Privacy Policy

CloseLeads AI is operated by the founder João Pedro Almeida Santos Torrinhas, an individual based in Portugal — “we”, “us” or “our” in this policy.

CloseLeads AI gives fitness professionals (“trainers”) an AI agent that talks to people interested in their services (“leads”). This policy covers both groups: trainers who create an account, and leads who chat with a trainer's agent.

For trainers' account data (your name, email, billing and how you use the product), we are the data controller: we decide how and why that data is used.

For leads' data (what a lead shares in a conversation with a trainer's agent), the trainer is the data controller and we act as their processor. We process that data only to provide the service to the trainer and on their instructions. If you are a lead and want to exercise your rights, contact the trainer first — or write to us and we will pass your request on.

If you are a trainer:

• Account details: name, email address, password (stored securely by our authentication provider, never in plain text) and, if you add it, your phone number.
• Your agent's setup: business name, specialization, website, tone, extra instructions, services and prices, questions and settings.
• Billing details: your plan and subscription status. Card details are entered on and handled by Stripe — we never see or store your full card number.
• Messages you send us through the contact form or by email.
• Basic, anonymous usage statistics about visits to our website (see section 8).

If you are a lead chatting with a trainer's agent:

• The messages you exchange with the agent.
• Details you choose to share, such as your name, phone number, email, goal, training experience, availability, training preference, start date, budget, age and diet.
• Information the agent produces from the conversation for the trainer: a short summary, your level of interest, a suggested next step, and whether the trainer should step in personally.

Please don't share more about your health than you need to. The agent is not a medical service: questions of a medical nature are handed to the trainer.

• To provide the service — run your account and agent, generate replies, qualify leads and show them on your dashboard (performance of a contract).
• To bill you — process subscriptions and keep invoices (performance of a contract and legal obligation).
• To send service emails — account confirmation, password resets, new interested leads, handoffs and plan limits (performance of a contract). You can turn some notifications off in your settings.
• To keep the service secure and working — prevent abuse, apply usage limits and fix problems (legitimate interests).
• To answer you — when you contact us (legitimate interests).

The conversation and the trainer's agent setup are sent to our AI provider, which we use to:

• write the agent's replies to the lead;
• summarise the conversation for the trainer, with the details the lead shared;
• estimate how interested the lead is and suggest the trainer's next step;
• flag when the trainer should step in personally, such as for a medical question.

Under the AI provider's terms for business use, the data we send is not used to train its models.

When a trainer uses the preview chat to test their own agent, the test conversation is processed in the same way but is not saved: no lead is created and nothing appears on the dashboard.

The agent's answers are generated automatically and can contain mistakes. The agent does not make decisions with legal or similarly significant effects about anyone; every follow-up is up to the trainer.

We never sell personal data. We share it only with service providers that process it on our behalf, under contract, to run the service:

• Hosting and database providers — to run the website and the application, and store data.
• Authentication provider — to manage accounts and logins.
• AI provider — to generate the agent's replies, summaries and suggestions.
• Email delivery provider — to send account and notification emails.
• Stripe — to process payments and subscriptions.
• Website analytics provider — for anonymous visit statistics.

Lead data is also shown to the trainer whose agent the lead talked to — that is the purpose of the service. We may also disclose data when required by law.

Some of these providers are located, or process data, outside the European Economic Area. In those cases the transfer is protected by an adequacy decision (such as the EU–US Data Privacy Framework) or by the European Commission's Standard Contractual Clauses.

• Trainer accounts — for as long as the account is active. When you ask us to delete your account, we delete your data within 30 days.
• Lead data — for as long as the trainer's account is active, unless the trainer or the lead asks us to delete it sooner. It is deleted together with the trainer's account.
• Billing records — for the period required by Portuguese tax law, even after an account is deleted.
• Messages to support — for as long as needed to deal with your request.

We don't use advertising or tracking cookies. When you log in, your browser stores a session token so you stay signed in — this is strictly necessary for the service to work.

Our visit statistics are collected without cookies and without identifying you personally.

Data is encrypted in transit (HTTPS), passwords are never stored in plain text, and access to personal data is limited to what is needed to run and support the service. No system is perfectly secure, but if a breach affects your data we will notify you and the authorities as the law requires.

Wherever you live, you have the right to the following. If you are in the European Economic Area or the United Kingdom, these rights are also guaranteed by the GDPR.

• access the personal data we hold about you and get a copy of it;
• correct data that is wrong or incomplete;
• have your data deleted;
• restrict or object to how we use it;
• receive your data in a portable format.

To exercise any of these rights, email support@closeleadsai.com. We will answer within one month. If you are a lead, the trainer you talked to is responsible for your data — we will forward your request to them if needed.

You can also complain to the Portuguese data protection authority, the Comissão Nacional de Proteção de Dados (cnpd.pt), or to the authority in the EU country where you live.

Trainer accounts are only for people aged 18 or over. Agents are not meant for children under 16; if you believe a child has shared personal data with an agent, contact us and we will delete it.

We may update this policy as the product changes. The date at the top shows when it was last changed. If the changes are significant, we will let trainers know by email before they take effect.