GRADEM AIPRIVACY POLICY
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Privacy Policy

Closers Academy.io — trading as BackPack Closers Community and Gradem AI (The Call Grade)
Last updated: 24 July 2026

Important notice. This Privacy Policy explains how Closers Academy.io ("we", "us", "our") collects, uses, stores, shares, and protects personal data — including through Gradem AI (also referred to as "The Call Grade"), our AI-powered sales call review tool. It is drafted to align with:

This Privacy Policy applies to all users, customers, leads, website visitors, and community members, including anyone who uploads a call recording to Gradem AI.

1. Who We Are

Business Name: Closers Academy.io
Status: Irish Registered Limited Company
Business Location: Ireland
Contact Email: sales@closersacademy.io

We provide online education, training, digital content, live and recorded sessions, community access, a job board relating to remote high-ticket sales, and Gradem AI — a paid, AI-powered tool that reviews and scores uploaded sales call recordings against our sales framework.

2. Scope of This Policy

This Privacy Policy applies when you:

3. Personal Data We Collect

We may collect the following categories of personal data:

3.1 Identity & Contact Data

3.2 Account & Usage Data

3.3 Marketing & Communications Data

3.4 Community & Training Data

3.5 Transaction Data

3.6 Call Recordings, Transcripts & AI-Generated Data (Gradem AI / The Call Grade)

Where you use Gradem AI, we additionally collect and process:

We do not intentionally collect special category data.

4. How We Collect Your Data

We collect data through:

5. How We Use Your Data (Purposes)

We use your data to:

6. Legal Bases for Processing

We process personal data under one or more of the following legal bases:

7. Marketing, Advertising & Tracking

7.1 Marketing Communications

By providing your details, you consent to receiving marketing communications via email, SMS, phone, and digital platforms. You may unsubscribe at any time. Service-related communications will continue where necessary.

7.2 Advertising & Retargeting

We use third-party advertising platforms (e.g. Meta, Google, TikTok) and tracking technologies to measure campaign performance, deliver targeted and retargeted advertisements, and analyse user behaviour and conversion data. This may involve cookies, pixels, and similar technologies.

8. Data Sharing & Third Parties

We may share your data with:

Job Board Data. If you choose to apply for roles advertised on our job board, your data may be shared directly by you with third-party employers, and we are not responsible for how third parties process your data.

9. Gradem AI / The Call Grade — Call Recordings & Third-Party Data

This section applies specifically to Gradem AI. It exists because a sales call recording necessarily contains the voice and statements of someone other than you — typically the prospect on the call — and we want to be direct about how that is handled.

9.1 What happens to a recording you upload

When you upload a call to Gradem AI, the file is stored on Cloudflare R2, sent to AssemblyAI to generate a transcript, and the resulting transcript (plus sampled video frames, where applicable) is sent to Anthropic to generate a score and written feedback against our sales framework. If your call meets the pass threshold, its transcript, score, and feedback may also be made visible to Santino and other authorised BackPack Closers staff for the purpose of the live call review shortlist.

9.2 You are responsible for lawful recording and upload

You confirm, by uploading a call recording, that:

Recording-consent laws vary by country and, in the US, by state. It is your responsibility, not ours, to know and follow the rules that apply to your calls. We act on your instruction as a processor of the recording you choose to upload — you remain responsible, as the party who made and submitted the recording, for the lawfulness of having recorded and shared it.

9.3 Indemnity

You agree to indemnify and hold harmless Closers Academy.io against any claim, loss, liability, fine, or expense arising from your recording, upload, or our processing of a call submitted by you without the necessary lawful basis, notice, or consent.

9.4 Retention of call data

Call recordings, transcripts, sampled frames, and AI-generated scores are retained for as long as your account remains active, or as reasonably necessary to operate the coaching shortlist and resolve any disputes about a review. You may request deletion of a specific call recording and transcript at any time by emailing sales@closersacademy.io; we will delete it unless we are required to retain it for legal, accounting, or dispute-resolution purposes.

9.5 AI limitations

Scores, transcripts, and feedback generated by Gradem AI are produced by automated systems and may contain errors, omissions, or inaccuracies. They are provided for training and educational purposes and are not a certified, professional, or infallible assessment of your call or your performance.

10. International Data Transfers

Your data may be transferred outside Ireland or the UK, including to the United States, where several of our service providers operate — including Anthropic, AssemblyAI, Cloudflare, and Stripe. Where this occurs, we rely on adequacy decisions, Standard Contractual Clauses, or other appropriate safeguards.

11. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes outlined in this Policy, comply with legal and accounting obligations, and defend legal claims or disputes. Access logs and transaction records may be retained for compliance and dispute resolution purposes. Call-specific retention is set out in Section 9.4 above.

12. Data Security

We implement appropriate technical and organisational measures to protect your data, including secure platforms and access controls, encryption where appropriate, and restricted internal access. However, no system can be guaranteed to be 100% secure.

13. Your Data Rights

Depending on your location, you may have the right to access your personal data, rectify inaccurate data, request erasure, restrict or object to processing, withdraw consent, request data portability, and lodge a complaint with a supervisory authority. Requests should be submitted to: sales@closersacademy.io

14. Cookies

We use cookies and similar technologies to operate and improve our website and marketing. See the Cookie Policy below for details.

15. Children

Our services, including Gradem AI, are not intended for individuals under 18. We do not knowingly collect data from minors.

16. Changes to This Policy

We may update this Privacy Policy from time to time. Continued use of our services constitutes acceptance of the updated Policy.

17. Contact Us

For privacy-related questions or requests, email: sales@closersacademy.io

Cookie Policy

This Cookie Policy explains how Closers Academy.io uses cookies and similar technologies when you visit our website, landing pages, checkout pages, and community platforms.

What Are Cookies?

Cookies are small text files placed on your device that help websites function properly, improve user experience, and provide analytics and marketing insights.

Types of Cookies We Use

Third-Party Cookies

We may allow third-party service providers (including Meta, Google, Stripe, Kajabi, Skool, and analytics partners) to place cookies on your device for the purposes outlined above. These third parties process data in accordance with their own privacy policies.

Managing Cookies

You can manage or disable cookies through your browser settings. Please note that disabling certain cookies may impact functionality or access to parts of our services. By continuing to use our website and services, you consent to the use of cookies in accordance with this policy.

Advertising & Platform Compliance Disclosure

Our marketing practices comply with the requirements of Meta, Google, and other advertising platforms. By submitting your details through any advertisement, form, or landing page, you acknowledge that you are providing your information voluntarily, your data may be used for marketing, retargeting, and conversion tracking purposes, and results, earnings, or outcomes shown in marketing materials are illustrative only and not guarantees. All testimonials, case studies, and examples are individual experiences and may not be representative of typical results.

Platform, Payment Processor & AI Provider Data Use

We deliver our services through third-party platforms including (but not limited to): Kajabi (course hosting), Skool or equivalent community platforms, Stripe (payment processing), Zoom (live training sessions), Cloudflare R2 (call recording storage for Gradem AI), AssemblyAI (call transcription for Gradem AI), and Anthropic (AI-generated scoring and feedback for Gradem AI). Data shared with these platforms is limited to what is necessary to provide access, process payments, manage accounts, and deliver services. Each platform acts as an independent data processor under its own privacy framework.

Data Processing & International Transfers

Where third-party platforms process personal data on our behalf, they do so under appropriate Data Processing Agreements (DPAs) and safeguards, including Standard Contractual Clauses where required. Your data may be transferred outside the EEA or UK. In such cases, we ensure appropriate legal safeguards are in place.

Consistency With Terms & Conditions

This Privacy Policy is intended to operate alongside and consistently with our Terms and Conditions. In the event of any conflict, the Terms and Conditions shall prevail in respect of contractual matters, and this Privacy Policy shall govern data protection matters.

Administrative Fees & Data Handling Costs

Where a refund is issued in accordance with our Terms and Conditions, we reserve the right to deduct a reasonable administrative fee to cover costs already incurred, including but not limited to payment processing and transaction fees, platform access setup and revocation, customer onboarding and account administration, and compliance, record-keeping, and data handling obligations. Such administrative fees reflect genuine costs incurred and are not imposed as a penalty. Further details regarding refunds and applicable deductions are set out in our Terms and Conditions.

Data Breach Response & Security Incidents

We take the security of personal data seriously and implement appropriate technical and organisational measures designed to protect your information against unauthorised access, alteration, disclosure, or destruction. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will, where required by applicable law, investigate the incident without undue delay, take appropriate steps to contain, remedy, and mitigate the effects of the breach, notify the relevant supervisory authority within the legally prescribed timeframe, and inform affected individuals where notification is required by law.

You acknowledge that no system, transmission method, or storage solution is entirely secure. While we take reasonable and proportionate steps to safeguard your personal data, we cannot guarantee absolute security. To the fullest extent permitted by law, Closers Academy.io shall not be liable for any unauthorised access, loss, disclosure, alteration, or destruction of personal data unless such incident arises directly from our failure to implement appropriate technical and organisational safeguards.

Cookie Banner Notice

"We use cookies to improve your experience, deliver personalised content and ads, and analyse our traffic. By clicking 'Accept', you consent to the use of cookies as described in our Privacy & Cookie Policy. You can manage your preferences at any time."

By clicking Accept, you provide explicit consent for the use of non-essential cookies, including analytics and marketing cookies, in accordance with UK GDPR, EU GDPR, and advertising platform requirements.

Meta (Facebook / Instagram) Lead Form Privacy Notice

When you submit your information via a Meta (Facebook or Instagram) lead form, you acknowledge and agree that you are providing your personal information voluntarily, your information will be used to contact you regarding online education, training, coaching, and related offers from Closers Academy.io, your data may be stored, processed, and used for marketing, follow-up communications, retargeting, and conversion tracking, and your information may be processed using third-party systems including CRM platforms, email marketing tools, and advertising platforms. Meta Platforms, Inc. acts as a separate data controller in respect of information collected via its lead forms. Their processing of your data is governed by Meta's own privacy policy. By submitting a Meta lead form, you confirm that you have read and agree to this Privacy Policy and consent to being contacted by Closers Academy.io.

Questions about this policy: sales@closersacademy.io — or read our Terms & Conditions.