Capssion Limited collects some Personal Data from its Users. Data Controller and Owner Capssion Limited. Room 1104 Crawford House, 70 Queen’s Road Central, Central, Hong Kong Owner contact email: dpo@capssion.com Types of Data collected Among the types of Personal Data that Capssion Limited collects, by itself or through third parties, there are: Cookies, Usage Data, first name, last name, gender, date of birth, phone number, company name, profession, address, country, email address, city, field of activity, website, username, Social media accounts permission and various types of Data. Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. The Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Capssion Limited Application. All Data requested by Capssion Limited is mandatory and failure to provide this Data may make it impossible for Capssion Limited Application to provide its services. In cases where Capssion Limited Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without any consequences on the availability or the functioning of the service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Any use of Cookies – or of other tracking tools – by Capssion Limited Application or by the owners of third party services used by Capssion Limited Application serves the purpose of providing the service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available. Users are responsible for any third party Personal Data obtained, published or shared through Capssion Limited and confirm that they have the third party's consent to provide the Data to the Owner. Mode and place of processing the Data Methods of processing The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time. Place The Data is processed at the Data Controller's operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller. Retention time The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data. The use of the collected Data The Data concerning the User is collected to allow the Owner to provide its services, as well as for the following purposes: Access to third party accounts, Analytics, Contacting the User, Content commenting, Device permissions for Personal Data access, Displaying content from external platforms, Handling payments, Managing contacts and sending messages, Registration and authentication, Social features, Hosting and backend infrastructure and Traffic optimization and distribution. The Personal Data used for each purpose is outlined in the specific sections of this document. Facebook permissions asked by Capssion Limited Capssion Limited may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows Capssion Limited to connect with the User's account on the Facebook social network, provided by Facebook Inc. For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy. The permissions asked are the following: Basic information By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available. About Me Provides access to the 'About Me' section of the profile. Access Page CTA Provides the access to manage call to actions on User-managed Pages. Birthday Provides access to the birthday. Contact email Access the User's contact email address. Email Provides access to the User's primary email address. Device permissions for Personal Data access Depending on the User's specific device, Capssion Limited may request certain permissions that allow it to access the User's device Data as described below. By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document. The exact procedure for controlling app permissions may be dependent on the User's device and software. Please note that the revoking of such permissions might impact the proper functioning of Capssion Limited. If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by Capssion Limited. Social media accounts permission Used for accessing the User's social media account profiles, such as Facebook and Twitter. Detailed information on the processing of Personal Data Personal Data is collected for the following purposes and using the following services: Access to third party accounts This type of service allows Capssion Limited to access Data from your account on a third party service and perform actions with it. These services are not activated automatically, but require explicit authorization by the User. Facebook account access This service allows Capssion Limited to connect with the User's account on the Facebook social network, provided by Facebook, Inc. Permissions asked: About Me, Access Page CTA, Birthday, Contact email and Email. Place of processing: US – Privacy Policy Instagram account access The Instagram Data is collected to (i) confirm Your subscription to the Platform and to (ii) compute statistics regarding Your Capssion activity. Your Instagram Data is stored in Capssion’s servers and shared with Capssion’s privileged partners for statistical purposes. Personal Data collected: all information and data available within Your Instagram account including, without limitation, the title of Your Instagram accounts, their date and country of creation, images and description including Your stories, number of views, number of pictures, number of comments, number of followers (“Instagram Data”) Place of processing: US – Privacy Policy YouTube account access YouTube Data is collected to (i) confirm Your registration on the Platform and to (ii) compute statistics regarding Your Capssion activity. Your YouTube Data is stored in Capssion’s servers and shared with Capssion’s privileged partners for statistical purposes. Personal Data collected: all information and data available within Your YouTube account including, without limitation, the title of Your YouTube channels, their date and country of creation, images and description, number of views, number of videos, number of comments, number of subscribers (“YouTube Data”). Therefore, by using the Platform, You notably agree to be bound to the Google Privacy Policy available at the following URL address: http://www.google.com/policies/privacy. You can revoke at any time Capssion’s access to Your YouTube Data via the Google security settings page available at the following URL address: https://security.google.com/settings/security/permissions. Place of processing: US – Privacy Policy – Revoke Access Analytics The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior. Google Analytics (Google Inc.) Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of Capssion Limited, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy – Opt Out MixPanel (MixPanel) MixPanel is an analytics service provided by Mixpanel Inc. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy Contacting the User Contact form (Capssion Limited) By filling in the contact form with their Data, the User authorizes Capssion Limited to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header. Personal Data collected: address, city, company name, country, date of birth, email address, field of activity, first name, gender, last name, phone number, profession and website. Mailing list or newsletter (Capssion Limited) By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Capssion Limited. Your email address might also be added to this list as a result of signing up to Capssion Limited Application or after making a purchase. Personal Data collected: address, city, company name, country, email address, first name, gender, last name, phone number, profession and website. Phone contact (Capssion Limited) Users that provided their phone number might be contacted for commercial or promotional purposes related to Capssion Limited, as well as for fulfilling support requests. Personal Data collected: phone number. Content commenting Content commenting services allow Users to make and publish their comments on the contents of Capssion Limited. Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments. If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service. Comment system managed directly (Capssion Limited) Capssion Limited has its own internal content comment system. Personal Data collected: email address, first name, last name, username and website. Device permissions for Personal Data access Capssion Limited requests certain permissions from Users that allow it to access the User's device Data as described below. Device permissions for Personal Data access (Capssion Limited Application) Capssion Limited requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document. Personal Data collected: Social media accounts permission. Displaying content from external platforms This type of service allows you to view content hosted on external platforms directly from the pages of Capssion Limited and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it. Handling payments Payment processing services enable Capssion Limited to process payments by credit card, bank transfer or other means. To ensure greater security, Capssion Limited shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction. Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment. Stripe (Stripe Inc.) Stripe is a payment service provided by Stripe Inc., which allows Users to make online payments. Personal Data collected: various types of Data as specified in the privacy policy of the service. Privacy Policy. PayPal (PayPal Inc.) PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments. Personal Data collected: various types of Data as specified in the privacy policy of the service. Privacy Policy. Hosting and backend infrastructure This type of service has the purpose of hosting data and files that enable Capssion Limited to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Capssion Limited. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored. Mongolab (ObjectLabs Corporation) Mongolab is a hosting and backend service provided by ObjectLabs Corporation. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: US – Privacy Policy Managing contacts and sending messages This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message. Mailjet (Mailjet SAS) Mailjet is an email address management and message sending service provided by Mailjet SAS. Personal Data collected: email address, name. Place of processing: Germany, Belgium, France – Privacy Policy Registration and authentication By registering or authenticating, Users allow Capssion Limited Application to identify them and give them access to dedicated services. Depending on what is described below, third parties may provide registration and authentication services. In this case, Capssion Limited Application will be able to access some Data, stored by these third party services, for registration or identification purposes. Facebook Authentication (Facebook, Inc.) Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: US – Privacy Policy Instagram Authentication (Instagram, Inc.) Instagram Authentication is a registration and authentication service provided by Instagram, Inc. and is connected to the Instagram social network. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: US – Privacy Policy Social features Inviting and suggesting friends (Capssion Limited) Capssion Limited may use the Personal Data provided to allow Users to invite their friends - for example through the address book, if access has been provided - and to suggest friends or connections inside it. Personal Data collected: various types of Data. Traffic optimization and distribution This type of service allows Capssion Limited to distribute their content using servers located across different countries and to optimize their performance. Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between Capssion Limited and the User's browser. Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information User are transferred. CloudFlare (Cloudflare) CloudFlare is a traffic optimization and distribution service provided by CloudFlare Inc. The way CloudFlare is integrated means that it filters all the traffic through Capssion Limited, i.e., communication between Capssion Limited and the User's browser, while also allowing analytical data from Capssion Limited to be collected. Personal Data collected: Cookies and various types of Data as specified in the privacy policy of the service. Place of processing: US – Privacy Policy Further information about Personal Data Push notifications Capssion Limited may send push notifications to the User. Selling goods and services online The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery. The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by Capssion Limited Application depends on the payment system used. The Service is not directed to children under the age of 16 Users declare themselves to be adult according to their applicable legislation. Minors may use Capssion Limited only with the assistance of a parent or guardian. Under no circumstance persons under the age of 16 may use Capssion Limited. Cookie Policy Capssion Limited uses Cookies. To learn more and for a detailed cookie notice, you may consult the Cookie Policy. Additional information about Data collection and processing Legal action The User's Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of Capssion Limited or the related services. The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities. Additional information about User's Personal Data In addition to the information contained in this privacy policy, Capssion Limited may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request. System logs and maintenance For operation and maintenance purposes, Capssion Limited and any third party services may collect files that record interaction with Capssion Limited (System logs) or use for this purpose other Personal Data (such as IP Address). Information not contained in this policy More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document. The rights of Users Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above. Capssion application does not support “Do Not Track” requests. To determine whether any of the third party services it uses honor the “Do Not Track” requests, please read their privacy policies. Changes to this privacy policy The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using Capssion Limited Application and can request that the Data Controller remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users. Information about this privacy policy The Data Controller is responsible for this privacy policy, prepared starting from the modules provided by Iubenda and hosted on Iubenda's servers. Definitions and legal references Personal Data (or Data) Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number. Usage Data Information collected automatically from Capssion Limited (or third party services employed in Capssion Limited), which can include: the IP addresses or domain names of the computers utilized by the Users who use Capssion Limited, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment. User The individual using Capssion Limited, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refers. Data Subject The legal or natural person to whom the Personal Data refers. Data Processor (or Data Supervisor) The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy. Data Controller (or Owner) The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of Capssion Limited. The Data Controller, unless otherwise specified, is the Owner of Capssion Limited. Application The hardware or software tool by which the Personal Data of the User is collected. Cookies Small piece of data stored in the User's device. Legal information Notice to European Users: this privacy statement has been prepared in fulfillment of the obligations under Art. 10 of EC Directive n. 95/46/EC, and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of Cookies. This privacy policy relates solely to Capssion Limited and Site.