Privacy Policy
Updated: July 2020

INTRODUCTION

CapTech (or “we” or “us”) are committed to your rights to privacy. This Privacy Policy, effective as of the date above, is designed to inform you about your rights and how we collect, use and share your personal data. Use of our website (“Site”) indicates agreement with this Privacy Policy and any updates. Any questions may be directed to Privacy@captechconsulting.com.

CapTech works with the world's most successful companies pioneering custom solutions that bridge the gap between business and technology. We are a national IT management consulting firm that collaborates with clients to design, develop, and manage technical and digital solutions that enhance customers experiences and meet strategic objectives. As part of that business and our services, you may share information with us.

INFORMATION YOU PROVIDE TO US

In visiting our site or conducting business with us, you may submit personal data directly to us for several reasons, such as interest in:

  • Learning more about our products and services
  • Accessing our proprietary content
  • Registering for webinars, training programs, courses, or other events
  • Subscribing to newsletters, updates, or requesting additional information
  • Applying for a job

In expressing such interest, you typically submit your name, title, address, telephone number, and email address. That information or combination of data or more sensitive information may be used to identify you (together “Personal Data”). Most of the Personal Data we receive from you may be publicly available, but will be protected as set forth below. Further, when accessing our Site, CapTech will learn other information about you during your visit. Similar to other commercial web sites, our Site utilizes a standard technology called "cookies" (see explanation below, "What Are Cookies?") and web server logs to collect information about how our Site is used. Information gathered through cookies and web server logs may include the date and time of visits, the pages viewed, time spent at our web site, the referring website and your IP address.

HOW WE USE YOUR INFORMATION

To administer our systems and Site, and make improvements to them, we may record non-personal information about your Site access, such as the internet protocol (IP) address and associated fully qualified domain name (FQDN), referring websites, and the browser software you are using to access the Site.

We limit the use of Personal Data to comply with the express use associated with your granted consent. In most instances, this means the Personal Data you provide is used to: deliver our products or services, respond to requests, deliver personalized content and product offerings, or as required for legal compliance or other lawful purposes. Your Personal Data is also used to communicate with you by e-mail, telephone, or text messages and send you marketing materials if you choose to opt-in to such campaigns, of which you may opt-out of at any time. t is the responsibility of each Signature Authority to:

  • Ensure that prior to execution, the appropriate reviews and approvals (Legal, Risk, Finance, Operations, Board of Directors and Markel) are complete; and
  • After execution, obtain and circulate the fully executed document(s) for storage.

Individuals are prohibited from acting as a signing authority in transactions that may result in a direct or indirect personal benefit. No individual may authorize expenditures for departments other than those within their area of responsibility.

COOKIE POLICY

A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a web site, that site's computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each web site can send its own cookie to your browser if your browser's preferences allow it, but (to protect your privacy) your browser only permits a web site to access the cookies it has already sent to you, not the cookies sent to you by other sites.

There are two types of cookies: (1) First-party cookies are created by the site you visited. The site is shown in the address bar. (2) Third-party cookies are created by other sites. These sites own some of the content, like videos or images, that you see on the webpage you visit. The first-party cookies are mostly necessary for the Site to function the right way, and they do not collect any of your Personal Data. The third-party cookies used on our Site are used mainly for understanding how the Site performs, how you interact with our Site, keeping our services secure, providing advertisements that are relevant to you, and all in all providing you with a better and improved user experience and help speed up your future interactions with our Site.

These cookies store information like the number of visitors to the Site, the number of unique visitors, which pages of the Site have been visited, the source of the visit etc. These data help us understand and analyze how well the Site performs and where it needs improvement.

DOUBLE CLICK

We may place pixels from DoubleClick, or other ad serving platforms in order to collect first-party cookie data for use with ad retargeting. This allows us to provide targeted advertising in the future. If you do not wish to receive this type of advertising from us in the future, you can opt out using the DoubleClick opt-out page or the Network Advertising Initiative (NAI) opt-out page on the NAI’s website.

HOW CAN I CONTROL THE COOKIE PREFERENCES?

Should you decide to change your preferences later through your browsing session, you can click on the “Privacy & Cookie Policy” link on the bottom of your screen. This will display the consent notice again enabling you to change your preferences or withdraw your consent entirely.

The “Help” section of the browser toolbar will inform you how to have notifications enabled when a new cookie is received, to prevent your browser from accepting a new cookie, or from disabling the use of cookies completely. Disabling cookies completely may cause CapTech’s Site features not to function as intended. Some browsers permit enablement of a “Do Not Track” feature. We honor this feature and do not track, plant cookies, or use advertising when this mechanism is in place. CapTech also does not permit third party behavioral tracking.

In addition, different browsers provide different methods to block and delete cookies used by websites. You can change the settings of your browser to block/delete the cookies. To find out more out more on how to manage and delete cookies, visit wikipedia.org, www.allaboutcookies.org.

OUR USE OF GOOGLE

We use Google Analytics to understand visitor traffic and navigation preferences for CapTech’s Site. You may opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout.

IP ADDRESSES

IP addresses are used by your computer every time you are connected to the Internet. Your IP address is a number that is used by computers on the network to identify your computer. IP addresses are automatically collected by our web server as part of demographic and profile data known as "traffic data" so that data (such as the Web pages you request) can be sent to you.

EMAIL INFORMATION

If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of information received online, mail and telephone.

THIRD PARTIES AND INFORMATION WE SHARE

Other than as set forth above, CapTech will not obtain Personal Data about you when you visit our Site, unless you choose to provide such information to us, nor will such information be sold or otherwise transferred to unaffiliated third parties without the approval of the user at the time of collection.

We may disclose information when legally compelled to do so, in other words, when we, in good faith, believe that the law requires it or for the protection of our legal rights. We may also link to other websites which are controlled by third parties. These third-party websites are not under CapTech’s control. Thus, once you have clicked these links and are on the third-party websites, you and your data are subject to the privacy notices or privacy policies of the third parties and not CapTech. Once navigating away from CapTech’s Site, we recommend you take the opportunity to familiarize yourself with your rights under any third-party privacy notice

Additionally, third party vendors may help us administer our Site, communication with you or others, comply with regulations, or deliver services. We may share your data with them in support of any of these goals. However, prior to doing so, we obtain assurances from our vendors that they will safeguard your Personal Data. There may be other limited instances where we need to share your Personal Data in order to respond to your request or inquiry.

YOUR CHOICES, ACCESS, CORRECTION, AND DELETION

To process your Personal Data, we typically rely upon your consent, contract performance, our legitimate business interest, or compliance with law. You may object to or restrict our processing of your Personal Data. You may withdraw any prior consent you may have given to Process Personal Data at any time. It is also within your rights to refuse to provide any Personal Data we request. However, refusal to provide certain Personal Data may limit your access to information or certain areas of CapTech’s Site.

Should you wish to access or amend any Personal Data you may have provided us or if you wish to request deletion, please contact at Privacy@CapTech.com. Your Personal Data will be deleted or blocked from our database at your request.

HOW DO WE PROTECT YOUR INFORMATION AND SECURE INFORMATION TRANSMISSIONS?

CapTech safeguards your Personal Data by regularly scanning the Site and taking commercially reasonable steps to make it as secure as possible. Despite the security measures we have implemented, it is well-known that Internet data transmission and electronic data storage are not 100% safe. As such, CapTech cannot and does not warrant the security of your Personal Data.

Email is not recognized as a secure medium of communication. For this reason, we request that you do not send private information to us by email. However, doing so is allowed, but at your own risk. Some of the information you may enter on our Site may be transmitted securely via a secure medium known as Secure Sockets Layer, or SSL. Credit Card information should never be transmitted via email.

CapTech may use software programs to create summary statistics, which are used for such purposes as assessing the number of visitors to the different sections of our Site, what information is of most and least interest, determining technical design specifications, and identifying system performance or problem areas.

For site security purposes and to ensure that this service remains available to all users, CapTech uses software programs to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage.

RIGHTS OF CERTAIN TYPES OF USERS

Subject to local law, you may have certain rights with regard to your Personal Data. To learn more about the Personal Data we collect about you or the rights you may have, please contact us at the contact information below. These rights may include the following rights to (1) access or rectify your Personal Data or request its deletion, (2) request a restriction on the processing of your Personal Data, (3) object to the processing of your Personal Data, or (4) exercise other rights with respect to your Personal Data. Please contact us as described below. While we strongly encourage you to first raise any questions or concerns about your Personal Data directly with us, you may have a right to lodge a complaint with the relevant supervisory authority.

A. INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA/EUROPEAN UNION (EU) - GDPR

CapTech’s headquarters and offices are in the United States and we do not intentionally target European visitors to our web site. For clients in the European Union (“EU”), where data collections specifically apply to them, CapTech complies with the EU General Data Protection Regulation 2016/679/EU (“GDPR”) as set forth by the EU regarding the collection, use, and retention of Personal Data from the EU member countries and Switzerland.

If you are a European resident or considered a Data Subject under GDPR, you have the following rights: [add in rights under those add in general statement or do we need more – RVA]

Rights under GDPR

Right to withdraw consent to the Processing of Personal Data at any time.

Right to object to the Processing of Personal Data if the Processing is carried out on a legal basis other than consent.

Right to learn if Personal Data is being Processed by CapTech, obtain disclosure regarding certain aspects of Processing, and obtain a copy of the Personal Data undergoing processing. (CapTech reserves the right to charge you a small but reasonable fee for this service, if requests are unfounded, repetitive, or excessive.)

Right to verify the accuracy of Personal Data and ask for it to be updated or corrected.

Right, under certain circumstances to restrict the Processing of Personal Data. In this case, CapTech will not Process Personal Data for any purpose other than storing it.

Right to receive Personal Data in a structured, commonly used, machine-readable format and, if technically feasible, to have it transmitted to another Controller without any hindrance. This provision is applicable provided that the Personal Data is processed by automated means and that the processing is based on your consent, on a contract which you are a part of or on pre-contractual obligations thereof.

Right to bring a claim before your competent data protection authority (DTA).

B. CALIFORNIA PRIVACY RIGHTS (CCPA)

We abide by California law where applicable for any California residents using our Site. You can request access to and/or revision of certain Personal Data by contacting us as described below. If you wish to limit the emails you receive from us, you can let us know by contacting us. California residents can make certain requests about their personal information under the California Consumer Privacy Act (“CCPA”). Specifically, if you are a California resident, you may request that we:

  1. Provide you with information about: the categories of personal information we collect, disclose or sell about you; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we share personal information. Such information is also set forth in this Policy;
  2. Provide access to and/or a copy of certain information we hold about you;
  3. Delete certain information we have about you; and/or
  4. Provide you with information about the financial incentives that we offer to you, if any.
  5. Send general information and answer questions and queries.
  6. Provide sales updates and information.
  7. Engage in marketing activities.
  8. Determine collaboration or partnership interest/opportunities of mutual interest.

California residents can also designate an authorized agent to make access and/or deletion requests on their behalf. We will take reasonable steps to verify your identity before responding to a request for access and/or deletion from you or your designated agent. The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights. Please note that certain information may be exempt from such requests under California law.

If you are a California resident and would like to exercise any of legal rights under the CCPA, please contact us at Privacy@CapTech.com.

The CCPA also sets forth certain obligations for businesses that “sell” personal information. Pursuant to the definition of “sell” under the CCPA and current guidance, we do not engage in such activity and have not engaged in such activity in the past twelve months, including for minors under 16.

If you are a California resident, California law requires us to provide you with information regarding how we collect, use, and share your “personal information” (as defined in the CCPA). We describe the categories of information we collect, our business purposes for collecting such information, the sources and uses of such information and the entities to which we share such information in this Policy above.

C. CANADA

CapTech also operates consistently with Canadian Anti-Spam Legislation (“CASL”). We do not send unauthorized Commercial Electronic Messages (“CEM”) to Canadian email addresses, unless they have opted-in to receive CEM. We understand a message sent to request consent is also considered CEM under CASL and we do not engage in this activity.

D. CHILDREN’S POLICY

CapTech’s Site is not intended for children under 16 years of age, nor do we knowingly market or sell any goods or services to persons under the age of 18. Accordingly, we do not knowingly process Personal Data from anyone under 18 years of age and anyone under 18 years of age should not submit any Personal Data to CapTech.

E. OTHER COMMUNICATIONS AND RIGHTS

Telephone/Text – CapTech seeks your consent before contacting you. Specifically, by e-signing your name and checking the box labeled YES where you provide your contact information, you are authorizing CapTech and/or its service providers to contact you at the number you listed via phone or text (SMS), including (as necessary) using automated dialing technology, for marketing or advertising purposes, or regarding your business with us. No purchase is required. No agreement or signature is required for you to receive the services. Separate message and data rates may apply. To opt-out at any time you may reply STOP to any CapTech text message. We acknowledge that this consent may be revoked at any time, but that until such consent is revoked, you may receive calls and text (SMS) messages from CapTech. If you are a job applicant, additional information will be collected, including sensitive Personal Data, and advanced consent will be obtained.

Email - CapTech seeks your consent before contacting you. Specifically, by providing your contact information and clicking the box labeled Subscribe where you provide your contact information, you are authorizing CapTech and/or its service providers to contact you via email. We may collect and send you email for the following purposes but will always accurately identify ourselves and use truthful and accurate subjects and information.

We have provided an “Unsubscribe” link at the bottom of any such email or communication and will promptly fulfill your request to opt-out/unsubscribe to these communications.

REQUESTS, RECOURSE, ENFORCEMENT, AND LIABILITY

Complaints and issues escalated to CapTech will be responded to promptly, especially with regard to any data breach, but in any event within 30 days of receipt. CapTech will investigate any complaints and issues, attempting to promote expedited resolution. To escalate any issue or complaint, please contact Privacy@CapTech.com.

POLICY CHANGES

We reserve the right to amend this privacy policy at any time with or without notice. However, please be assured that if the Privacy Policy changes in the future, we will not use the personal information you have submitted to us under this Privacy Policy in a manner that is materially inconsistent with this Privacy Policy, without your prior consent.

If you have any questions regarding this Policy, or your dealings with our Site, please contact us here.

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