Last Modified: June 2019
You have the right to make a complaint at any time to the supervisory authority for data protection issues in your country. We would, however, appreciate the chance to address your concerns before you contact the appropriate supervisory authority, so please contact us first.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that individual can be identified. We may collect, use, store and transfer data about you. In order to address this information, we have grouped it together as follows:
- Identity Data includes first name, middle name or initial, last name and title.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Transaction Data includes details about payments from you and other details of products and services you purchased from us.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may also collect, use and share anonymous Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data as this data will not directly or indirectly reveal your identity.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
If You Fail To Provide Personal Data
Please be aware that, if you choose to limit the personal information you provide to us (or provide no personal information at all), then we may be unable to provide you with the services you have expressed an interest in or retained us for.
3. HOW DO WE COLLECT YOUR DATA?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data information by filling in forms or by corresponding with us by mail, phone, email or otherwise. This includes personal data you provide when you:
- purchase our services;
- subscribe to our blog;
- request information from us; or
- contact us for any purpose.
- Automated technologies or interactions. As you interact with our website, we may automatically collect your Technical Data about your computer or mobile device, browsing actions and patterns. We collect this data by using cookies and similar technologies.
- Third parties or publicly available sources. We may receive personal data about you from analytics providers such as Hubspot, Google Analytics and other similar third party automated marketing services.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we use your personal data in the following circumstances:
- to correspond and communicate with you.
- to manage our relationship with you, including where we need to provide services to you, communicate with you and invoice you.
- where we need to comply with a legal obligation.
- where it is necessary for our legitimate interests (or those of a third party) and your interests and rights do not override those interests.
- to inform our marketing strategy and to enhance or personalize our communications with you.
Below is a table that includes a description of all of the ways we plan to use your personal data, and which of the legal basis we rely on to do process your personal data. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||Technical Usage||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|Establishing you as a customer||Identity Contact||Necessary for the performance of a contract with you.|
|Communicating with you for the purposes of providing you with any services which you have ordered or purchased from us||Identity Contact||Necessary for the performance of a contract with you.
Necessary for our legitimate interests in operating our business correctly and promoting our products and services effectively.
|Managing our relationship with you, including reviewing and responding to any questions, feedback or other communications submitted by you||Identify Contact||Necessary for the performance of a contract with you.
Necessary to comply with our legal obligations.
Necessary for our legitimate interests in operating our business correctly, promoting our products and services effectively, developing and improving our products and services and responding to queries or complaints effectively.
|Managing and processing all payments, fees and/or charges and collecting and recovering any sums owed to us.||Identity Contact
|Necessary for the performance of a contract with you.
Necessary for our legitimate interests in processing payments made by our customers and recovering any debts owed to us.
We do not allow your personal data to be used to send third party direct marketing communications to you.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will receive marketing communications from us if you have requested information from us or purchased or services and you have not opted out of receiving that marketing communications.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of purchasing our services.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with our vendors who assist us in providing services to you. For example, we use Federal Express to ship packages and WeTransfer to ship files electronically. Except in connection with providing services you requested, we will not share your personal data with any person or entity outside CAPITAL DATA, CAPITAL DATA ANALYTICS, INC. for any purpose.
6. TRANSFERS OF PERSONAL INFORMATION TO UNITED STATES
7. DATA SECURITY
We have appropriate physical, electronic, and managerial procedures to prevent unauthorized access to or use of your personal data. We will maintain and upgrade our security measures by implementing improved technologies as we deem reasonably necessary to maintain the foregoing procedures.
Please remember that no transmission of data over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security of any information that you transmit to us, and you do so at your own risk. Once we receive your transmission, we use our best efforts to ensure its security on our systems.
8. DATA RETENTION
We are required by law to keep basic information about our customers including Contact, Identity, Financial and Transaction Data, even after your relationship with CAPITAL DATA, CAPITAL DATA ANALYTICS, INC. has ended. Where we have anonymized your personal data so that it can no longer be associated with you we may use this information indefinitely without further notice to you.
9. NOTICE TO RESIDENTS OF EUROPE ECONOMIC AREA AND THE U.K.
Under the GDPR, you have rights under data protection laws in relation to your personal data for the items set forth below.
- Access: Subject to certain exceptions, you have the right to request a copy of the personal information we are processing about you, which we will provide to you in electronic form.
- Rectification: You have the right to require that any incomplete or inaccurate personal information that we process about you is amended.
- Deletion: In certain circumstances, you have the right to request that we delete personal information that we process about you.
- Restriction: You have the right to request that we restrict our processing of your personal information where: (a) you believe such information to be inaccurate, (b) our processing is unlawful but you oppose the deletion of your personal information, (c) we no longer need to process such information for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because we require the information in connection with legal claims, or (d) you have objected to the processing of your personal information.
- Portability: You have the right to request that we transmit the personal information we hold in respect of you to another data controller, where this is (a) personal information which you have provided to us, (b) the processing is by automated means, and (c) we are processing that information on the basis of your consent or in order to perform our obligations under a contract to you.
- Objection: Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defense of a legal claim.
- Withdrawing Consent: If we rely on your consent to process your personal information, you have the right to withdraw your consent at any time. This includes cases where you wish to opt out from marketing messages that you receive from us.
If you wish to exercise any of the rights set out above, please contact our Privacy Manager. Please note that some of these rights may be limited where we have an overriding legitimate interest or legal obligation to continue to process the personal information, or where the personal information may be exempt from disclosure due to applicable law, the applicable rules of professional conduct, attorney-client privilege, legal professional privilege, other applicable privileges or protections, or professional secrecy obligations.
You will not have to pay a fee to access your personal data or to exercise any of the other above-listed rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Requirements From You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated as to our progress with your request(s).
10. CHILDREN’S PRIVACY
Our website is not designed or intended to attract children under the age of 18. We do not knowingly collect personal data from any person we know is a child under the age of 18.
11. NOTICE TO CALIFORNIA RESIDENTS
We do not disclose a user’s personal data to any third-party for such third-party’s direct marketing purposes. Additionally, this website does not monitor or identify “do not track signals” from your computer, and such signals will not impact the operation of this website.