1. Who is the data controller
NexCloser (“we,” “us,” “our”) is the controller of personal data processed in connection with the marketing site, the paid tiers (Closer, Senior, Partner), and our direct communications with you. Skool, Stripe, Vercel, PostHog, and other third-party providers are separate controllers or processors for the data they handle on their own platforms; their privacy policies apply to those operations in parallel with ours.
Privacy contact: info@nexcloser.com
2. What we collect
Information you give us
- Account information: name, email, country, time zone, and (for Senior and Partner) application answers including background, experience, capital, and product ideas.
- Identity verification: where required for higher tiers, government-ID copies, proof of address, or proof of funds. We retain only what is necessary and for as long as the law and our risk management require.
- Payment information: handled and stored by Stripe. We receive a tokenised reference, the last four digits of the card, country of issue, and billing metadata; we never receive or store raw card numbers, CVCs, or full bank details.
- Programme work: deal notes, call recordings (only where you and other participants consent), screen-share artefacts, documents you upload as part of training or review, and Partner work product such as ideation notes and product drafts.
- Communications: emails, support messages, community posts, voice-note submissions, and feedback you send us.
Information collected automatically
- Behavioural analytics via PostHog in anonymous mode: pages visited, click events, device class, browser, approximate location derived from IP (city-level, not street), anonymised session identifiers.
- Server and security logs via Vercel and our infrastructure providers: IP address, user agent, request timestamps, error traces. Used for security, fraud prevention, abuse investigation, and operations.
- Local-storage preferences: theme and language preference. Stored in your browser only.
Information from third parties
We may receive information from Stripe (payment status, dispute notices), Skool (community handle linkage), and, where you authenticate via a social account, the corresponding provider (the basic profile fields you have authorised to share).
3. Why we use it
- To deliver the service: provision your tier access, schedule and run training sessions and 1:1s, attribute deals, calculate and pay commission, run the Partner programme, and provide support.
- To bill and collect payment: via Stripe, including subscriptions, retries, refunds, dispute responses, and invoicing.
- To prevent fraud and abuse: chargeback defence, spam detection, suspicious-activity monitoring, sanctions screening where applicable, and enforcement of the Terms of Service.
- To secure the service: detect, investigate, and respond to attacks, vulnerabilities, and abuse.
- To improve the product: aggregated analytics show which sections are read and which CTAs convert. We do not use this to build profiles or target ads.
- To communicate: cohort updates, training drops, programme announcements, billing notices, policy changes, and (where you opt in) marketing. You can opt out of marketing emails at any time using the unsubscribe link in each email or by writing to info@nexcloser.com.
- To enforce our rights: investigate complaints, defend ourselves in disputes, and protect the rights, safety, and property of NexCloser, our members, our staff, and the public.
- To meet legal obligations: tax, accounting, anti-money-laundering checks where applicable, response to lawful requests, and compliance with court orders.
De-identified and aggregated data. We may de-identify or aggregate personal data so it cannot reasonably be linked to you, and use such data for any lawful purpose, including research, benchmarking, public reporting, and improving our offerings. De-identified data is not subject to the rights described below.
4. Legal bases (EEA, UK, Switzerland)
Where the GDPR or similar law applies, we rely on the following legal bases:
- Performance of a contract: providing paid tiers, attributing and paying commission, processing applications, fulfilling the Partner Agreement.
- Legitimate interests: running and improving the service, securing it, defending fraud and chargebacks, enforcing the Terms, communicating cohort-relevant updates, marketing to existing customers in a balanced way, and protecting our legal rights. We balance these interests against your rights and offer an opt-out where applicable.
- Consent: where required, for example for non-essential cookies, call recording, optional newsletter sign-up, or sensitive uses. You can withdraw consent at any time without affecting prior lawful processing.
- Legal obligation: tax records, anti-fraud, court orders, regulatory cooperation.
- Vital interests and public interest: rare, but possible in safety-related or emergency situations.
5. Cookies and similar technologies
The marketing site sets a small number of first-party cookies and local-storage values:
- Strictly necessary: theme and language preference (stored locally only, no server cookie required).
- Analytics: anonymous PostHog identifiers used to deduplicate sessions and measure aggregate engagement.
- Security and fraud prevention: short-lived tokens used to mitigate automated abuse.
We do not place advertising or cross-site tracking cookies by default. If we add advertising or marketing cookies in the future, we will surface a consent banner first to visitors in jurisdictions where consent is required. Stripe and Skool set their own cookies on their own domains when you transact or log in there; their policies govern that.
You can control cookies via your browser settings. Disabling strictly necessary cookies or local storage may degrade functionality such as theme preference and login.
6. Who we share data with
We share personal data only with service providers, professional advisers, and parties listed below, and only for the purposes described above:
- Skool hosts the community.
- Stripe handles all payment processing and stores card data on our behalf.
- Vercel hosts the marketing site and provides serverless infrastructure.
- PostHog processes anonymised behavioural analytics.
- Email, CRM, and scheduling tooling: providers we engage to send transactional and programme communications and to manage 1:1s. A current list is available at info@nexcloser.com on request.
- Mentors and Senior leads, on a need-to-know basis, when reviewing your deal work or running your 1:1s.
- Professional advisers such as lawyers, accountants, auditors, and insurers when reasonably necessary.
- Acquirers and successors: if NexCloser is involved in a merger, acquisition, financing, restructuring, sale of assets, or bankruptcy, personal data may be transferred to the counterparty subject to a continuation of substantially similar protections.
- Authorities and third parties where we believe in good faith that disclosure is necessary to comply with law, respond to lawful requests, enforce our Terms, investigate fraud, prevent harm, protect rights, or defend claims. We may not be permitted by law to notify you of such disclosures in every case.
We do not sell personal data, we do not share data for cross-context behavioural advertising, and we do not engage in “targeted advertising” as defined by US state privacy laws.
7. International transfers
Several of our providers (Stripe, Vercel, PostHog, Skool) operate from or process data in the United States and other countries. Where we transfer personal data from the EEA, UK, or Switzerland to a country that does not have an adequacy decision, we rely on appropriate safeguards such as the Standard Contractual Clauses, the UK International Data Transfer Addendum, or equivalent mechanisms, supplemented by provider-side certifications and security measures where available. You can request a copy of the relevant safeguard by emailing info@nexcloser.com.
8. How long we keep data
- Account and billing data: while your account is active, plus the period required by tax, accounting, and anti-fraud law (typically 5 to 10 years depending on jurisdiction).
- Programme work (deal notes, recordings, documents): for the duration of your tier participation, plus 24 months after exit unless you request earlier deletion or longer retention is required for legitimate-interest or legal-defence reasons.
- Application data (for Senior and Partner): 24 months after the final decision, regardless of outcome, to support fairness review and re-application.
- Marketing emails: until you unsubscribe, then we keep a minimal suppression record to honour your opt-out.
- Analytics: PostHog raw events retained for up to 12 months. Aggregated metrics may be retained indefinitely.
- Security and audit logs: up to 24 months.
- Support communications: 24 months from the last interaction.
Where retention is required by law, we apply the longer of the periods above and the legal requirement. Data may be retained longer to defend or prosecute legal claims, subject to access being limited.
9. Your rights
Depending on where you live, you may have some or all of the following rights:
- Access: obtain a copy of the personal data we hold about you.
- Correction: correct inaccurate or incomplete data.
- Deletion: ask us to delete your data, subject to retention obligations, ongoing contract performance, fraud prevention, and legal-defence interests.
- Restriction or objection: object to or restrict certain processing, including direct marketing.
- Portability: receive your data in a portable, machine-readable format where the legal basis is contract or consent.
- Withdraw consent: where we rely on consent.
- Complain: to your local data protection authority. We would prefer you tell us first so we can resolve it.
To exercise any of these, email info@nexcloser.com. We may need to verify your identity before acting on a request to prevent unauthorised disclosure. We respond within 30 days, or sooner where the law requires; we may extend by a further two months for complex or numerous requests, with notice. We may decline or limit a request where the law permits or requires, for example where it would compromise another person’s rights, ongoing investigations, trade secrets, or legal-defence interests.
California, Colorado, Virginia, and other US state rights
Residents of states with comprehensive privacy laws have rights similar to those above and the right to non-discrimination for exercising them. We do not sell personal information and we do not engage in targeted advertising as defined under those laws, so there is no “opt out” to exercise for those purposes. You may designate an authorised agent to make a request on your behalf; we may require reasonable proof of authorisation.
10. Children
NexCloser is not directed to anyone under 18 and we do not knowingly collect personal data from minors. If you believe a minor has provided data to us, email info@nexcloser.com and we will delete it after appropriate verification.
11. Security
We use industry-standard administrative, technical, and physical safeguards appropriate to the sensitivity of the data, including TLS in transit, access controls, least-privilege admin access, secret rotation, and provider- side encryption at rest. No system is bulletproof. You are responsible for safeguarding your account credentials and for using up-to-date devices and browsers. If we experience a data breach that triggers a legal notification obligation, we will notify affected individuals and the relevant authorities within the time and in the manner the law requires.
12. Automated decision-making
We do not use solely automated decision-making (including profiling) that produces legal or similarly significant effects on you, except where permitted by law and with appropriate safeguards. Spam detection, fraud-prevention scoring, and analytics that inform human decisions do not constitute solely automated decision-making.
13. Your responsibilities
You confirm that any personal data you submit about other people (prospects, customers, colleagues) was lawfully obtained, that you have any required consents or notices in place, and that you will inform those individuals where required. You will not upload sensitive personal data (such as health, biometric, or government identifiers) to NexCloser other than where we expressly request it for identity verification or compliance.
14. Changes to this policy
We may update this policy as the programme evolves. Material changes will be flagged on the marketing site and inside the community at least 14 days before they take effect. Non-material changes (clarifications, typo fixes, provider name updates) take effect on posting. The effective date at the top of this page reflects the latest revision. Continued use of NexCloser after the effective date constitutes acceptance of the updated policy.
15. Contact
Privacy questions, requests, complaints, and notices: info@nexcloser.com. For everything else, see the contact section of the Terms of Service.