Privacy Policy
1. General
Capitique Ltd with the company registration number 12496710, with its registered office at 6th Floor, Amp House, Dingwall Road, England, CR0 2LX ( "the company", "we" or "us") is committed to protecting your information and respecting your privacy.
Capitique ltd is registered with the Information Commissioner's Office (Ref: ZA819054). The ICO is the UK's independent authority set up to uphold information rights.
This Privacy Policy together with the Terms & Conditions (and any other documents referred to therein) set out the basis on which any personal data we collect from you, or which you provide to us, through our website (as defined in the Terms & Conditions) will be processed by us. When you complete any form, speak with our staff or submit any details to us or using our website, we will collect, use and disclose your personal information in the manner described in this Privacy Policy.
Please read this Privacy Policy carefully to understand our views and practices regarding your personal data, how we use it and how we will treat it. If you do not agree with this Privacy Policy, please do not use our services.
Any new Privacy Policy will be effective from the time that it is posted on the Website. We reserve the right to make changes to our Privacy Policy at any time, without notice, where such change is required by applicable legislation. You may object to any new use or change in use of your personal data by contacting us as set out in section 11 (Contact Us) below. We will treat such objection as a notice to terminate the services provided by Capitique ltd.
2. Information We Collect
2.1 Information we collect from you we may collect and process the following data about you:
-
Personal data including your title, full name, nationality, current address, email address, mobile telephone number, home telephone number, date of birth and any proof of your identity and/or address that we may request. This information is collected through the onboarding process.
-
Any personal details we obtain from you which we may use/share to manage our compliance obligations or partner compliance obligations.
-
Your participation in any promotion sponsored by us;
-
Correspondence that you send us;
-
Calls that we make to you, or you make to us;
-
Surveys that you complete.
-
Information collected through cookies – please see section 10 Cookies for more details.
-
Your IP address, log-in times, operating system and browser type.
-
Details of your visits to our website including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access whilst visiting our Website.
2.2 To meet our legal obligations related to fraud prevention and anti-money laundering, we may obtain information about you from third-party agencies. This may include details such as your financial history, county court judgments, and any bankruptcies. We may collect this information from credit reference and fraud prevention agencies at any time during or after the onboarding process, whenever we determine it is necessary to help prevent fraud and reduce our financial risk. For more information, please contact us.
3. How We Use Your Information
We will use your personal data to provide information on services requested or products ordered. Data is collected and used on a lawful basis only which is outlined below.
Lawful basis
3.1 Purpose
• To perform a contract with you
• To take steps at your request prior to entering into a contract/onboarding process
• To decide whether to enter into a contract /onboard a new client
• To manage the client
• To ensure our records remain relevant
3.2 Our legitimate interest
• For good governance, accounting, managing and auditing our business operations and where required client’s business operations.
• For market research, analysis and developing statistics
• To send you marketing communications with your consent
3.3 Legal obligation
• When you exercise your rights under data protection law and make requests
• For compliance with legal, regulatory requirements and related disclosures
• For establishment and defence of legal rights
• For activities relating to the prevention, detection and investigation of crime
• To verify your identity, engage in fraud prevention and anti-money laundering checks
• To monitor emails, calls, other communications
3.4 Your consent
• When you request, we disclose your personal data to other people or organisations
• When we process any special categories of personal data at your request
• To send you marketing communications where we have asked for your consent to do so
4. Storing Your Personal Data
4.1 Where is it Stored?
The data that we collect from you may be transferred to and stored at, destinations outside the United Kingdom ("UK") for the reasons set out below:
-
if this is necessary for providing you with the services you request.
-
where our anti-fraud agencies, credit reference agencies and other service providers are based outside the UK and require access to your data to perform their obligations to us and provide services to you;
-
if you have been referred to us by a third party and that third party is entitled to a commission payment – for further detail see section 6.4.
We have taken and will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy no matter where it is located.
4.2 Security
We are committed to ensuring that your information is secure. To prevent unauthorised access or disclosure of information we have physical, electronic and managerial procedures in place to keep your information safe.
Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website. Any transmission is at your own risk. Once we have received your information, we will use strict procedures to prevent unauthorised access.
4.3 Retention
We are by law required to retain certain records for a period of at least six years which will include your personal data such as your name, contact details and accounting history etc. Otherwise, we will delete and destroy all personal data that we hold about you when you (or we) terminate the relationship with you.
5. Your rights under the General Data Protection Regulation (GDPR)
-
The right to be informed
-
The right of access
-
The right of rectification
-
The right of erasure
-
The right to restrict processing
-
The right to data portability
-
The right to object
-
Rights in relation to automated decision making and profiling
If you would like further information about data protection you can visit the Information Commissioner's Office (ICO) at ico.org.uk. The ICO is the UK's independent authority set up to uphold information rights in the public interest and data privacy for individuals. We comply with all ICO regulatory and statutory requirements. You have the right to make a complaint to the ICO regarding the handling of your data.
6. Disclosure of Your Information
6.1 Group Companies
We may disclose your personal information to any member of our group,(which means our subsidiaries, our ultimate holding company and its subsidiaries) or third party partners . This may be necessary in order to, among other things, fulfil your request, process your payment details, provide support services and monitor fraudulent activities.
6.2 Fraud and Credit Reference Agencies
When you onboard with Capitique and at regular intervals and at any other time we feel it is necessary to do so to protect our financial interests and prevent money-laundering or fraud, we share certain information about you and your business and any other information as required as part of our normal business operations with our banks, payment facilitator partners, government agencies to identify our clients and reduce exposure to fraud and other criminal activities. When conducting identification or fraud prevention checks, the relevant parties may retain a record of our query along with your information and may share this information with other fraud prevention agencies. If you want to know what information these companies hold about you, you can write to us to further elaborate and share this with you. Please refer to our Money Laundering Regulations for further details.
6.3 Strategic Partners
Capitique may supply strategic partners with certain information related to you or your business, (such as your name, address, telephone number, date of birth, email address and gender) to provide operational services. Our strategic partners gather information for their own purposes and for that reason we cannot exercise control over the uses to which they apply your personal information.
Where required by law, strategic partners and suppliers are certified or authorised and regulated to the required standards. Your personal data may be transferred outside the UK and the European Economic Area. If these countries do not have adequate protections for personal data under applicable laws we will take all necessary steps to safeguard your personal data.
6.4 Other Disclosures
We will share your personal information with third parties only in the ways that are described in this Privacy Policy. We do not sell your personal information to third parties. We may also disclose your personal information to:
-
a prospective buyer of our business or a buyer of a substantial number of the shares in our business;
-
the police, other lawful enforcement body, regulatory body or court if we are under a duty or required by law to disclose or share your personal data, or to protect the rights, property, or safety of ourselves or our group companies, our customers, or others;
-
third parties where you have expressed an interest in receiving information about their goods and services and
-
third parties who referred you to us initially and to whom we owe a commission payment as a result of the referral.
-
third parties we may occasionally use to provide you with the services that you have requested. We require these third parties to not use your personal information for any other purpose.
7. Communicating With You
We may contact you by email to the primary email address or telephone with the registered email address or contact number provided either during the onboards process or thereafter
You can change your primary email address and/or contact telephone number at any time, subject to the provisions of section 9 below.
7.1. Newsletters and Marketing
You are free to opt out of receiving all marketing communications from us and our strategic partners at any time by contacting us. Should you be opted in to receive email correspondence, there is an unsubscribe link on each email we send out, if you use this, we will not send any unsolicited mail to your registered email address. Please note that you will still receive communication regarding your business interests. From time to time, we do share aggregated information about our customers' use of our website and services with other companies for research and analysis purposes, but you cannot be identified from this aggregated information.
7.2. Phishing
Phishing is the name given to attempts to steal personal/financial details from a website user. "Phishers" use fake or "spoof" emails to lead users to counterfeit websites where the user is tricked into entering their personal details, PLEASE NOTE: WE WILL NEVER SEND EMAILS ASKING YOU FOR SUCH DETAILS. If you do received such emails please urgently contact the Capitique team.
8. Links to Other Web sites
Our website 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.
The Capitique Ltd website also includes social media features, such as the Facebook 'like' button and widgets, such as the 'Share this' button or interactive mini-programs that run on our website. These features may collect your IP address, which page you are visiting on our website and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the company providing it.
9. Accessing and Updating Your Information
If your personal details (such as your name, address, or telephone number) change you should inform Customer Services via the "Contact" section of the website or refer to your business manager as soon as you can. We shall not be liable for any loss arising out of your failure to keep your personal details up to date.
10. Cookies
10.1. General
A cookie is a small amount of data which contains information that is downloaded to the device from which you access our website. Cookies are useful because they allow us and other websites to recognise your device. Cookies are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. For example, they can allow you to navigate between web pages of our website and remember your preferences such as your language selection.
10.2. Types of Cookies and Consent
In order to comply with legislation, we have reviewed the use of cookies on our site and set out the information below. This is to ensure that you are aware of these cookies and are able to give your consent for the placing of some or all of these cookies on your device when you use our site. In summary, we use the following types of cookies:
-
Strictly necessary cookies – These are cookies which are essential for our site to operate such as those which identify you. They allow you to move around our website and use the services you have requested. These cookies will be activated when you enter our site and as you use our site.
-
Compliance cookies – These include cookies which are necessary to assist in meeting our regulatory compliance obligations, such as anti-money. These cookies will be activated when you enter our site and as you use our site.
-
Performance cookies – These are cookies that help us to improve how our site works and to deliver a better service to you. For example, they will assess which pages you visit most often or if you get an error message. They also allow us to see if you have used the website of one of our group or affiliated companies. All information collected by these cookies is aggregated and therefore anonymous.
-
Functionality cookies – These cookies allow us to deliver a more personalised service to you and allow our website to remember choices you have made such as the language you prefer or the region you are in. They may also be used to provide services you have requested such as being able to comment on one of our blogs.
-
Third Party cookies – When you visit a page on our website with content embedded from third parties, for example, YouTube or Twitter, cookies may be downloaded onto your device. We do not set or control these cookies. If you are concerned about the types of cookies that may be downloaded you check the third party websites for more information about these cookies.
We may use other cookies from time to time in accordance with this policy. By using our website and other online services, you acknowledge that we may use some or all of the cookies mentioned and you agree that we can place Performance and Functionality Cookies on your device when you use our website. If you do not agree to this you should cease using our website and online services or adjust your browser settings. Please see section 10.3 below.
10.3. Blocking Cookies
Should you want to continue using our services but restrict our use of cookies, you can block cookies by activating the setting on your browser which allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including Strictly necessary and/or Compliance cookies, as described above) you may not be able to access all or parts of our website. Our website may issue some of the cookies described above as soon as you visit our website unless you have adjusted your browser setting so that it will refuse cookies.
11. Contact us
Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to: info@capitique.co.uk