Privacy Policy
This is a translation for your convenience. The legally binding version is the German original at closercart.com/legal/datenschutz.
1. Controller
The controller responsible for data processing on this website and in the CloserCart platform is:
ScaleFaktor L.L.C.
30 N Gould St, Ste N
Sheridan, WY 82801, USA
Email: [email protected]
Since the controller is established outside the EU but the offering is directed at customers in the EU, the General Data Protection Regulation (GDPR, Art. 3 (2) GDPR) applies.
2. Hosting and infrastructure
This website (closercart.com) is delivered via Cloudflare, Inc. (USA). The application (app.closercart.com) is operated at Vercel Inc. (USA). Database, authentication, and file storage run at Supabase with server location Zurich, Switzerland. On access, these providers process technically necessary connection data (in particular IP address, timestamp, page accessed, user agent) to deliver and secure the content. The legal basis is our legitimate interest in a secure and performant operation (Art. 6 (1) lit. f GDPR). Data processing agreements are in place with all infrastructure providers.
3. Registration, account, and contract handling
When you create a CloserCart account, we process the data you provide: email address, company name, selected plan, as well as billing and usage data of your account. The legal basis is contract performance (Art. 6 (1) lit. b GDPR). Login is passwordless via magic links sent to your email address.
If you enter your email address in the first step of the checkout, we also store it together with your plan selection even if you do not complete the checkout. We use this to follow up on started registrations and to be able to contact you with questions about your sign-up (Art. 6 (1) lit. b and f GDPR). You can object to this storage informally by email at any time, in which case we delete the entry.
4. Payment processing
Payment for your CloserCart subscription is handled via Stripe, Inc. or Stripe Payments Europe Ltd. Your payment data (e.g. card details) is collected and processed directly by Stripe; we do not receive full card details. The legal basis is contract performance (Art. 6 (1) lit. b GDPR). The privacy information of Stripe applies in addition.
5. CloserCart as a processor (checkouts of our customers)
Through CloserCart, our customers (providers of coaching and services) handle their own sales. For the end-customer data processed in the course of this, such as name, contact data, contract data, digital signature, as well as the timestamps and IP addresses logged for contract documentation, the respective provider is the controller under data protection law. ScaleFaktor L.L.C. processes this data as a processor pursuant to Art. 28 GDPR exclusively on the provider's instructions. Please direct questions about a specific purchase to the provider you bought from; their legal notice and legal texts can be found directly in the respective checkout.
6. Email delivery
We send transactional emails (e.g. login links, contract and payment notifications) via Postmark (AC PM LLC, USA). In doing so, recipient address, subject, and delivery status are processed (Art. 6 (1) lit. b and f GDPR).
7. Bot protection
To protect forms, we use Cloudflare Turnstile. In doing so, Cloudflare processes technical signals from your browser to detect automated access (Art. 6 (1) lit. f GDPR). No advertising profiles are created.
8. Cookies and local storage
The marketing website works without tracking and analytics cookies and without advertising tracking. In the application, we set exclusively technically necessary cookies for login (session) as well as local storage for settings such as the color scheme. A consent banner is therefore not required (§ 25 (2) TDDDG).
Referral cookie (partner program)
If you access CloserCart via a partner's referral link (closercart.com/via/…), we set a first-party cookie named "cc_ref" with the partner code (storage duration 60 days). It serves exclusively to attribute a later registration to the partner's referral and to credit them their commission. The cookie contains no personal data about you, there is no cross-site tracking and no profiling. The legal basis is our legitimate interest in operating the partner program (Art. 6 (1) lit. f GDPR); as a cookie necessary to provide this service explicitly requested via the referral link, no consent is required (§ 25 (2) no. 2 TDDDG). When you click a referral link, we additionally store the accessed path without IP address and without browser identifier as anonymous click statistics for the partner.
9. Data transfer to third countries
Some of the named providers as well as the controller itself are established in the USA. Insofar as personal data is transferred to the USA, this is done on the basis of EU standard contractual clauses (Art. 46 (2) lit. c GDPR) and, where available, a certification under the EU-U.S. Data Privacy Framework. Contract and end-customer data from the checkouts is stored in Switzerland (Supabase, Zurich), for which an adequacy decision of the EU Commission exists.
10. Storage period
We store account data for the duration of the contractual relationship and delete it thereafter, unless statutory retention obligations (e.g. commercial and tax law periods) apply. Checkout opt-ins without completion (section 3) are deleted on request at any time. Contract documents of the providers are stored on behalf of the respective provider and deleted on their instruction.
11. Your rights
You have the right to access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20), as well as objection to processing based on legitimate interests (Art. 21 GDPR). To exercise these, contact us informally at [email protected]. You also have the right to lodge a complaint with a data protection supervisory authority, for example the supervisory authority of your place of residence.
12. Version of this policy
Version: 10 July 2026. We adapt this policy when our processing activities or the legal situation change; the version published here at the time applies.