Privacy Policy

We, Captur Limited (“Captur,” “we,” “us,” or “our"), believe your privacy is critically important.

To fulfil our commitment to respecting and protecting your privacy and to comply with our obligations under data protection laws including the General Data Protection Regulation (GDPR), we adhere to our principles as explained in detail below:

• We inform you of the personal information that will be collected, and where necessary seek your consent to collect, use, or disclose your personal information.
• We identify the purposes of use for collecting your personal information.
• We collect only information that is necessary to carry out the identified purposes of use.
• We use or disclose your personal information only for the purposes for which it is collected, except with your consent or as required or permitted by law, and we will keep your information only as long as necessary to fulfil those purposes.
• We endeavour to make sure your personal information is accurate, complete, and up-to-date.
• We protect your personal information with appropriate security safeguards.
• We make our policies and practices for the handling of your personal information as transparent as possible.
• You will have access to your personal information and will be able to request the export, correction, or deletion of your personal information as appropriate.
• We will be accountable to you. We are always interested in hearing your opinion regarding our compliance with these principles, this Privacy Policy, and applicable law.

This Privacy Policy explains how Captur will handle and safeguard your personal information, and the choices you have to access and control your personal information.

This Privacy Policy (which is our “privacy notice” for the purposes of the GDPR) also describes how we collect and use personal information about you through your use of this website (capturphotos.com and all subdomains). This includes when you sign up to newsletters, fill out a form to download a piece of content, contact us through an online form, or create an account to use our web apps (captur.app and all subdomains).

Captur Limited is the "data controller" of our website users’ personal data (which we call "personal information" for clarity). This means we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy policy.

It is important you read this Privacy Policy together with any other policy or fair processing notice we may provide on occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your information. This Privacy Policy supplements the other notices and is not intended to override them.

It is important that you read this notice, so that you are aware of how and why we are using such information.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  - apply for our products or services;
  - create an account on our website;
  - subscribe to our service or publications;
  - request marketing to be sent to you;
  - enter a competition, promotion or survey; or
  - give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  - apply for our products or services;
  - create an account on our website;
  - subscribe to our service or publications;
  - request marketing to be sent to you;
  - enter a competition, promotion or survey; or
  - give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

When you visit our website, we may obtain and maintain certain electronic identification or log data from your mobile device or personal computer such as: operating system type, IP address, browser information including type and language settings, device identifier, advertising identifier or mobile application identifier.

This information is necessary as part of our ongoing efforts to detect and deter unauthorised or fraudulent use of or abuse of the service, as well as to provide you and optimise the service for your environment. Also, please note that, an advertising identifier may be associated with our internal identifier.

If you fill out any form on our website, we may use your identity and contact details to contact you periodically to keep you updated about changes to our website, our policies or the terms of use.

We use your personal information in this way to allow us to comply with legal obligations (when changes to the law require changes to our terms) and for our legitimate interests to keep our records updated.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Captur, as a data controller, uses your information for the following purposes as well as those specific purposes set out previously:
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To register you as a new customer
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We collect Identity and Contact data on the lawful basis of the performance of a contract with you.

• To process and deliver your order including:
  – manage payments, fees, and charges
  – collect and recover money owed to us

We collect Identity, Contact, Financial, Transaction, and Marketing and Communications Data on the lawful basis of the performance of a contract with you and it is necessary for our legitimate interests (to recover debts due to us).

• To manage our relationship with you which will include:
  – notifying you about changes to our terms or privacy policy
  – asking you to leave a review or take a survey

We collect Identity, Contact, Profile, and Marketing and Communications Data on the lawful basisof the performance of a contract with you and it is necessary to comply with a legal obligation and for our legitimate interests (to keep our records updated and to study how customers use our products/services).

• To administer and protect our business and this website
  – including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data

We collect Identity, Contact, and Technical Data on the lawful basis of it is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) and to comply with a legal obligation.

• To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

We collect Identity, Contact, Profile, Usage, Marketing and Communications, and Technical Data on the lawful basis of it is necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).

• To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

We collect Technical and Usage Data on the lawful basis of it is necessary for our legitimate interests(to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

• To make suggestions and recommendations to you about goods or services that may be of interest to you

We collect Identity, Contact, Technical, Usage, and Profile Data on the lawful basis of it is necessary for our legitimate interests (to develop our products/services and grow our business). Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us
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We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing
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We will get your express opt-in consent before we share your personal data with any company outside the Captur group of companies for marketing purposes.

Opting out
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Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at via hello@capturphotos.com or by writing to:

Captur Limited
Attn: Privacy Policy
14-18 Sloane Court East, Flat C
London
SW3 4TG
UK

To fulfil our commitment to respecting and protecting your privacy and the confidentiality of your information, Captur has implemented industry-standard safeguards to prevent unauthorised access or disclosure, misuse, alternation, or destruction of your information.

Because no method of electronic transmission or method of data storage is perfect or impenetrable, we cannot guarantee that your information will be absolutely safe from intrusion during transmission or while stored in our systems.

To help protect your privacy and confidentiality of your information, we also need to ask for your cooperation regarding the following: Please do not share your password with others or use the same passwords you use for other services. Also, please notify us in the event you suspect any unauthorised use of your account or any other breach of security via hello@capturphotos.com or by writing to:

Captur Limited
Attn: Privacy Policy
14-18 Sloane Court East, Flat C
London
SW3 4TG
UK

Our website is hosted by Google Cloud Platform and MongoDB on servers located in the European Economic Area (EEA). We will not transfer your personal data outside of the EEA.

We require your consent in order to send you marketing communications by email.

In most cases, however, we do not require your consent to use your personal information. Details of the lawful basis of our use of your personal information are set out above.

In some circumstances, we may approach you for your specific written consent to allow us to process certain personal information for a specific purpose. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

We require your consent in order to send you marketing communications by email.

In most cases, however, we do not require your consent to use your personal information. Details of the lawful basis of our use of your personal information are set out above.

In some circumstances, we may approach you for your specific written consent to allow us to process certain personal information for a specific purpose. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we have a policy to limit access to your personal information to those employees, agents, contractors and other third parties who have a legitimate reason to receive it. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Captur will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity, the potential risk of harm from unauthorised use or disclosure, the purposes for which we use your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

It is important the personal information we hold about you is accurate and current, otherwise we may not be able to send you the emails you wish to receive.

To facilitate and provide you with the best experience, it sometimes is necessary for Captur to request third party partner service providers or agents to help us process and/or store your personal information. We strictly evaluate the partner service providers and agents, and we make every effort to ensure that they have established appropriate and secure information administration and organisational control systems, and we strictly require they comply with applicable laws and regulations. We also require they access your personal information only the extent necessary to perform tasks on our behalf.

We use third-party analytics services to help understand your usage of our services. In particular, Captur uses Posthog and Sentry to measure performance and track usage. You can read more about Posthog's privacy policies and the way they use the data we send them on their Privacy Policy page. You can read more about Sentry's privacy policies and the way they use the data we send them on their Privacy Policy page.

Other than as described in this Privacy Policy and, where relevant, other applicable privacy policies or addendums, Captur will never provide your information to any third parties without your consent, unless we believe in good faith that we are required or permitted to do so under applicable laws or to protect and defend Captur’s rights and/or property.

We use cookies and similar technologies, including local storage:

• to help us maintain your session when you use the website;
• to enhance security;
• to remember information about your browser and your preferences; and
• to help us understand how people use our services and to improve the service.

By continuing to use the website, you are agreeing to our use of cookies and similar technologiesin accordance with this Privacy Policy.

Most browsers allow you to control whether or not to accept cookies. If you, however, deactivate cookies or limit the ability to set cookies, you may not be able to use certain parts or all functions, and it may limit your overall user experience.

Captur has tried to make it as easy as possible for you to have control over your personal information. Under certain circumstances, by law, you have the right to:

• Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request the erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party (in limited circumstances and where this is technically possible).

If you want to exercise these rights, please contact us on hello@capturphotos.com, or by writing to:

Captur Limited
Attn: Data Controller
14-18 Sloane Court East, Flat C
London
SW3 4TG
UK

Where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose (such as opting-in to receiving marketing emails) you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us on hello@capturphotos.com. You can withdraw your consent to receive future marketing information from us by clicking the link at the bottom of any email from us.

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another lawful basis for doing so in law. Your withdrawal of consent does not affect the lawfulness of our use of your personal information up to the time that you let us know that you have withdrawn your consent.

If you have any questions, comments, or concerns about this Privacy Policy or our other privacy policies or practices, please contact us using hello@capturphotos.com or by writing to:

Captur Limited
Attn: Data Controller
14-18 Sloane Court East, Flat C
London
SW3 4TG
UK

We may modify our Privacy Policy from time to time for various reasons including to improve our privacy practices, to reflect changes to our Service, and to comply with relevant law. The last time we updated this Privacy Policy was the 26th of January 2021 and it was initially released on 16th May 2020.

When we make any material changes to our Privacy Policy, we will provide notice to you on our website, or by other reasonable means. We encourage you to review changes carefully. If you agree to the changes, then please continue to use our service. If you, however, do not agree to any of the changes and you no longer wish to use our service, you may choose to unsubscribe to all communications. Continuing to use our service after a notice of changes has been communicated to you or published on our service constitutes your acceptance of changes and consent to the modified Privacy Policy.

Last updated: 26/01/2021, 11:47:15