This Privacy policy (“Privacy Policy”), together with our Terms of Service, sets out the basis on which any Personal Information we collect from you (“you,” “your,” or “client”) or that you provide to us, will be processed by us. By “Personal Information,” we mean any information that, either alone or in combination with other data, enables you to be directly or indirectly identified, for example, your name, email address, username, contact details, or any unique identifier such as an IP address, device ID or another online identifier.
Please read the following carefully to understand what data we collect, how it is used, and how to share it. If you do not wish for your Personal Information to be used in the ways described within this Privacy Policy, then you should not access or use the website, services, functions, or features offered from time to time on the Services.
Certain subsidiaries may use different privacy policies to notify you about how your Personal Information is used and disclosed in your use of particular services or relationship to that subsidiary. To the extent that our subsidiaries post or reference different privacy policies, the privacy policy posted by each subsidiary, not this Privacy Policy, will apply to your Personal Information collected in the context of those services or by that subsidiary.
“Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, such as your name, email address, IP address, telephone number, and broader categories of information such as your professional information and internet activity
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship.
We may share your Personal Information with companies or individuals that we contract with in order to receive services (our “Service Providers”). These services may include, among other things, providing products or services to you on our behalf, creating or maintaining our databases, payment processing, researching and analyzing the people who request information from us, preparing distribution communications, or responding to inquiries. We do not allow our Service Providers to use or disclose your Personal Information for any purpose other than providing services to us.
We may share your Personal Information with companies that we own or control, or that own or control us, or that are under common ownership or control.
We may share your Personal Information with companies or individuals outside of CLTS who may use your Personal Information for their own purposes (a “Third Party”). For example:
We may, as a result of a sale, merger, consolidation, change in control, transfer of assets, reorganization or liquidation of our company (a “Reorganization Event”), transfer, sell or assign your Personal Information to parties involved in the Reorganization Event. You acknowledge that such transfers may occur and are permitted by and subject to this Privacy Policy.
Capstone Limited is committed to protecting your privacy. Internally, only people with a business need to know Personal Information or whose duties reasonably require access to it are granted access to clients ’Personal Information. Such individuals will only process your Personal Information on our instructions and are subject to a duty of confidentiality.
We use cookies and similar tracking technologies, such as web beacons and pixels, to track activity on our Services and hold certain information. Cookies are files with a small amount of data that may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. If you choose to restrict cookies, some functionality and features of our website may be unavailable.
You may unsubscribe from receiving promotional emails from us by following the instructions in those email communications or emailing us at support@capstone.cn.com. Please note that even if you opt out of receiving promotional communications from us, we may continue to send you non-promotional emails, such as communications regarding our ongoing relationship with you.
The General Data Protection Regulation (GDPR) harmonizes national data privacy laws throughout the European Union (EU) and enhances the protection of all EU residents with respect to their personal data. The GDPR applies to all companies handling the personal data of EU residents, including companies established outside the EU, if they offer goods or services to EU residents.
In 2001, the EU recognized Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) as providing adequate protection. Canada’s adequacy status ensures that data processed in accordance with GDPR can be subsequently transferred from the EU to Canada without requiring additional data protection safeguards or authorization to transfer the data.
We are required to comply with the European Union (“EU”) General Data Protection Regulation and applicable local laws about certain Personal Information we collect. For such Personal Information, the CLTS entity identified at the time of collection is the data controller of the Personal Information. In this section, “Personal Information” is defined in accordance with the General Data Protection Regulation
We collect your Personal Information, detailed in “How We Collect and Use Your Personal Information,” under the following lawful bases:
| Use of Your Personal Information | Categories of Personal Information | Lawful Basis for Processing |
| Onboard customers or suppliers, maintain or service accounts, process requests, verify identity, and perform other activities. |
Direct Identifiers, Commercial Information, Internet Activity Information, Professional and Employment-Related Information, Profile Information | Depending on circumstances, processing may be based on contract, consent, or legitimate interests. |
| Improve services, run analytics, assess quality, confirm balances, manage financial transactions. | Direct Identifiers, Commercial Information, Internet Activity Information, Professional and Employment-Related Information | Processing may be based on contract or legitimate interests. |
| Send marketing communications. | Direct Identifiers, Commercial Information, Internet Activity Information, Professional and Employment-Related Information, Profile Information | Processing may be based on consent or legitimate interests |
| Administer and improve websites. | Direct Identifiers, Commercial Information, Internet Activity Information, Professional and Employment-Related Information, Profile Information | Processing may be based on consent or legitimate interests. |
| Ensure security and prevent accidental disclosure or fraud. | Direct Identifiers, Commercial Information, Internet Activity Information, Professional and Employment-Related Information, Profile Information | Processing is based on legal obligations and legitimate interests. |
If we need to collect Personal Information by law or under the terms of a contract we have with you and you fail to provide us with the requested information, we may not be able to perform the contract we have or are trying to enter into with you. We will inform you of any mandatory Personal Information we require from you and the consequences if you fail to provide it.
We maintain appropriate technical and organizational safeguards designed to help protect Personal Information from unauthorized disclosure or access and accidental or unlawful destruction, loss, or alteration. For example, we limit access to your Personal Information to authorized parties and have systems designed to ensure that we can restore availability and access to Personal Information in case of a physical or technical incident. Although we reasonably safeguard personal information, we cannot guarantee the security of personal information obtained or stored electronically.
We will store your Personal Information for no longer than is necessary to perform our obligations or to achieve the purposes for which the Personal Information was collected or as may be permitted under applicable law. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure of the Personal Information; the purposes for which we process the Personal Information and whether we can achieve those purposes through other means; and the applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period, we will remove Personal Information from our systems and records or take appropriate steps to anonymize it properly.
We may occasionally update this Privacy Policy to reflect changes in our practices. When we post modifications, we will revise the “Last Updated” date at the top of this web page.
Please periodically review this page for the latest information on our privacy practices.
If you should have any questions or concerns regarding this Privacy Policy, please contact us via support@capstone.cn.com