Legal
Privacy Policy
Last updated: 15 November 2026
1. Introduction
This Privacy Policy describes how LB FRAME ("we," "us," or "our"), a simplified single-shareholder joint-stock company (SASU) registered in Salon-de-Provence, France, collects, uses, and protects your personal data when you use Klozeo (the lead database), its API, its MCP server and the apps you connect to it (the "Service").
This policy is written in compliance with the General Data Protection Regulation (GDPR), the French Data Protection Act (loi Informatique et Libertés), and other applicable laws. It is also available in French.
Our dual role under GDPR
Data Controller: we determine how and why your account, billing, and usage data are processed.
Data Processor: for the lead data you upload to Klozeo, including leads a connected app saves there at your request, you remain the Data Controller. We process that data exclusively on your behalf and according to your instructions, including when you ask a connected app to read or change it. Our Data Processing Agreement, part of the Terms of Service, governs this processing from the day you create your account.
2. What personal data we collect
2.1 Account data
When you create an account, we collect:
- Email address
- Email verification date (account metadata)
- Name (if provided)
- Password (stored as a hash, never in plain text)
- Team memberships and roles, if you join or invite a team. The owner and the active members of each workspace you are in see your email address (Section 9.6)
- For each session: IP address and browser (user agent)
- The source of your first visit, only if you accepted it in the cookie banner and your browser still holds it when you sign up: the page that referred you, the landing page and the campaign parameters of the link (Section 7.2)
2.2 Lead data (your content)
We store the canonical 9-digit SIREN, including when you submit a SIRET, to identify and deduplicate leads. For a sole proprietor, this identifier can identify a natural person. It appears in lead reads, exports and configured webhooks; the SIRET establishment suffix is not stored or sent.
You control what lead data you store. This data belongs to you. Typical fields include:
- Business names and contact information
- Addresses and geographic location data
- Phone numbers and email addresses
- Website URLs and social media links
- Categories, tags and custom attributes
- Notes and scoring data
We also keep the history of lead creation, updates, merges and deletions: action, date, actor and values before and after the change. The values before and after in the history of a lead deleted more than 30 days ago, including note text and the assignee, are erased by a daily job, so they are gone within 31 days of the deletion. The action, the date, the member or API key that acted, the channel, the reason and the names of the changed fields remain. Backups keep those values for up to 90 days after the erase. The history of a lead that is not deleted is not purged, including the text of a deleted note.
2.3 Usage and monitoring data
We measure audience without cookies and collect error reports to keep the Service running. See Section 6.
2.4 API usage data
When you use the Klozeo API, we log request metadata (endpoint, timestamp, HTTP status, rate-limit counters) to enforce plan limits and ensure service stability. This data does not include request payloads.
2.5 Connected apps
When you connect an app or AI assistant, we record the connection (the app's name and the access it received). See Section 8. We also keep the origin and date of your first connection per channel (Claude, ChatGPT or other) until your account is deleted, even after you disconnect the app. If you create your account from a connected app, we also keep that sign-up origin (Claude, ChatGPT or other) and the app's OAuth client identifier until your account is deleted.
2.6 Payment data
Payments are processed by Stripe Payments Europe, Limited (Ireland). When you create an account, we create a Stripe customer with your email address, your name and your Klozeo account identifier. When you subscribe, you enter your payment details directly with Stripe: we never receive or store card numbers.
Klozeo stores your Stripe customer identifier and, for each subscription, its Stripe identifiers, plan, status, billing period, trial dates, cancellation and end dates, number of seats and billing interval. See Stripe's Privacy Policy for what Stripe collects.
2.7 Waitlist, newsletter and guides
Waitlist: your email address, the plan you are interested in, where you signed up and the page that referred you. We use it to tell you when sign-ups reopen.
Leads Bible guide (PDF): your first name, your email address and your answer to “your biggest challenge”; the form can also send a name, a company size and an industry. We record when the guide was sent, whether and when you downloaded it, and when the two follow-up emails were sent. We use these data to send you the download link and two follow-up emails, 2 and 7 days after the download, only while you have a confirmed newsletter subscription and have not unsubscribed. The request is stored in Klozeo’s database with its own unsubscribe link; it does not create a newsletter record.
Newsletter: the form collects only your email address. Klozeo’s database stores that address, the “newsletter” source, subscription status, creation, sending and confirmation dates, confirmation and unsubscribe tokens, and the confirmation expiry date. Confirmation emails are sent through Resend (Section 9.1).
Unsubscribing: the newsletter record is deleted. Only your normalized email address (lowercase, with leading and trailing spaces removed) remains in an opposition list in Klozeo’s database, without a name, token or date. This list prevents newsletter and guide follow-up emails and is kept after account deletion. The guide request has its own retention period (Section 10.3).
2.8 Messages you send us
When you write to us through the contact form or by email, we receive your name, email address and message.
To count accepted contacts, we retain a technical event for 400 days: pseudonymous metadata with no directly identifying data (random identifier and exact date-time only, without name, email, message or IP). This timestamp can be matched to that of the received message.
2.9 Anti-abuse counters
To limit login attempts and abusive email requests, we use shared counters per IP address (IPv4) or network prefix (IPv6 /64 and /48), and per email address for guide and newsletter requests. These identifiers are hashed before storage in Klozeo’s database; counters include request counts, timestamps and an expiry. Hashing is pseudonymization, not anonymization.
These counters are short-lived: a few seconds to two hours, depending on the limit. Expired counters are automatically purged by a task that runs every minute. Temporary in-memory guards also limit requests per IP or network over one minute; they are not stored in the database.
For other authentication routes, technical counters also associate the IP address with the endpoint, without hashing; they are purged after ten minutes of inactivity.
3. How we use your personal data
3.1 Your lead data
- We do not sell your data
- We do not share your data with third parties for marketing or advertising purposes
- We do not use your data to train AI or machine-learning models
- We do not access your lead data except when strictly required to provide technical support at your request
3.2 Account and operational data
We use account and operational data to:
- Provide, operate, and maintain the Service
- Process payments and send billing-related communications
- Send transactional emails (email verification, password resets, team invitations, plan changes, the guide you requested)
- Send guide follow-ups only with your current confirmed newsletter consent
- Send up to two onboarding emails in your first days while your account has no leads, each with a one-click unsubscribe link
- Tailor onboarding and product emails by recording, per account, how it connects to Klozeo (for example n8n, Make, Zapier, our SDKs or an AI assistant, with first and last use) and the language of your browser at sign-up, never the raw technical headers
- Respond to support requests
- Monitor service health, detect abuse, and prevent fraud
- Comply with legal and regulatory obligations
4. Your rights
You have rights over your personal data; we honor them without delay.
4.1 Rights for EU/EEA residents (GDPR)
- Right to access: obtain a copy of the personal data we hold about you
- Right to rectification: correct inaccurate or incomplete data
- Right to erasure: request deletion of your personal data
- Right to restrict processing: restrict certain processing operations
- Right to data portability: receive your data in a machine-readable format
- Right to object: object to processing based on legitimate interests
- Right to lodge a complaint with the CNIL
4.2 Access and export
You can access and export your lead data at any time using the built-in export features (CSV, JSON, XLSX).
4.3 Disconnecting an app
You can disconnect an app or AI assistant at any time; see Section 8.
4.4 Account deletion
You can delete your account yourself: in the dashboard, open Settings → Delete my account. Enter your password and type DELETE to confirm. Once the request is recorded, your access is revoked and deletion of the account and associated data is completed within 30 days, subject to the backup retention periods and legal obligations described in Section 10.3.
Your Stripe subscriptions are cancelled. If no invoice has been finalized, the Stripe customer is deleted; otherwise its profile is anonymized (contact details and metadata are cleared), but invoices already issued are kept for accounting obligations.
If you cannot use this process, email [email protected] or use our contact page. We handle your request within 30 days.
4.5 California residents (CCPA)
- Right to know what personal information is collected and how it is used
- Right to know whether your personal information is sold or disclosed (we do not sell it)
- Right to opt out of the sale of personal information
- Right to access and delete your personal information
- Right to non-discrimination for exercising your privacy rights
5. Legal basis for processing (GDPR Art. 6)
5.1 Contract performance (Art. 6(1)(b))
- Account creation and management
- Processing your lead data as instructed, including through the apps you connect
- Processing payments and managing subscriptions
- Providing customer support
5.2 Legitimate interests (Art. 6(1)(f))
- Maintaining a secure and functional platform, including error monitoring
- Measuring audience without cookies to improve the Service
- Detecting and preventing fraud or abuse
- Helping new accounts get started with up to two onboarding emails, which you can unsubscribe from in one click
- Enforcing our Terms of Service
5.3 Consent (Art. 6(1)(a))
- Newsletter and downloadable guides you subscribe to
- Keeping the source of your first visit and the campaign parameters of your sign-in link (Section 7.2)
- Testing variants of our website pages and measuring the results to improve them (Section 6.2)
5.4 Legal obligation (Art. 6(1)(c))
- Tax and accounting obligations
- Responding to lawful requests from competent authorities
6. Analytics & monitoring
The tools below run on servers operated by LB FRAME. They are not shared with other companies.
6.1 Plausible Analytics (cookieless)
We use Plausible, a privacy-first analytics tool that we host ourselves, to measure aggregate traffic: page views, referrer, device type, browser, country, requests for the guide, and usage events of the website and the dashboard (such as a completed sign-up, a lead created or an export).
Plausible does not use cookies, does not track you across websites and does not store IP addresses. It does not require consent under the GDPR or the ePrivacy Directive, so it runs whether or not you accept the cookie banner.
To stay within that exemption, events go through our own web server before they reach Plausible. Your browser sends only three items: the name of the event, the path of the page (without query string or fragment) and the host of the referring site; the server drops anything else. Plausible receives these three items, your browser's user agent and your network (your IPv4 address, or the first 64 bits of your IPv6 address). It turns the last two into a salted hash that changes every day and into a country, and does not keep the network.
6.2 GrowthBook (A/B tests)
We use GrowthBook, hosted ourselves, to test variants of some pages, only if you accept “Improving the site”. In the dashboard, the variant is computed in your browser from your account identifier, email address and plan.
If you accept “Improving the site” in the cookie banner, your browser creates a random visitor identifier and keeps it for at most 13 months; later visits do not extend this period. When you are not signed in, the variant is computed from this identifier. When a page shows you a variant, your browser sends us this identifier, the name of the test and the variant shown. When you request the Leads Bible guide, subscribe to the newsletter or create an account, your browser also sends this identifier, and we record only that this action took place and when. We never record your email address, name, account or IP address with this data, and we never link it to them. If you refuse, or have not chosen yet, your browser creates no identifier: you always see the standard version of the pages and nothing is sent.
We use this data only to compare the variants of our own pages, as aggregated statistics in GrowthBook. It is not shared with anyone, and we delete it 13 months after recording it. We process it on the basis of your consent (Art. 6(1)(a) GDPR).
You can refuse or withdraw your consent at any time, as easily as you gave it, with the “Cookie settings” link at the bottom of every page of the website except the dashboard, this one included: your browser then deletes the identifier, you always see the standard version of the pages and nothing more is sent. Clearing this website's data in your browser also deletes the identifier and your choice; we ask again on your next visit.
6.3 GlitchTip (error monitoring)
We use GlitchTip, hosted ourselves, to receive technical error traces and a sample of performance traces (about 10%) from the website, the dashboard and the web server: the type of error, where it happened in the code, the page and the browser. These traces contain no cookies and no request content. The IP address is not sent by the application; the error-monitoring server keeps at most a truncated version of it (network prefix), which does not identify you.
8. AI assistants and connected apps
Data exchanged with an assistant
You can connect Klozeo to AI assistants and other apps through its MCP server (mcp.klozeo.com), by OAuth authorization or with an API key. Klozeo never sends your data to an assistant on its own initiative: an assistant receives data only when it calls a Klozeo tool or the Klozeo API on your behalf.
What the assistant reads (lead fields, which may include the contact details of the people in your leads, notes, statistics) is then sent to it and processed by its provider (for example Anthropic, Cursor or OpenAI) under that provider’s own terms and privacy policy, as a recipient you chose. Klozeo does not control that processing, including whether the provider uses it to train its models: check your settings with the provider.
Data also travels the other way. When you ask an assistant to save or update leads, for example with contact details you paste into the conversation, it sends those fields to Klozeo. Klozeo stores them in the connected workspace like any other lead data: the same history and retention periods apply (Section 10.3). The change also triggers the webhooks configured in that workspace, and their destinations receive the lead event (Section 9.2). You can correct or delete these leads from the dashboard or the API, within the limits of your role.
Klozeo also keeps a separate save record for each request an assistant makes to save leads. It prevents a retried request from saving twice and lets Klozeo return the same result again. It links the request to the member and workspace that made it, to the connection used, to the identifiers of the leads concerned, to the outcome for each lead and to a fingerprint of the request. It contains no contact details and no conversation text. Klozeo keeps it for 30 days, then the automatic retention purge deletes it. It is separate from lead history, and disconnecting the assistant does not delete it sooner.
Classic MCP connections (Claude Code, Cursor and other MCP clients)
An OAuth authorization on the classic MCP server gives the app: Full access to your personal workspace, like an API key.
- Read, create, update and delete your leads and their notes
- Import, update, delete and export leads in bulk
- Manage scoring rules, custom attributes and webhooks
- Manage the API keys of your personal workspace
The app receives an API key of your personal workspace. It does not expire: it stays valid until you revoke it. Team workspaces you belong to are not included.
To disconnect the app, revoke its key under Dashboard → API Keys. The key carries the app’s name.
Klozeo records this key under the app’s name, with its creation date.
A Claude connector added with the address https://mcp.klozeo.com/mcp remains a classic connection.
The Klozeo app for ChatGPT
When you connect ChatGPT to Klozeo, you choose the workspace it can access: your own, or a team you are an active member of. Your role in that workspace (owner, admin, editor or viewer) limits what it can do, and is checked again at every request.
At connection, read-only:
- Search your leads and read every field of a lead
- Read the notes attached to a lead
- Read the statistics, categories and cities of the workspace
Permission to make changes is requested separately, the first time ChatGPT needs it. A viewer cannot grant it:
- Add a note to a lead
- Update the fields of a lead
- Add a tag to a lead
A change made through this app can trigger the webhooks configured in this workspace. A notification already sent to a third-party service cannot be recalled or undone.
ChatGPT can never:
- Create or delete leads, edit or delete notes
- Export your data or make bulk changes
- See, create or delete API keys
- Manage webhooks, scoring rules or custom attributes
Duration and revocation:
- The app receives an access token valid for 8 hours, renewed automatically. The connection stays valid as long as it is used at least once every 6 months.
- Permission to make changes is requested separately, the first time the app needs it. Your answer is remembered for this app and this workspace.
- The connection ends, and Klozeo asks for your consent again, if you disconnect the app, change your password, leave the team or lose the role it requires, if the addresses registered by the app change, or if the connection is not used for 6 months.
- Apps that receive the authorization on your own computer (a localhost, 127.0.0.1 or [::1] address) or through a private app scheme see this screen every time.
- You can disconnect this app at any time in Klozeo, under Dashboard → MCP → Connected applications. Access stops at the next request.
Klozeo keeps a record of each connection: app, workspace, role, permissions granted, and the dates of creation, expiry, last use and revocation. Tokens are stored only as hashes, never in plain text. These records are deleted with your account.
Klozeo does not receive your conversations: only the requests ChatGPT sends to Klozeo’s tools, with their parameters (for example the text of a search or a note) and the technical information ChatGPT attaches, such as language or an approximate location. Klozeo never asks for your password or API keys in ChatGPT. What ChatGPT reads is sent to OpenAI and processed under the OpenAI terms that apply to your account: for a personal ChatGPT account, OpenAI’s Privacy Policy; for a business or education plan (such as ChatGPT Business, Enterprise or Edu), your organization’s agreement with OpenAI, such as the OpenAI Services Agreement, and OpenAI’s commitments on business data.
The Klozeo connector for Claude
Claude (claude.ai, Claude Desktop and the mobile apps) connects to Klozeo through Anthropic’s connector system, at https://mcp.klozeo.com/v1/mcp, using OAuth. When you connect Claude, you choose one or more workspaces it can access: your own, or teams you are an active member of. Your role in each workspace (owner, admin, editor or viewer) limits what it can do there, and is checked again at every request. Claude receives the name of each connected workspace, or the owner's email address when a workspace has no name.
At connection, read-only:
- Search your leads and read every field of a lead
- Read the notes attached to a lead
- Read the statistics, categories, cities and statuses of the workspace
Permission to make changes is requested separately, the first time Claude needs it. A viewer cannot grant it:
- Save leads, including contacts you paste into the conversation
- Update an existing lead
- Add a note to a lead
- Add a tag to a lead
A change made through this app can trigger the webhooks configured in this workspace. A notification already sent to a third-party service cannot be recalled or undone.
Claude can never:
- Delete leads, edit or delete notes
- Export your data, import a file or update leads in bulk from a filter
- See, create or delete API keys
- Manage webhooks, scoring rules or custom attributes
Duration and revocation:
- The app receives an access token valid for 8 hours, renewed automatically. The connection stays valid as long as it is used at least once every 6 months.
- Permission to make changes is requested separately, the first time the app needs it. Your answer is remembered for this app and the workspaces you chose. Adding a workspace asks again, in read-only.
- The connection ends, and Klozeo asks for your consent again, if you disconnect the app, change your password, if the addresses registered by the app change, or if the connection is not used for 6 months. If you leave a team or lose the role it requires, that workspace is removed from the connection, which ends when no workspace is left.
- Apps that receive the authorization on your own computer (a localhost, 127.0.0.1 or [::1] address) or through a private app scheme see this screen every time.
- You can disconnect this connector at any time in Klozeo, under Dashboard → MCP → Connected applications. Access stops at the next request.
Klozeo keeps a record of each connection: app, workspaces with the role in each, permissions granted, and the dates of creation, expiry, last use and revocation. Tokens are stored only as hashes, never in plain text. These records are deleted with your account. Klozeo also keeps the date of your first connection through Claude and, if you created your account while connecting Claude, that sign-up origin; both are kept until your account is deleted, even after you disconnect Claude (see Section 2.5).
Klozeo receives only the requests Claude sends to Klozeo’s tools, with their parameters (for example the text of a search or a note, or the contact details you ask it to save) and the technical information that accompanies them; those parameters may repeat parts of your conversation. Klozeo has no access to the rest of your conversations with Claude and never asks for your password or API keys in Claude. What Claude reads is sent to Anthropic and processed under the Anthropic terms that apply to your account: for an individual claude.ai account, Anthropic’s Privacy Policy; for a business plan (such as Team or Enterprise), your organization’s agreement with Anthropic.
Claude Code usually connects to the classic MCP server with an API key, as described in the Claude Code documentation; that access follows the rules for classic MCP connections above. If you use, in Claude Code, a connector added to your claude.ai account, this section applies.
10. Data storage, security and retention
10.1 Data location
10.2 Security measures
- Encryption in transit (HTTPS/TLS) for all data exchanges
- Passwords stored as hashes
- Access controls by workspace and role, API key authentication
- Vulnerability scans (Go and JavaScript dependencies, secrets in the source code, container images) that must pass before every release
No method of internet transmission is 100% secure. We apply industry-standard protections but cannot guarantee absolute security.
10.3 Data retention
- Technical contact events (pseudonymous metadata): 400 days
- A/B test measurement (random visitor identifier, test, variant, actions): 13 months
- Account and lead data: retained for as long as your account is active
- Lead data: permanently deleted within 30 days of account termination
- Lead history: kept for as long as the owner account exists, then deleted with that account. The values in the history of a lead deleted more than 30 days ago (before and after, note text, attribute values, assignee) are erased by a daily job, so they are gone within 31 days of the deletion. The action, date, member or API key that acted, channel, reason and names of the changed fields remain. Backups keep those values for up to 90 days after the erase, so about 120 days after the deletion. The history of a lead that is not deleted is not purged, including the text of a deleted note. Members see each other’s email addresses in the dashboard and, on assigned entries, in the API (Section 9.6). A removed member’s email address stays on those entries until their account is deleted or, for a deleted lead, until its history values are erased. When a member deletes their account, their actor identifier is removed from other owners’ history
- Assistant save records: a separate record per save request, kept 30 days then deleted by the automatic retention purge. It links the member, workspace and connection to the lead identifiers, the outcome and a request fingerprint, with no contact values and no conversation text
- Webhook events: the content of an event is erased as soon as your endpoint accepts it. If delivery fails for good, or the webhook is paused, it is kept 72 hours after the event so that you can redeliver it, then erased. Delivery receipts (event, state, dates, HTTP status), with no lead data, are kept until the webhook or the account is deleted
- Backups: encrypted and stored in Cloudflare R2 (EU jurisdiction), retained for at most 90 days; deleted data may therefore remain in backups for up to 90 days after deletion. The history values of a deleted lead are erased within 31 days of the deletion and may remain in backups for up to 90 days after that erase
- API keys: a key is deleted when you revoke it; only a minimal audit record remains (key name and dates, no fingerprint). Keys and their audit records are deleted with your account
- Newsletter: unsubscribing stops the newsletter and the guide follow-ups immediately. Klozeo then keeps only your email address, in an opposition list, so that we never write to you again; the newsletter record, including any first name and link tokens it contained, is deleted
- Leads Bible guide requests and waitlist: kept for 3 years after our last contact with you. Waitlist entries of people who have not created an account are also deleted 3 months after sign-ups reopen
- Legal obligations: certain data may be retained longer where required by law
An automatic retention purge runs every day at 03:30 UTC. In particular, it applies the guide request and waitlist retention periods, deletes expired temporary authorizations and retries pending account deletions.
11. Children's privacy
Klozeo is a professional tool intended exclusively for users aged 18 years and over. We do not knowingly collect personal data from minors. If you believe a minor has created an account, please email [email protected] and we will delete the account immediately.
12. International data transfers
Lead and account data is stored within the EU. Cloudflare, Discord, Resend and Stripe may process the data listed in Sections 9.1 and 9.3 in the United States. Such transfers comply with applicable data protection requirements, provider by provider:
- Cloudflare, Inc.: certified under the EU-US Data Privacy Framework. If that certification lapses or is invalidated, the European Commission’s Standard Contractual Clauses in its data processing addendum apply
- Discord, Inc.: the Standard Contractual Clauses, which Discord states it uses for transfers outside the EEA. Discord also states that it complies with the EU-US Data Privacy Framework
- Resend (Plus Five Five, Inc.): the Standard Contractual Clauses in its data processing addendum, which stand on their own and do not depend on its EU-US Data Privacy Framework status. Resend also participates in that framework
- Stripe, LLC: the data we send to Stripe goes to Stripe, LLC in the United States under the EU-US Data Privacy Framework (Stripe, LLC is certified). The Standard Contractual Clauses in Stripe’s data transfers addendum are the fallback. Stripe may also pass data to its group companies and sub-processors in other countries, as its data processing agreement allows
If a mechanism above does not apply, or for a provider we add, we rely on other lawful transfer mechanisms recognised under GDPR.
An AI assistant you connect may process the data it reads outside the EU, under its provider's own transfer mechanisms.
13. Changes to this policy
We may update this Privacy Policy to reflect changes in our practices, legal requirements, or the tools we use. When we do, we will update the "Last updated" date at the top of this page. We encourage you to review this policy periodically.
Continued use of the Service after a policy update constitutes your acceptance of the revised policy.
14. Language and disputes
This policy is written in French and in English. The French version prevails in case of discrepancy.
Any dispute relating to this policy falls under the jurisdiction of the courts of the registered office of LB FRAME (Salon-de-Provence, France), subject to mandatory rules protecting consumers and to your right to lodge a complaint with the CNIL.
15. Contact
For any questions about this Privacy Policy or to exercise your rights, email [email protected].
You also have the right to lodge a complaint with the French data protection authority:
CNIL, Commission Nationale de l'Informatique et des Libertés
www.cnil.frLB FRAME
SASU, RCS Salon-de-Provence 103 671 350
765 Boulevard des Ventadouiro, 13300 Salon-de-Provence, France
Publication director: Leonardo Balland