Privacy Policy

Last updated: January 9, 2022

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Your privacy is important to us. This privacy policy (“Privacy Policy”) describes how closest AI (“Closest”) collects, uses, and discloses information with respect to the Site, Application or Services (collectively, the “Platform”). We want to clearly explain the types of information we gather, how it is maintained and used, and how to correct or change it.

1. Definitions

Capitalized terms not otherwise defined herein shall have the meanings ascribed to them in Closest’s Terms of Service.

“Account” means the account you registered for to access and use the Platform.

“Application” means any applications for mobile, tablet and other smart devices and application program interfaces through which Closest provides services, if any.

“Personal Information” means information (which may include sensitive information) relating to an individual who is identifiable or may be identified from that information in conjunction with other information that is in, or is likely to come into Closest’s possession.

“Services” means the services Closest makes available through its site for hosts to list pools and for guests to book such pools.

“Site” means and any other website through which Closest makes Services available.

“Third Parties” means companies or persons not related by common ownership or control (i.e. non-affiliates) or other unrelated individuals. Third Parties may be financial and non-financial companies, or persons other than you or Closest.

“Users” means any individual who accesses or uses the Platform for any reason

2. What types of information does Closest gather about you?

We collect several types of information from and about users of the Platform, including Personal Information by which you may be personally identified, such as name, address, e-mail address, phone number, and any other information Closest obtains about you.

We receive, store and process information, including Personal Information that you make available to Closest by your use of the Platform. We collect this information directly from you when you provide it to us, automatically as you navigate through the Platform, and from Third Parties as described herein.

Information You Provide to Us

In order to register for an Account via the Platform, you must provide a username, email address, level of education, identifying information related to education, and preferences. Closest may store all information for as long as you maintain an Account with Closest. Should you choose to cancel your Account, we will delete your user information upon request.

You make available to us any correspondence or transactions you engage in on the Platform, including but not limited to, posting listings, booking Accommodations, posting reviews or comments, and linking your Account to Third Party websites such as Facebook.

Information We Collect Through Your Use of the Platform

When you use certain features of the Platform, Closest may receive, store and process information about your location, including general information (e.g. IP address, zip code) and more specific information (e.g. GPS-based functionality on mobile devices used to access the Platform).

We may also receive, store and process log data, which is information that is automatically recorded by our servers whenever you access or use the Platform. This information includes your IP address, date and time of access, the hardware and software you are using, referring and exit pages and URLS, the number of clicks, device event information, pages viewed and the order of pages, and the time spent on particular pages.


We use cookies to allow users to log into their Accounts and use the Platform. We may use technologies such as our own cookies to provide you with advertising based on your specific interests or preferences. If you would like to opt-out of receiving behavioral-based advertising from advertising companies with whom we have a relationship, you may do so by visiting the Network Advertising Initiative or Digital Advertising Alliance.

We may participate in demographic, interest, and location-based advertising. If we do so, we will not use Personal Information in conjunction with this information. You may opt out or customize your demographic and interest based settings, on the Google Display Network, using the Ad Settings.

3. How does the Company use and process the information it gathers?

We use information that we collect about you or that you provide to us, including any Personal Information, to enable you to access and use the Platform, connect and communicate with other users, and to foster a trusted and safe environment for users of the Platform. Additionally, we use your information to send you important notices regarding the Platform as well as marketing, advertising and promotional messages that may be of interest to you. You may opt-out from receiving such communications in the “Account” section of the settings

We use information that we collect about you or that you provide to us to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with Third Parties.

We may, either directly or through Third Parties, review, scan or analyze your communications with other users on the Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research and customer support purposes. We will not review, scan, or analyze your communications for sending Third-Party marketing messages to you. We will also not sell these reviews or analyses of communications to Third Parties.

4. How does the Company disclose or share your Personal Information and to whom does it disclose such information?

Information that you provide to create your profile and Listings may be visible to the general public for marketing purposes. Listings may include information such as the city, neighborhood, and approximate geographic location displayed on a map of where the Accommodation is located.

Your profile and Listings may appear as search results on search engines by default. You may opt-out of this feature by changing your settings. Please be aware that Closest does not control the practices of Third Party search engines and as a result, your information may continue to be visible as a search result.

Closest does not share your telephone number with other users without your consent. As a Guest, if you agree to be contacted by Hosts before your request for a Booking has been accepted, and the Host decides to do so, Closest will act as an intermediary and connect you with the Host. We will not share your phone number unless a Booking is confirmed. If a Booking is confirmed, your phone number will become visible to the Host and Guest, and either party may contact one another directly.

Your payment and billing information will never be shared with other users.

We disclose your information to Third Parties as further explained in Section 5 below.

We may, without notice to you, store, transfer and disclose data to the Tax Authority relating to transactions, Bookings, Accommodations and Taxes including but not limited to, Personal Information, Listings, transaction dates and amounts, tax identification numbers, amount of taxes received by Hosts from Guests, or allegedly due, contact information and similar information.

In the event legal enforcement requests information about you, we will use commercially reasonable efforts to notify you (before or after) about such requests unless (i) providing notice is prohibited by the legal process itself, court order or by applicable law, or (ii) providing notice would (a) be futile, (b) be ineffective, (c) create a risk of injury or bodily harm to others or (d) create a risk or increase a risk of fraud upon Closest, its users, or the Platform.

Third Party Access and Use

We may allow our business partners to use their cookies and other tracking technologies on our Platform. We may also, either directly or through Third Parties we engage to provide services to us, track your behavior in utilizing the Platform for purposes of our own customer support, analytics, research, product development, fraud prevention, risk assessment, regulatory compliance, investigation, as well as enable you to use and access the Platform. If you disable cookies, you may lose certain features and functionality of the Application or Site, as cookies are necessary to track and enhance use of and access to the Platform.

At times, you may be directed to Third Party websites and/or offered the option to download an application using a Third Party platform. Hosts may elect to use Third Party services made available through the Closest.

Closest may use social plugins provided and operated by Third Parties such as Facebook’s “Like” button. By clicking on the such social plugin, you may be sending your information to a Third Party. Please be aware that the terms of the Third Party’s privacy policy will apply to your use of any Third Party platforms (e.g. social plugin, website, or applications).

If Closest undertakes or is involved with any merger, acquisition, reorganization, sale of assets, bankruptcy or event of insolvency, then we may sell, transfer or share some or all of our assets including your Personal Information. In this event, we will notify you of the transfer of Personal Information, which may become subject to a different privacy policy.

5. Children Under 13

The Platform is not intended for individuals under the age of thirteen (13), and we request that these individuals do not provide Personal Information through our Application. We do not knowingly collect information from children under thirteen (13) without parental or legal guardian’s consent. Visit the Federal Trade Commission website for more information about the Children’s Online Privacy Protection Act (COPPA).

How to access, change, or delete your information, or cancel your Account You may review, update, correct or delete the Personal Information in your Account. You may cancel your Account entirely by accessing the settings on the Site or Application. Please note that any reviews, forum postings, and materials you have posted may continue to be publicly available on the Site or Application even after you cancel your Account.


We are continuously implementing and updating administrative, technical, and physical security measures to help protect your Personal Information against unauthorized access, destruction or alteration. However, no method of transmission over the Internet, and no method of storing electronic information, can be 100% secure. So, we cannot guarantee the security of your transmissions to us and of your Personal Information that we store.


The Privacy Policy is subject to change. We suggest you review the policy from time to time. If we make changes to the Privacy Policy, we will revise the “Last Updated” date at the top of this policy. Any changes to this policy will become effective when we post the revised Privacy Policy with respect to the Platform. Your use of the Platform following these changes constitutes acceptance of the revised Privacy Policy.


Procedures for local, state and federal information collections / law enforcement requests 

Federal government information collections must comply with the Paperwork Reduction Act. 44 U.S.C. § 3501, et seq. sets forth requirements governing information collections of the public from federal agencies. In the absence of administrative procedures governing an information collection, the collection of information is presumed to be for a law enforcement purpose. 5 C.F.R. § 1320.3(c).

No government law enforcement-related information collections may access Closest subscriber information without a warrant or court order.

State or local agencies may not search listings on Closest’s website for the purpose of identifying individuals in violation of the law without first obtaining a lawfully obtained subpoena or court order prior to the agency’s search of Closest’s website.  City of L.A. v. Patel, 576 U.S. 409, 419 (2015). The information hosts provide to bona fide guests on the Closest platform (“facility”) are electronic communications protected under the law.  Under the Electronic Communications Privacy Act, it is a crime whenever a government employee or agent “intentionally accesses without authorization a facility through which an electronic communication service is provided.” 18 U.S.C. §§ 2701(a)(1) & (b)(2).  Further, consistent with Supreme Court precedent, the Act makes clear that no government employee or agent may access the information, including the address, of a Closest user (“subscriber”) without a warrant issued consistent with state or federal criminal procedures or a court order issued by a court of competent jurisdiction via a showing of facts that the information sought is relevant to an ongoing criminal investigation.  18 U.S.C. §§ 2703(c) & (d).

Closest will respond to lawfully authorized, properly served requests, to the extent permitted by its Terms of Service, Privacy Policy, and US law.  Proper service of government information requests or law enforcement requests should be directed to Closest’s Registered Agent for Service of Process: Closest AI, 12578 Huntington Trace, Alpharetta, GA 30005., 650-248-2400