you authorise advertising on your posts, these platforms process the content and its performance data
We do not sell your personal information and we do not share it for advertising unrelated to this programme.
12.5 How Long We Keep It
- Unsuccessful applications — deleted within 6 months, unless you ask us to keep you on file for future rounds
- Accepted creators — kept for the duration of your participation and for 3 years afterwards
- Payment and tax records — kept for 7 years, as Estonian accounting law requires
- Submitted videos — kept for as long as the licence in the Creator Agreement runs
12.6 International Transfers
The programme is open to creators in the United States, United Kingdom, Canada, Australia, New Zealand and Ireland. Your data is processed in Estonia and by the providers listed above, which may process it outside your country. Where data leaves the EEA or the UK, transfers rely on the European Commission's Standard Contractual Clauses or an adequacy decision.
12.7 Your Rights
The rights described in section 7 apply to creator data as well. To exercise them, or to ask what we hold about you, email [email protected].