LAST UPDATED August 27th, 2023
2. The Types of Information That Captivation Hub Collects About You and How Captivation Hub Collects Information About You
Captivation Hub may collect two types of information from you when you visit the Platform: Personal Information and Non-Personal Information (collectively “Information”).
We collect Information:
3. How Captivation Hub Uses Personal Information It Collects About You and the Purposes for the Collection and Use
We use Personal Information that we collect about you or that you provide to us for the following purposes:
LEGAL BASIS FOR OUR USE (APPLICABLE ONLY TO EEA AND UNITED KINGDOM VISITORS): If you are in the European Economic Area or the United Kingdom, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.However, we will collect Personal Information from you only where we have your consent to do so, where we need the Personal Information to perform a contract with you, where we have a legal obligation to do so, or where the processing is in our legitimate interests (such as processing for administrative purposes, direct marketing, product development or improvement, preventing fraud or criminal acts and in support of information security) and not overridden by your data protection interests or fundamental rights and freedoms.
If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the time of collection. We will also tell you whether the requirement for that information is mandatory and explain any consequences to you if you do not provide the information.Similarly, if we collect and use your Personal Information based on our legitimate interests (or those of any third party), we will take reasonable steps to provide clear notice and describe our legitimate interests.
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information for any specific processing activity, please contact us using the contact details provided under the “HOW TO CONTACT US” Section below.
4. How Captivation Hub Protects Your Information
The Platform is designed to provide reasonable and appropriate administrative, technical and organizational security measures to protect your Personal Information against risks such as temporary or permanent loss, destruction, and unauthorized or unlawful access, alteration, use or disclosure. We require our suppliers and vendors to apply similar protections when they access or use Personal Information that we share with them. Users of the Platform must also do their part in protecting the data, systems, networks, and service they are utilizing. No technology, data transmission or system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that your password to any Captivation Hub account has been compromised), please immediately notify us by contacting us using the instructions in the “HOW TO CONTACT US” section below.
5. When Captivation Hub Shares Your Information
We also share non-personally identifiable information, such as anonymized or aggregated information, with suppliers for purposes such as analysis, identifying trends in the areas of our products and to help research and develop new Captivation Hub Services.
Captivation Hub does not sell any of your Personal Information.
6. YOUR LEGAL RIGHTS
Captivation Hub respects your rights in how your Personal Information is used and shared. You may request access or corrections to your personal data and make choices about the kinds of marketing materials you receive (or choose not to receive marketing from Captivation Hub at all). If you are in Europe, you may have additional rights under the GDPR. Additional choices and rights may be available to you depending on which Captivation Hub Services you use.
7. Information From Children
We do not knowingly collect, use, or disclose Information from children under 16. If we learn that we have collected the Personal Information of a child under 16—or the equivalent minimum age depending on the jurisdiction, such as 13 in the United States per the Children’s Online Privacy Protection Act—we will take steps to delete the information as soon as possible. If you are under 16, do not provide any Information about yourself to Captivation Hub, including your name, address, telephone number or email address. If you become aware that Information of a child under 16 years of age has been provided, please use one of the methods provided under the “HOW TO CONTACT US” section below.
8. Links to Other Websites and Services
9. Do Not Track
Some browsers incorporate a "Do Not Track" (“DNT”) feature that, when turned on, signals to websites and online services that you do not want to be tracked. At this time, the Platform does not respond to DNT signals.10. California Privacy RightsThis section is addressed to California residents only and provides more information about your rights under the California Consumer Privacy Act or “CCPA” (California Civil Code Section 1798.100 et seq.), as amended, and how Captivation Hub processes California residents’ Personal Information in compliance with the CCPA.Subject to certain exceptions, the CCPA grants to California residents the rights to: be notified about the collection, use, disclosure, sale or sharing of their Personal Information; request access to, deletion of, or correction of their Personal Information; request to opt out of the “sale” or “sharing” of Personal Information (where such information is sold or shared); limit the use or disclosure of Sensitive Personal Information (as defined under CCPA); and to not be discriminated against for exercising such rights.
Sold or Shared Identifiers (such name, address, IP address, email, etc.)
Commercial information (such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, etc.)
11. International Compliance
Data Protection and GDPR
Regulation (EU) 2016/679, more commonly known at the General Data Protection Regulation (EU GDPR), is an EU regulation aimed at harmonizing data protection laws across the EU. The EU GDPR is focused on giving individuals more control over how their data is used by companies, and making the collection and processing of data more transparent. The EU GDPR was incorporated directly into UK law following the end of the Brexit transition period, meaning that UK-based businesses and other entities subject to UK law still have to comply with its provisions through the ‘UK GDPR’. This document will refer to the EU GDPR and the UK GDPR, together, as the GDPR.
Controller and processorThe GDPR imposes various obligations on a person depending on whether they are a controller or a processor of personal data. A controller is an entity which decides to process personal data, and makes decisions regarding the basis of processing and the methods which will be used. Controllers have certain obligations regarding personal data, which you should familiarize yourself with before collecting personal data from your customers. A processor is an entity which processes data for and on behalf of a controller. They make no independent decisions regarding the data or its processing, as they only process it on behalf of the controller and must comply with all instructions given by the controller. When you use the Captivation Hub platform you are a controller. You are in control of the data you upload to the Captivation Hub platform, what you do with that data, and why. As a result, you are responsible for ensuring that you have a legal basis on which to process the data, and that you do not retain the data for any longer than is necessary.You should ensure that you understand your obligations as a controller, and update your own systems and policies to allow the lawful transfer of personal data to Captivation Hub.Captivation Hub is a data processor. We, through the Captivation Hub platform, store and otherwise process the data you have collected under your instructions. We will never use any personal data which you have uploaded to the Captivation Hub system for our own purposes or without your instruction. Legal basis for processingPersonal data may only be collected and processed if there is a legal basis for doing so. The allowable legal bases are set out in the GDPR. As a processor, Captivation Hub relies on our customers to select the correct basis under which they will be collecting and processing personal data, and to put the appropriate notices or consents in place. Before you use the Captivation Hub platform, you should take time to identify which legal bases may be available to you, and only collect and otherwise process personal data to the extent necessary to carry out that basis. You should not change the basis under which you have collected personal data without very good reason, so it is important to understand the requirements of the different bases and make sure you select the right one at the start. Data subject access rightsThe GDPR grants data subjects (i.e., your customers) certain rights relating to their personal data, including the right to access, correct and/or delete any data relating to them. Captivation Hub has put in place systems for you to inform us if you receive such a request from a data subject, and for us to inform you if we receive such a request. You should familiarize yourself with the obligations which will be imposed on you, including relating to any personal data you hold on your own systems, or services other than Captivation Hub. Transfers of data to the USAPersonal data may not be transferred outside the EEA or the UK other than in accordance with the GDPR. We utilize the Standard Contractual Clauses as part of our Data Processing Agreement which we sign with all of our customers. Data SecurityWe have put in place security safeguards and measures to help ensure that any personal data we hold is stored securely. We regularly test our products for bugs and vulnerabilities.We have regular back-up systems in place as well as data recovery and data integrity systems and processes to help minimize risk of corruption to or loss of personal data.
We take our duties as a processor very seriously. We have put in place a number of procedures and taken a number of steps to help ensure that we comply with the GDPR such as:
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