Capitan Systems Limited

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Privacy Policy

Version 1.0 - March 2021

Unless otherwise provided herein, this "Privacy Policy" is subject to the terms of the "Terms and Conditions for the use of www.i-capitan.com" and "Saas Terms and Conditions" and capitalised terms will have the meaning specified in the "Terms and Conditions for the use of www.i-capitan.com" and "Saas Terms and Conditions".

The Supplier reserves the right to change the terms of this "Privacy Policy".

For the purpose of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, (“GDPR”) or any subsequent amendment or replacement or supplementary legislation (together “Data Protection Law”), the data controller is the Supplier.

Collected Information

We may collect and process the following data about You when You use our Site or Services:

Information You give us

You may give us information about You by filling in forms on our Site or Services or by corresponding with us by phone, e-mail or otherwise. This includes information You provide when You register to use our Site or Services, apps, subscribe to our Site or Services, search for content, participate in discussion boards or other social media functions on our Site or Services, enter a competition, promotion or survey and when You report a problem with our Site or Services.

The extent of the information You give us is defined in our Data Protection Policy.

Information we collect about You

With regard to use of our Site or Services we may automatically collect the following information:

  1. technical information, including the Internet protocol (IP) address used to connect Your computer to the Internet, Your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  2. information about Your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site or Services (including date and time);
  3. content You viewed or searched for;
  4. page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Information we receive from other sources

We may receive information about You if You use the Site or Services. In this case we will have informed You when we collected that data that it may be shared internally and combined with data collected on  through our Site or Services.

We may work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about You from them.

Use of Information

We use information held about You in the following ways.

Information You give to us

We will use this information:

  1. to carry out our obligations arising from any contracts entered into between You and us;
  2. to provide You with the information, products and services that You request from us;
  3. to provide You with information about other goods and services we offer that are similar to those that You have already purchased or enquired about;
  4. to provide You, or permit selected third parties to provide You, with information about goods or services we feel may interest You. If You are an existing customer, we will only contact You by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to You. If You are a new customer, and where we permit selected third parties to use Your data, we (or they) will contact You by electronic means only if You have consented to this by ticking the relevant box situated on the form on which we collect Your data;
  5. to notify You about changes to our Site or Services;
  6. to ensure that content from our Site or Services and Services is presented in the most effective manner for You and for Your computer.

Information we collect about You

We will use this information:

  1. to administer our Site or Services and Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  2. to improve our Site or Services and Services to ensure that content is presented in the most effective manner for You and Your computer;
    to allow You to participate in interactive features of our Site or Services, when You choose to do so;
  3. as part of our efforts to keep our Site or Services and Services safe and secure;
  4. to measure or understand the effectiveness of advertising we serve to You and others, and to deliver relevant advertising to You;
  5. to make suggestions and recommendations to You and other users of our Site or Services and Services about goods or services that may interest You or them.

Information we receive from other sources

We may combine this information with information You give to us and information we collect about You. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Disclosure of your Information

Information we share with third parties

We may share Your information with selected third parties including:

  1. Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
  2. Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or You.
  3. Credit reference agencies for the purpose of assessing Your credit score where this is a condition of us entering into a contract with You.

Information we disclose to third parties.

We may disclose Your personal data to third parties:

  1. If the Supplier is acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  2. If we are under a duty to disclose or share Your personal data in order to comply with any legal obligation, or in order to enforce or apply our Agreement with You; or to protect our rights, property, safety, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we Store Your Personal Data

The personal data that we collect from You may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers or partners. Such staff or subcontractors maybe engaged in, among other things, the fulfilment of Your order, the processing of Your payment details or the provision of support services. By submitting Your personal data, You agree to this transfer, storing or processing outside of the EEA.

We will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy. In particular, this means that Your personal data will only be transferred to a country that provides an adequate level of protection (for example, where the European Commission has determined that a country provides an adequate level of protection) or where the recipient is bound by standard contractual clauses according to conditions provided by the European Commission (“EU Model Clauses”).

Our Site or Services and Services are accessible via the internet and may potentially be accessed by anyone around the world. Other users may access the Site and publicly available parts of the Services from outside the EEA. This means that where You chose to post Your data on our Site or Services or within the Services, it could be accessed from anywhere around the world and therefore a transfer of Your data outside of the EEA may be deemed to have occurred. You consent to such transfer of Your data for and by way of this purpose.

Protection of Information

  1. All information You provide to us is stored on our secure servers.
  2. Any payment transactions and transfers of personal information on our Site or Services will be encrypted using SSL technology.
  3. Where we have given You (or where You have chosen) a password which enables You to access certain parts of the Site or Services, You are responsible for keeping this password confidential. We ask You not to share any password with anyone.
  4. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will endeavour to protect Your personal data, we cannot guarantee the security of Your data transmitted to our Site or Services. Any transmission is at Your own risk. Once we have received Your information, we will use strict procedures and security features to try to prevent unauthorised access.

Cookies

We use cookies on our Site or Services and within our Site or Services to distinguish You from other users of our Site or Services. This helps us to provide You with a good experience when You use our Site or Services and also allows us to improve the Services. For detailed information on the cookies we use and the purposes for which we use them see our Website Cookie Information.

Age of Users

This Site is not intended for and shall not be used by anyone under the age of 16.

Links to Other Websites

Our Site or Services or our Site or Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If You follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before You submit any personal data to these websites.

Your Rights

You have the right under Data Protection Law, free of charge, to request:

  1. Access to Your personal data
  2. Rectification or deletion of Your personal data
  3. A restriction on the processing of Your personal data
  4. Object to the processing of Your personal data
  5. A transfer of Your personal data (data portability)

You can make a request in relation to any of the above rights in Writing. We will respond to such queries within 30 days and deal with requests we receive from You, in accordance with the provisions of Data Protection Law.

Consent

You have the right to withdraw Your consent to us processing Your personal data, at any time, by writing to us.

Where we process Your personal data for marketing purposes, we will inform You and obtain Your opt in consent (before collecting Your personal data) if we intend to use Your personal data for such purposes or if we intend to disclose Your information to any third party for such purposes. If You change Your mind about being contacted in the future, please click on the unsubscribe links in the emails which you have received and we will remove You from our mailing lists.

Data Retention

We retain personal data for as long as necessary for the relevant activity for which it was provided or collected. This will be for as long as we provide access to the Site or Services to You, Your account with us remains open or any period set out in any relevant contract You have with us. However, we may keep some data after Your account is closed or You cease using the Site or Services for the purposes set out below.

After You have closed Your account or ceased using the Site or Services for a period of at least 90 days, we usually delete personal data, however we may retain personal data where reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, maintain security, prevent fraud and abuse, resolve disputes, enforce our Terms and Conditions, or any other agreement with You, or fulfil Your request to “unsubscribe” from further messages from us.

We will retain de-personalised information after Your account has been closed.

Please note: After You have closed Your account or deleted information from Your account, any information You have shared with others will remain visible. We do not control data that other users may have copied from the Site or Services. Your profile may continue to be displayed in the services of others (e.g. search engine results) until they refresh their cache.

Complaints

If You have any complaints about our use of Your personal data please contact us as set out at the end of this Privacy Policy or contact our supervisory authority in the UK:

The Information Commissioner’s Office at, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.

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