This is the privacy notice of https://new.capital/ referred to in this document as “New Capital”, “we”, “our”, or “us”.
This website is operated by New Capital LT, UAB . We are registered in Lithuania under registration number 304696871, and our registered office is at Lvovo str. 13C – 5, LT-09313, Vilnius, Lithuania.
This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
- We take the protection of your privacy and confidentiality seriously. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
- We undertake to preserve the confidentiality of all information you provide to us.
- Our policy complies with Ireland law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
- The law requires us to tell you about your rights and our obligations to you regarding the processing and control of your personal data. To comply with this law, we therefore request that you read the information provided at knowyourprivacyrights.org
- Except as set out below, we do not share, sell, or disclose to a third party, any information collected through our website.
B. WHAT INFORMATION DO WE COLLECT AND HOW WILL WE USE IT
Information being collected
|Visit our website||Cookies
Browser related data
|to improve the browsing experience,
to accommodate the design of our website
|Register and create an account||Name
VAT ID or Tax ID
Date and time of your request.
|to create a user account for you
to enable us to contact you regarding the management of your account
|Contract by accepting our terms and agreements|
|to send you news and information regarding our products and services||Consent|
|Verify your account details||A photo of you holding your passport or national ID card, document number and expiration date||to verify your identity||Contract, Legal|
|Purchase our services||Name and Surname
|to verify your details
to minimize fraud
to invoice you
|Payment method details||to process your payments to us||Contract|
|End-user proof of address (usually a recent utility bill) Customer ID/driving license/residence permit copies||to comply with local regulations where end user information is required
in order to use local services
|Contact our support team||Your name, email address and phone number
|to provide the needed support and customer care||Contract, when you are a registered user or customer or service provider
Consent in all other cases
|The contents of your messages|
THE BASES ON WHICH WE PROCESS INFORMATION ABOUT YOU
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category. If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data. If the basis changes then, if required by law, we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
- Information we process because we have a contractual obligation with you when you register to create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us. In order to carry out our obligations under that contract, we must process the information that you provide to us. Some of this information may be personal information. We may use this information in order to:
- verify your identity for legal purposes
- promote products and services to you
- provide you with our services
- provide you with suggestions and advice on products, services and how to obtain the most from using them and our website
- Information we process for the purposes of legitimate interests we may process information on the basis there is a legitimate interest, either to you or to us, of doing so. Where we process your information on this basis, we do after having given careful consideration to:
- whether the same objective could be achieved through other means
- whether processing (or not processing) might cause you harm
- whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
- record-keeping for the proper and necessary administration of our business
- responding to unsolicited communication from you to which we believe you would expect a response
- protecting and asserting the legal rights of any party
- insuring against or obtaining professional advice that is required to manage business risk
- protecting your interests where we believe we have a duty to do so.
- Information we process because we have a legal obligation. We are subject to the law therefore, we must process your information in order to comply with statutory obligations. For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.
RETENTION PERIOD FOR PERSONAL DATA
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
- to provide you with the services you have requested;
- to comply with other laws, including for the period demanded by tax authorities (this will typically be a period of 7 years);
- to support a claim or defence in court.
If have not purchased or otherwise used any of our services, your personal information may be deleted by deleting your account.
USE OF INFORMATION WE COLLECT THROUGH AUTOMATED SYSTEMS WHEN YOU VISIT OUR WEBSITE
- to track how you use our website
- to record whether you have seen specific messages we display on our website
- to enable you to sign in to your account on our site
- to maintain the conversation session during a live chat with our support team
Pixels are a small amount of code on a web page or in an email notification. We may use pixels to learn whether you’ve interacted with certain of web or email content on our Services. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
- Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded. We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution. We use this information in aggregate to assess the popularity of the web pages on our website and how we perform in providing content to you. If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
- Our use of remarketing
C. SHARING INFORMATION
- Third-party service providers or consultants. We engage third-party service providers to process payments on our behalf. These providers are limited to only accessing or using this data to provide services to us and must provide reasonable assurances they will appropriately safeguard the data. We do not store your credit card information.
- Compliance with Legal Obligations. We will disclose your or your end users’ personal information to a third party if (i) we required to do so by applicable law, regulation, legal process or a government request (including to meet national security or law enforcement requirements), (ii) to enforce our agreements and policies, (iii) to protect the security or integrity of our services and products, (iv) to protect ourselves, our other customers, or the public from harm or illegal activities, or (v) to respond to an emergency which we believe in good faith requires us to disclose data to assist in preventing a death or serious bodily injury.
- We may share your personal information or your end users’ personal information with an affiliate company, such as a subsidiary of New Capital. We and our subsidiaries will only use the information as described in this notice.
- Aggregated or de-identified data. We might also share data with third parties if the data has been de-identified or aggregated in a way so it cannot be used to identify you or your end users. How third-party service providers handle this data is generally determined by those providers’ own policies and local regulations.
D. INTERNATIONAL TRANSFER OF INFORMATION
The provision of our services requires the transfer of data outside of the European Economic Area (the “EEA”). In order to fulfil our contractual obligations to you, we may transfer, process and store your information in any country in which New Capital or its affiliates, subsidiaries, suppliers or agents maintain facilities. Information collected within the EEA may, for example, be transferred to and processed in a country outside of the EEA which may not provide the same level of protection for personal data as within the EEA. By using our Services, you consent to any such transfer of your information outside your country.
E. COMMUNICATIONS AND NOTIFICATIONS
As part of the service, we may send you messages relating to your account and the services you are using, such as invoices, payment receipts, low balance alerts, technical notifications and other issues. These messages comprise a mandatory part of the services. If you wish to stop them, you must cancel your services. When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our business. We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high-quality service. If you contact our sales or support teams, we will respond to your communications by means of live chat, email or telephone. We may contact you from time to time to keep you up to date with news about our services, including new products, campaigns, promotions and payment methods. You can stop receiving promotional messages by following the instructions included in such messages.
F. THIRD PARTY SITES
G. USE OF SITE BY CHILDREN
We do not sell products or provide services for purchase by children, nor do we market to children. If you are under 18, you may use our website only with consent from a parent or guardian.
H. ACCESS TO YOUR OWN INFORMATION
ACCESS TO YOUR OWN INFORMATION
At any time, you may review or update personally identifiable information that we hold about you, by signing in to your account on our website. To obtain a copy of any information that is not provided in your account section on our website you may send us a request at firstname.lastname@example.org . After receiving the request, we will inform you when we expect to provide you with the information, and whether we require any fee for providing this information to you.
REMOVAL OF YOUR INFORMATION
If you wish us to remove personally identifiable information from our website, you may contact us at email@example.com . This may limit the service we can provide to you.
VERIFICATION OF YOUR INFORMATION
When we receive any request to access, edit or delete personal identifiable information, we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
F. HOW YOU CAN COMPLAIN