Legal · Privacy

Privacy Policy

How Closo collects, uses, licenses, shares, and protects the data you and your connected marketplaces generate — across crosslisting, wholesale, financial analytics, and AI.

Effective date: July 1, 2026 Last updated: July 1, 2026 Version 1.0

This Privacy Policy explains how Closo processes information in connection with our crosslisting, wholesale, financial-analytics, and AI products (together, the "Service"). It is designed to be read together with our Terms of Service. Please read it carefully — several sections describe broad operational rights we exercise over the content and data you connect to Closo, including automatically building wholesale lots, powering recommendations to other users, and training machine-learning models.

By creating an account, connecting a marketplace, installing the browser extension, or otherwise using the Service, you acknowledge the practices described here. Where a specific practice legally requires your separate, affirmative opt-in (for example, "selling" or "sharing" personal information under certain U.S. laws, or providing revenue data to a financing partner), we describe that separate consent in Section 16.

01

Who we are & scope of this policy

Closo ("Closo," "we," "us," "our") operates a multi-tenant software platform for resale sellers who buy and resell fashion and general merchandise across online marketplaces. For the purposes of the EU/UK General Data Protection Regulation ("GDPR") and similar laws, Closo acts as a controller of the personal data described in this policy, and as a processor or service provider where we handle certain data strictly on your documented instructions (for example, listing content we transmit to a marketplace at your direction).

This policy applies to our websites (including closo.co and app.closo.co), the web application, the Closo browser extension, our APIs, and related services. It does not apply to third-party marketplaces (Poshmark, eBay, Mercari, Vinted, Depop, Shopify), payment providers, or other third parties, which are governed by their own privacy policies.

Closo supports six marketplaces — Poshmark, eBay, Mercari, Vinted, Depop, and Shopify. Our plans are Free ($0), Member ($99/yr), Executive ($252/yr), and Pro Trader ($499/yr).

02

Definitions

Capitalized terms have the following meanings throughout this policy:

TermMeaning
Seller / User / youAn individual or business that creates a Closo account and uses the Service.
MarketplaceAny of the connected third-party selling platforms (Poshmark, eBay, Mercari, Vinted, Depop, Shopify).
Listing ContentPhotos, titles, descriptions, categories, attributes, prices, and other product data you create, import, or connect through the Service.
Connected DataData retrieved from a Marketplace via your authenticated session, including listings, orders, sales, prices, and surfaced buyer interactions.
Financial DataRevenue, fees, cost of goods sold (COGS), expenses, payouts, and derived financial metrics.
Platform DataAggregated, de-identified, statistical, derived, or model-level data generated by Closo across its user base. See Section 6.
Wholesale MarketplaceThe Closo feature through which sellers bundle inventory into lots and buyers purchase them.
ExtensionThe Closo browser extension, which performs marketplace-side actions using your existing, logged-in browser session.
ProcessAny operation performed on data — collection, use, storage, disclosure, analysis, licensing, or deletion.
03

Data we collect

We collect the following categories of information. Not every category applies to every user; what we collect depends on the plan you use, the marketplaces you connect, and the features you enable.

3.1 Account & identity data

Name, email address, password credentials (stored only as salted hashes), business name, billing details processed through our payment provider, plan tier, support correspondence, and preferences.

3.2 Marketplace-connection data

When you connect a Marketplace, we collect and process Connected Data surfaced through your authenticated session, including: your listings and inventory; orders and sales history; pricing, offers, and markdowns; shipping and fulfillment status; and buyer-facing interactions to the extent the Marketplace exposes them to you (for example, likes, shares, views, offers, questions, and messages). Where buyer interactions include another person's personal data, we process it as needed to provide the Service to you and consistent with the relevant Marketplace's terms.

3.3 Financial data

Revenue, marketplace and payment fees, COGS, expenses, payouts, and metrics derived from them. If you connect a bank or financial account (for example, via Plaid), we collect the account and transaction data you authorize, solely for the features you enable, such as expense categorization, tax preparation, or financing eligibility.

3.4 Listing content & photos

Product photos, titles, descriptions, categories, sizes, brands, conditions, and other attributes you create, upload, import, or connect. This Listing Content is central to the Service and is subject to the license in Section 5.

3.5 Device & usage data

IP address, browser type, device and operating-system identifiers, extension version, pages and features used, timestamps, referring URLs, diagnostic and crash logs, and cookie or similar identifiers (see Section 17).

3.6 Extension-collected marketplace session data

The Extension operates within your browser using your existing, already-authenticated marketplace session. It reads the marketplace pages and API responses necessary to import listings, publish or update listings, capture sale and inventory state, and perform the actions you request. The Extension does not collect, transmit, or store your marketplace usernames or passwords. See Section 10 for details on session scope.

3.7 Data from third parties

We may receive limited data about you from payment providers, financing partners, analytics vendors, and marketplaces (for example, confirmation that a listing succeeded), which we combine with the data above to operate and improve the Service.

04

How we use your data

We use the data described above for the purposes below. Several of these are broad grants that are core to how Closo works; by using the Service you enable them, subject to the separate opt-ins described in Section 16 where required by law.

PurposeWhat it means
Operate the ServiceAuthenticate you, sync marketplaces, store your inventory, run the app and extension, and provide support.
Crosspost & exportPublish, update, relist, and export your products to multiple Marketplaces on your behalf, keeping titles, photos, and prices synchronized.
Auto-build wholesale lotsAutomatically create and assemble wholesale lots from your inventory, including AI-built lots and price floors, so slow-moving stock can be listed for sale. See Section 7.
List into other stores & the wholesale marketplaceExport or list your products into the Wholesale Marketplace and, where you participate, into other sellers' stores or bundles. See Section 7.
Recommendations & signalsGenerate recommendations, demand and pricing signals, and analytics shown to you and to other users (for example, sourcing suggestions, comparable-price ranges, and demand indicators). See Section 7.
Train & improve ML modelsTrain, evaluate, fine-tune, and improve machine-learning and AI models — using aggregated or de-identified data where feasible, and including your data. See Section 8.
Financial metrics & tax reportsCompute revenue, profit, and expense metrics; prepare tax-report artifacts (e.g. Schedule C summaries), forecasts, and analytics. See Section 9.
Financing eligibilityWith your consent, share revenue data with financing partners to assess funding eligibility. See Section 9.
Benchmarking & market analyticsProduce market-level statistics, benchmarks, trends, and insights, which may be surfaced to you, to other users, or externally in de-identified form. See Section 6.
Safety, security & complianceDetect fraud and abuse, enforce our terms, meet legal obligations, and protect users and the Service.
CommunicationsSend transactional messages and, subject to your preferences and applicable law, product and marketing messages.
Plain-language summary Closo doesn't just store your listings — it acts on them: crossposting them, turning them into wholesale lots, surfacing them and their signals to other sellers and buyers, and learning from them to improve the product for everyone. The sections below spell out the scope of each of these rights.
05

Content & photo license

You retain ownership of your Listing Content. To operate and promote the Service, you grant Closo a worldwide, non-exclusive, royalty-free, transferable, and sublicensable license to host, store, cache, reproduce, adapt, reformat, translate, resize, create derivative works from, publicly display, publicly perform, distribute, and otherwise use your Listing Content — including your product photos, titles, descriptions, and product data.

This license authorizes Closo to use your Listing Content across, without limitation:

  • the Marketplaces you connect, to publish and maintain listings on your behalf;
  • other sellers' stores and bundles, and the Wholesale Marketplace, where your products are offered or exported;
  • Closo's recommendation, signals, benchmarking, and analytics surfaces shown to you and to other users; and
  • Closo's marketing, SEO, and promotional surfaces (for example, demonstrating the Service or featuring listings), used solely to operate and promote the Service.

The license is granted for the purpose of operating and promoting the Service and continues for as long as your Listing Content is present in the Service and as reasonably necessary thereafter (for example, in backups, in already-distributed copies on Marketplaces or in buyers' possession, or where content has been incorporated into aggregated or derived Platform Data). Adapted, aggregated, or derived materials, and copies already distributed to third parties, may persist after deletion of the original. You represent that you have all rights necessary to grant this license and that your Listing Content does not infringe any third party's rights.

Note on distributed copies Once a listing or photo has been published to a Marketplace or transferred to a buyer or another seller, Closo cannot recall those external copies. Deletion within Closo does not delete copies that already left the Service.
06

Data ownership & platform data

As between you and Closo:

  • You own your underlying Listing Content, subject to the license in Section 5.
  • Closo owns all Platform Data — the aggregated, de-identified, statistical, derived, inferred, and model-level data, analytics, insights, market statistics, benchmarks, trained models, and model weights that Closo generates, in whole or in part, from processing data across its users. Platform Data does not identify you or your individual account and is not returned to your ownership upon deletion of your account.

Closo may use, retain, license, and commercialize Platform Data indefinitely, including after your account is closed, provided such use does not re-identify you in a manner prohibited by applicable law.

07

Automated wholesale lots & cross-user features

Closo includes features that act on your inventory automatically and surface data across users. By using the Service you enable the following, subject to the controls in Section 15:

7.1 Automatic lot creation

Closo may automatically create and build wholesale lots from your inventory — including selecting items, grouping them, and setting AI-derived price floors — so that dead or slow-moving stock can be offered for sale through the Wholesale Marketplace. You control whether lots are published for purchase and can adjust or remove them.

7.2 Cross-user recommendations & signals

Data derived from your inventory, pricing, and sales may be used to power recommendations, demand signals, and pricing insights that are shown both to you and to other users — for example, sourcing suggestions, comparable-price ranges, and demand indicators. Where surfaced to other users, this is done in aggregated, de-identified, or listing-level form as appropriate to the feature.

7.3 Listing into other stores & the wholesale marketplace

Where you participate in wholesale or cross-selling features, your products (and their Listing Content) may be exported or listed into the Wholesale Marketplace and into other sellers' stores or bundles, so that other Closo users and buyers can discover and purchase them. Buyer and transaction data arising from these features is processed to complete and support the transaction.

08

Machine learning & model training

Closo trains, evaluates, fine-tunes, and improves machine-learning and AI models — including recommendation, pricing, demand-forecasting, categorization, and other models — using data processed through the Service. This includes your Listing Content, Connected Data, Financial Data, and usage data.

Where feasible, we use aggregated or de-identified data for training and we apply measures to reduce the identifiability of training inputs. However, you acknowledge that your data may be included in training and improvement processes, and that trained models and their outputs are Platform Data owned by Closo (see Section 6). Models may retain patterns learned from data even after the underlying source data is deleted.

We do not use your data to train models on behalf of unrelated third parties for their own independent purposes without an appropriate legal basis. Where applicable law grants you a right to opt out of the use of your personal data for model training, you may exercise it as described in Section 15; opting out does not require Closo to retrain or delete already-trained models.

09

Financial data specifics

Closo computes financial metrics to help you understand and run your business:

  • Tax reports. We use your revenue, fees, COGS, and expense data to prepare tax-oriented summaries (for example, Schedule C category breakdowns). These are informational tools to assist you and your tax professional.
  • Forecasts & analytics. We generate revenue forecasts, profitability analytics, and trends from your Financial Data.
  • Financing eligibility. Only with your separate, affirmative consent, we may share revenue and related data with financing partners (for example, embedded revenue-based-financing providers) to assess your eligibility for funding. See Section 16.
Important disclaimer Closo is not a lender, bank, broker-dealer, investment adviser, accountant, or tax preparer. Financial metrics, forecasts, and tax artifacts are provided for informational purposes only and do not constitute financial, tax, accounting, or legal advice. Financing, if offered, is provided by independent partners under their own terms. Always consult a qualified professional before relying on any figure.
10

Marketplace credentials & the extension

Closo never stores your marketplace passwords. The Closo browser extension performs marketplace-side actions — importing, listing, updating, and capturing sale state — by operating within your browser using your existing, already-authenticated marketplace session. It does not ask for, transmit, or retain your marketplace login credentials.

10.1 Scope of session access

When you direct the Extension to perform an action, it reads and writes only the marketplace pages and API endpoints necessary to complete that action (for example, reading your listings to import them, or submitting a new listing you asked us to crosspost). Where Closo stores marketplace authorization tokens or session artifacts to perform actions you request, they are stored securely and used only to operate the features you have enabled, and can be revoked by disconnecting the marketplace or removing the Extension.

10.2 Your control

You can disconnect any Marketplace, disable, or uninstall the Extension at any time. Doing so stops future session-based actions; it does not retroactively undo listings already published or data already imported.

11

How we share data

We do not sell your personal data for money. We share data in the following circumstances:

  • Service providers & subprocessors. Hosting, payments (Stripe), bank-account linking (Plaid), analytics, communications, and AI/model vendors that process data on our behalf under contract. See Section 12.
  • Marketplaces. To publish, update, and manage listings on your behalf at your direction.
  • Other Closo users & buyers. For wholesale, cross-selling, and recommendation features, your listings and derived signals may be shown to, and transacted with, other users and buyers (see Section 7).
  • Financing partners. With your consent, revenue and related data to assess funding eligibility (see Section 9).
  • Legal, safety & compliance. To comply with law, respond to lawful requests, enforce our terms, or protect the rights, safety, and property of Closo, our users, or others.
  • Business transfers. In connection with a merger, acquisition, financing, reorganization, or sale of assets, data may be transferred as part of that transaction, subject to this policy or a successor policy.
  • Aggregated / de-identified data. Platform Data may be shared or published without restriction, as it does not identify you.

Certain cross-user or cross-context disclosures (for example, some advertising or benchmarking uses) may be considered a "sale" or "share" of personal information under some U.S. laws. Where that is the case, we honor opt-outs as described in Section 14.

12

Subprocessors

We engage vetted third parties to process data on our behalf under contractual data-protection obligations. Representative categories and providers include:

CategoryExample provider(s)Purpose
Cloud hosting & infrastructureCloud/data-center providersRun and store the Service.
PaymentsStripeProcess subscriptions and payments.
Bank-account linkingPlaidConnect financial accounts you authorize.
AI / model vendorsAI/ML service providersSupport recommendation, forecasting, and generative features.
Analytics & monitoringProduct analytics / error monitoringUnderstand usage and maintain reliability.
CommunicationsEmail / messaging providersSend transactional and product messages.
Financing partnersEmbedded-finance providersAssess funding eligibility (with consent).

A current list of subprocessors is available on request at support@closo.co. We remain responsible for our subprocessors' handling of personal data on our behalf.

13

Legal bases for processing (GDPR / UK GDPR)

If you are in the European Economic Area, the United Kingdom, or another jurisdiction requiring a legal basis, we rely on:

  • Performance of a contract — to operate the Service you requested, including crossposting, imports, and account management.
  • Legitimate interests — to secure, improve, and analyze the Service; to build recommendations, signals, benchmarking, and Platform Data; and to train and improve models, balanced against your rights.
  • Consent — for specific processing that requires it, such as certain marketing, financing-partner data sharing, and, where required, model-training or "sale/share" of personal data. You may withdraw consent at any time.
  • Legal obligation — to comply with applicable laws, including tax, accounting, and law-enforcement requirements.

Where we rely on legitimate interests, you may object as described in Section 15.

14

U.S. state privacy rights (CCPA / CPRA and similar)

If you are a resident of California or another U.S. state with a comprehensive privacy law, you have rights to know/access, delete, correct, and obtain a portable copy of your personal information, and to opt out of the "sale" or "sharing" of personal information and of certain profiling. We do not knowingly sell the personal information of individuals under 18. We do not use or disclose sensitive personal information for purposes beyond those permitted by applicable law.

To exercise these rights, use the mechanisms in Section 15, including a "Do Not Sell or Share My Personal Information" request. We honor recognized opt-out preference signals (such as Global Privacy Control) where required. We will not discriminate against you for exercising your rights. You may use an authorized agent, subject to verification.

15

Your rights & choices

Subject to your jurisdiction and applicable exceptions, you may exercise the following rights. Verified requests are typically answered within the timeframe your law requires (for example, 30–45 days).

Access

Get a copy of the personal data we hold about you.

Correction

Fix inaccurate or incomplete personal data.

Deletion

Request deletion, subject to legal and operational exceptions.

Portability

Receive certain data in a portable, machine-readable format.

Opt-out of sale/share

Opt out of any "sale" or "sharing" of personal information.

Opt-out of model training

Where legally required, opt out of use of your personal data to train models.

Object / restrict

Object to or restrict processing based on legitimate interests.

Withdraw consent

Withdraw any consent you previously gave, without affecting prior processing.

To make a request, email support@closo.co or use the in-app privacy controls. We may need to verify your identity before acting. Some data — such as already-distributed listing copies, aggregated Platform Data, trained models, and records we must retain by law — may not be fully deletable or reversible, as described in Sections 5, 6, and 8.

16

Consent mechanics

General acceptance. When you sign up, connect a Marketplace, install the Extension, or use the Service, you agree to this Privacy Policy and to the operational uses described in Sections 48 (operating the Service, crossposting, automated wholesale-lot creation, cross-user recommendations, benchmarking, and model training on an aggregated/de-identified-where-feasible basis).

Separate opt-in where required. For processing that law requires be based on affirmative, granular consent, we obtain a separate opt-in — presented distinctly from general acceptance — including:

  • Selling or sharing personal information in a manner requiring opt-in consent in your jurisdiction;
  • Financing: sharing your revenue and related data with a financing partner to assess funding eligibility;
  • Model training using your personal data where opt-in consent is legally required; and
  • Non-transactional marketing where consent is required.

You can withdraw any such consent at any time via in-app settings or by emailing support@closo.co. Withdrawal is prospective and does not affect processing already carried out or trained models already produced.

17

Cookies & tracking

We use cookies and similar technologies to keep you signed in, remember preferences, secure the Service, measure performance, and understand usage. Some are strictly necessary; others (analytics and, where used, marketing) are optional and controllable through your browser settings, our cookie controls where presented, or recognized opt-out signals. Disabling some cookies may affect functionality.

18

Data retention

We retain personal data for as long as your account is active and as needed to provide the Service, then for the period necessary to satisfy the purposes described here — including legal, tax, accounting, dispute-resolution, and security obligations. Retention periods vary by data type; for example, financial and tax-related records may be retained for the statutory period. After the applicable period, we delete or de-identify data. As noted above, aggregated Platform Data, trained models, distributed listing copies, and backup copies may persist beyond deletion of your account.

19

Security

We implement administrative, technical, and organizational measures designed to protect personal data, including encryption in transit, access controls, credential hashing, and monitoring. As stated in Section 10, we do not store marketplace passwords. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If we become aware of a breach affecting your personal data, we will notify you and regulators as required by law.

20

International data transfers

Closo operates globally and may process and store data in countries other than your own, including the United States and the countries where our subprocessors operate. Where we transfer personal data across borders in a way subject to transfer rules (for example, from the EEA or UK), we use appropriate safeguards such as the European Commission's Standard Contractual Clauses (and the UK Addendum) or another lawful transfer mechanism. You may request more information about these safeguards at support@closo.co.

21

Children

The Service is intended for business users and is not directed to individuals under 18. We do not knowingly collect personal data from anyone under 18. If we learn that we have collected such data, we will delete it. If you believe a minor has provided us data, contact support@closo.co.

22

Changes to this policy

We may update this policy from time to time. When we make material changes, we will update the "Last updated" date and, where required, provide additional notice (for example, by email or in-app). Your continued use of the Service after an update takes effect constitutes acceptance of the revised policy, except where separate consent is legally required for a new use.

23

Contact & Data Protection Officer

For privacy questions or to exercise your rights, contact us:

Data controller
Bewearcy Solution Inc.
Privacy & DPO
Postal address
16192 Coastal Highway, Lewes, Delaware 19958, USA
EU/UK representative
[REPRESENTATIVE, IF APPLICABLE]

If you are in the EEA or UK and believe we have not addressed your concern, you have the right to lodge a complaint with your local supervisory authority.

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