1. OVERVIEW
This document (“Privacy Policy”) explains how we collect, use, process, share, and store your personal information when you access and use our application (“App”).
This Privacy Policy constitutes a binding legal agreement by and between you, an individual (“User”, “you,” “your”), and Capital Consultants Management Corporation (“Company”). The App is powered by the technology of Resvu USA Inc. (“Resvu”) (collectively Company and Resvu as “Providers”, “we”, “us”, “our”).
Defined terms are as specified throughout this Privacy Policy, and are identified in quotes.
By accessing and using the App, you agree to be bound by this Privacy Policy.
If you do not wish to be bound by this Privacy Policy, please do not use the App.
This Privacy Policy includes the following sections:
- Categories of personal information that we collect and when we collect personal information;
- Our use, processing and storage of your personal information;
- Providing your personal information to third parties and transfer of personal information;
- Your privacy rights;
- Cookies and other similar technologies that we use;
- Protecting your personal information;
- Contact information about your rights under this Privacy Policy; and
- Changes to this Privacy Policy.
2. CATEGORIES OF PERSONAL INFORMATION THAT WE COLLECT AND WHEN WE COLLECT PERSONAL INFORMATION
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, with you (“personal information”). Personal information does not include publicly available information from government records or de-identified or aggregated information.
We may collect, store, and use different categories of personal information about you, including:
| Categories of information |
Type of information |
| Account information |
first and last name; user name and password; email address; physical address, phone number |
| Internet/device information |
amount of time during which you have had an account with us; cookie information; device identifier |
| User Content |
content that you create or provide to the App |
We collect your personal information when you:
- Create or edit an account with us; and
- Access and use our App
We also may collect your personal information from our third party marketing representatives.
Note: If you fail to provide certain personal information to us when requested, we may not be able to perform all our legal and contractual obligations or carry out all activities requested by you within the App.
3. OUR USE, PROCESSING, AND STORAGE OF YOUR PERSONAL INFORMATION
We use, collect, and process your personal information for the following purposes:
| Legal Basis |
Purpose |
| Contract |
To create and manage your account, send you promotional materials, provide you with information that you request |
| Consent |
To use cookies, to request your feedback |
| Legitimate Interest |
To enable participation in interactive features of our App, notify you of changes to this Privacy Policy, inform you of new products and services, determine how our App are being used to improve the features and functionality |
| Legal Obligation |
To comply with our legal obligations |
In some instances, we may use your personal information in combination with information belonging to others. In this process, we use various methods to remove the identifying portions of any personal information before combining it with the information of others. The output of this process is aggregate data, which is incapable of identifying you or any others. We use this aggregate data for several reasons, including improving the features and functions of our App, and how we deliver it to you. Further, we may sell this aggregated data to other parties; provided, that, such aggregated data does not identify your User Content, without your prior written consent.
We will store your personal information in the United States, and will store it for as long as necessary to fulfill the purposes for which it was collected, and to allow us to satisfy any legal and reporting requirements.
Automated Processing: We do not conduct automated decision-making processing; such as profiling.
We do not sell personal information. We do not sell your personal information to third parties for a monetary payment or something else of value received in return. However, we may provide your personal information to third parties where we do not receive a monetary payment (as described in the next section).
Children’s Personal Information: We do not knowingly collect, process, or store the personal information of a user who is not of legal age in their country, state, region or province of origin. If we learn that we have collected, processed or stored the personal information of a user who is not of legal age in their country, state, region or province of origin, we will use commercially reasonable efforts to delete such personal information as soon as possible.
4. PROVIDING YOUR PERSONAL INFORMATION TO THIRD PARTIES AND TRANSFER OF PERSONAL INFORMATION
We may provide your personal information to third parties, where we do not receive a monetary payment, including:
| Third Party |
Purpose for providing personal information |
| Service providers |
A “Service Provider” is a company or person which processes your personal information for a business purpose under a contract between us and the Service Provider. We may transfer your personal information to a third party Service Provider for business purposes. Examples of a business purpose are providing services such as email notifications, to monitor and analyze trends and usage |
| Marketing agencies |
To assist in marketing and email campaigns |
| Public authorities &
legal proceedings |
To respond to a subpoena, warrant or other legal processes issued by a court or public authority; discovery requests and demands as part of a civil lawsuit or similar legal process; disclosure is required to comply with applicable laws, and similar legal processes |
| Business transfer |
If we sell a business, your personal information may be sent to the buyer of that business. If we buy a business, we may acquire your personal information |
| Professional advisors |
To our attorneys and accountants who assist us in providing our products and services to you |
If you reside outside of the United States, we will transfer your personal information to the United States, and we will put in place the required safeguards so that the transfer of your personal information complies with data protection laws.
5. YOUR PRIVACY RIGHTS
Subject to applicable laws, you may have the following additional rights:
| Right |
The action you may take |
| Access |
By logging into your account with us, you can access much of your personal information. However, if you don’t see the information that you are looking for, you can contact us as specified in section 8. |
| Correction
(also known as Rectification) |
By logging into your account with us, you can access much of your personal information. We ask that you keep your personal information accurate and up-to-date. However, if you need assistance with correcting any of your personal information, you can contact us as specified in section 8. |
| Deletion
(also known as Right to be Forgotten) |
You may delete your account with us at any time or you may request that we delete the personal information which we maintain about you. We may retain your personal information for as long as we believe it is necessary to fulfill the purposes for which the personal information was collected, or as otherwise required by law. There are instances where applicable law allows or requires us to refuse to delete your personal information. In the event that we cannot delete your personal information, we will inform you of the reasons why. |
| Restrict Processing |
You may have a right to request that we restrict processing of your personal information under certain circumstances, including if you believe the personal information is not accurate. |
| Portability |
You may have the right, if it is possible, given our then-current automated systems and data architecture, you have the right to receive your personal information in machine readable format. |
| Objection |
You may have the right, in limited circumstances, to object to our processing of your personal information. |
| Opt-Out |
You may have the right to object to our processing of your personal information to deliver advertisements according to our target-audience preferences. |
| Withdraw Consent |
Where we collect and process your personal information based on your consent, you have the right to withdraw your consent by deleting your account. |
| Lodge a Complaint |
You have a right to file a complaint with the appropriate government agency if you believe we have not complied with this Privacy Policy or have violated the applicable privacy law. |
If you are a resident of the State of California, under California Civil Code known as the “Shine The Light”, you may request and obtain from us, once a year, and free of charge, information about the categories of personal information (if any) we disclosed to third parties for direct marketing purposes, and the names and addresses of all third parties with which we shared your personal information during the immediately preceding calendar year. If you are a resident of the State of California and would like to make such a request, please submit your request in writing via email to us as specified in section 8.
When you contact us, we may request information from you to enable us to confirm your identity. We will use reasonable means to confirm that the individual that is making the request is you. If we cannot verify that the individual making the request is you, we may deny the request.
There will be no charge to request and receive access to your personal information which we have collected about you. If we cannot provide you with access to your personal information, we will inform you of the permissible reasons why we may not be able to provide access.
In addition, we may not always be able to fulfill your request to your satisfaction. In some cases, we may be prohibited by law, agreement, or legitimate interest to fully comply with your request. When those situations arise, we will inform you of why we are unable to fulfill your request.
6. COOKIES AND OTHER SIMILAR TECHNOLOGIES THAT WE USE
We use cookies, and similar technologies to enhance and improve your experience when you use the App.
A “cookie” is a small text file that is stored in your computer’s internet browser when you access and use a website or App. There are many different types of cookies. Some cookies are used to make websites and Apps function properly, called “strictly necessary cookies”. Other cookies, called targeting, functional, or performance cookies, are used to analyze site performance and traffic, or to tailor advertisements to users. Some cookies contain unique identifiers about you or your device.
When you access and use our App, we will send that identifier to your device and it will be stored on your device. Your device will send the identifier back to us each time you access and use our App. A cookie will be either a “session” cookie or a “persistent” cookie: (a) a session cookie will expire when you stop using our App and (b) a persistent cookie will be stored in your device’s web browser, and will remain in use until the expiration date has expired (you can delete a persistent cookie before its expiration date by using the web browser on your device).
We use the following types of cookies in our App:
| Type of cookie |
Who’s cookies |
Purpose of cookie |
| authentication cookies |
our cookies |
These cookies are session cookies and enable you to login to our App |
| targeting cookies
|
third party cookies |
These cookies are persistent cookies in order to provide you with support services within the App |
If you opt-out of using these cookies, then your rights to access and use the App will be terminated.
We use a couple of services to obtain analytics, which are used in our App, to understand how you use our App so that we can improve the product features and functionality, as well as, your user experience.
7. PROTECTING YOUR PERSONAL INFORMATION
We are committed to protecting the security of the personal information that we collect from you. We use reasonable physical, technical, and administrative measures to help protect your personal information from the risk of accidental loss, and unauthorized or inappropriate access, destruction, use, modification, or disclosure.
The safety and security of your information also depends upon you. If you access our App using a username and password, you are responsible for keeping this information confidential and not sharing it with anyone else.
8. CONTACT INFORMATION ABOUT YOUR RIGHTS UNDER THIS PRIVACY POLICY
If you have any questions regarding the collection, processing or storage of your personal information, or to exercise your rights under this Privacy Policy, please contact us at [email protected].
9. CHANGES TO THIS PRIVACY POLICY
Occasionally, we may make changes to this Privacy Policy. If we make material changes to this Privacy Policy, we will provide you with notice by displaying a prominent notice on the App or by sending you an email. Please make sure you read any such notice carefully. Having received notice of any changes to the Privacy Policy, if you continue to use the App, then you agree to the updated Privacy Policy. If you do not wish to continue using the App under the updated Privacy Policy, you can terminate your access and use of the App.
This Privacy Policy was last updated: December 18, 2023
