ClosPrivacy notice
Effective date: 4 November 2026
This notice explains how Synergy Minds (FZE) ("we") handles personal data in connection with Closentry. We act in line with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and, where it applies, the data-protection law of DIFC / ADGM.
1. The software keeps your data on your computers
Closentry runs on your own computers. Bank statements, ledgers, reconciliations, workpapers, the audit trail and settings are stored in folders you control (your Windows profile, %LOCALAPPDATA%\Closentry, and any team folder you choose). The software does not send this data to us or to anyone else, and it does not include analytics, tracking or advertising. It connects to the internet only when you choose to (for example, opening the purchase link in your browser).
The session, audit trail and history saved by the software can be encrypted with your Windows login, and account numbers can be masked in exports (Settings › Privacy & compliance). Errors are written to a crash log on your computer (%LOCALAPPDATA%\Closentry\crash.log); it is not sent anywhere.
2. Data we do process
| What | Why | Legal basis | Kept for |
|---|---|---|---|
| Name, company, business email and phone of the buyer | to issue licence keys and invoices, and to contact you about your licence | contract | the licence term plus 7 years for accounting records |
| The computer code you send us for a computer-bound key | to issue that key | contract | the licence term |
| Messages, diagnostics text or sample files you send to support | to answer your request | contract / legitimate interest | 12 months after the request is closed |
| Payment records | to collect fees and meet tax law | legal obligation | as required by UAE tax law |
| Name, email, firm and message you send through the website's partner, affiliate or contact forms | to answer your application or enquiry | legitimate interest / steps before a contract | 24 months after the last contact |
| Bank details and payout records of partners and affiliates | to pay commission | contract / legal obligation | the partnership plus the accounting-records period above |
We do not sell personal data, and we do not use it for automated decisions about you.
Our website uses no cookies, analytics or advertising trackers. When you arrive through a partner or affiliate link, its referral code (not personal data) is kept in your browser's local storage for 90 days, so the enquiries you send us can be credited to that partner; you can clear it by clearing your browser's site data. Forms on the website are sent by your own email program / through our form provider, name and country.
3. Sharing
We share personal data only with providers who help us run the business (for example, email, accounting and payment services), under contracts that require them to protect it, and with authorities where the law requires. list the providers and the countries they are in, if data leaves the UAE.
4. Your rights
You may ask to access, correct, delete or restrict the processing of your personal data, to object to it, and to receive it in a portable format, as the PDPL and the laws in section 5 allow. Write to privacy email. We answer within 30 days. You may also complain to the UAE Data Office.
5. If you are in the EU, the UK or India
The software itself still sends us nothing (section 1). What follows applies to the personal data in section 2.
European Union / EEA and United Kingdom (GDPR and UK GDPR). Synergy Minds (FZE) is the controller. The legal bases are those in the table in section 2: performance of a contract (Art. 6(1)(b)), our legitimate interest in answering enquiries and running the partner programmes (Art. 6(1)(f)), and legal obligations such as tax records (Art. 6(1)(c)). You have the right to access, correct and erase your data, to restrict or object to its processing, to data portability, and to withdraw consent where we rely on it. You may complain to the supervisory authority where you live or work (in the UK, the Information Commissioner's Office). When personal data goes to a country without an adequacy decision, we use the European Commission's Standard Contractual Clauses (and, for the UK, the UK International Data Transfer Addendum). Our representative in the EU: name and address, or "not required"; in the UK: name and address, or "not required". Data protection officer: name and contact, or "not appointed - not required".
India (Digital Personal Data Protection Act, 2023). We are the Data Fiduciary for the data in section 2 and process it for the purposes stated there, with your consent or for the legitimate uses the Act allows (for example the contract you asked for). You may ask for a summary of your data and its processing, correct, complete, update or erase it, nominate someone to exercise your rights, and raise a grievance with our Grievance Officer: name, email, who replies within 30 days. If you are not satisfied, you may complain to the Data Protection Board of India.
Elsewhere. We apply the same rights wherever we can, and follow the data-protection law that applies to you.
6. Security
We protect the data we hold with access controls, encryption in transit and at rest where available, and need-to-know access for staff.
7. Changes
We will post changes to this notice at https://www.closentry.com and update the effective date.
Contact: Synergy Minds (FZE), Block C VL04-149, SRTI Park, Sharjah, UAE, privacy email