CAPSTONE WIRELESS, LLC. PRIVACY NOTICE
The updated the Capstone Wireless Privacy Notice goes into effect on July, 2020
Capstone Wireless, LLC. and its worldwide affiliates and subsidiaries (collectively “Capstone Wireless”, “us”, “we”, “our”) are committed to protecting your privacy while providing you with a positive experience on our website and in using our products and services.
This Privacy Notice (“Notice”) explains our privacy practices and provides information on how and why we collect, use and share your personal data from our customers, website visitors, and end users of our products and services (collectively “you”, “your”) through our interaction with you and through our products and services and when you visit our website, available at www.capstonego.com and associated sub-domains (“Website”) collaboration platform (“Services”). The policy also describes your choices regarding use, access, deletion and correction of your personal information.
Capstone Wireless’ Privacy Notice applies to Capstone Wireless websites and Services that link to or reference this Notice. Additional information on our personal information practices may be provided in supplemental term and conditions, supplemental privacy statements, or notices provided prior to or at the time of data collection.
We recommend that you read this Notice in full to ensure you are fully informed. However, if you only want to access a particular section of this Notice, then you can click on the relevant link below to jump to that section.
Information We Collect
Information We Use
Sharing and Disclosure of Information to Third Parties
Your Privacy Rights
Blogs and Forums
International Data Transfers
Updates to this Notice
INFORMATION WE COLLECT
As used in this Notice, “personal information” or “personal data” means any information or data relating to an identified or identifiable natural person or household (an “identifier”) that we process in connection with our Websites, Apps, and Services; an identified or identifiable natural person or household is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person or household;
Information which you actively provide to us
We may ask you to provide certain personal information when you create a Capstone Wireless account, or when you visit or use certain parts of our Website, Apps and Services. The personal information that you are asked to provide, and the reasons you are asked to provide it, will depend on the context in which we are asking for the information.
We collect information which you provide directly to us when you use our Website, Apps or Services. The types of personal information we may collect directly from you include email addresses, postal addresses, phone numbers, employee names, usernames, information about the type of service required, marketing preferences, job titles, credit card payment information, transactional information (including Services purchased), as well as any communications, inquiries, contact or other information you choose to provide during your use of the Services.
When you actively provide this personal information, we will only use this information in a manner that is reasonably proportionate to achieve the specific purpose(s) for which we collect the information.
Information we collect from End Users on behalf of Capstone Wireless customers
If you are not a Capstone Wireless customer but you engage in communications powered by Capstone Wireless Services (an “End User”), we may collect and store personal information about you on behalf of a Capstone Wireless customer. You may directly communicate this information to us (for example, via a fill-out form or during the process of signing up for an account to publish and share content on Capstone Wireless’ Knowledge Base platform) or indirectly (for example, by providing the personal information to the Capstone Wireless customer during a conversation, and the Capstone Wireless customer causes the information to be entered into our systems).
This may include your full name, email address, username, other forms of personal information we collect on behalf of the relevant customer, and other forms of personal information we collect as necessary to offer the relevant Website, App or Service. We use this information in connection with providing our Website, App and/or Services to the Capstone Wireless client on whose behalf we collect or store the information, as otherwise necessary to administer and maintain our Website, Apps or Services, and for other legitimate business purposes permitted by our agreement with the relevant Capstone Wireless client.
Certain Capstone Wireless products and services may also access and store personal information about you from a customer’s social media accounts or accounts a customer may have with other third-party services, when the customer chooses to connect its Capstone Wireless accounts with its other accounts. With respect to social media, only personal information that an End User has directly provided to the relevant Capstone Wireless customer or that an End User has designated as publicly accessible will be accessed or stored. We use this information in connection with providing our Services to our clients. For example, we use this information to enable Capstone Wireless customers to respond to social media posts and messages from within their Capstone Wireless accounts, and to enable Capstone Wireless customers to track and analyze their interactions with End Users via social media.
Information we collect automatically when you visit our Website or Apps or use our Services
When you visit our Website, or use our Apps or Services, we may collect certain information automatically from your device. In some jurisdictions, including in the European Economic Area, this information may be considered personal data under applicable data protection laws:
Usage information – We keep track of your activity in relation to the Website, Apps or Services, the configuration of your device, and performance metrics related to your use of the Website, Apps or Services. For example, when you use our Services, we may collect:
- Traffic data about the communications that take place through our platform (such as calls, team chat, video conferencing, SMS) to enable us to transmit those communications effectively and efficiently
- Network Monitoring data to enable us to maintain the security and agility of our internal networks
- Log data about you when they use the Services, Website or Apps including Internet Protocol (“IP “) address, Internet Service Provider (“ISP”), browser type, referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site
- Device data about any device including mobile phone number and other information related to mobile devices like operating system and model if you use our Services via our Apps. For other devices information collected by cookies and other similar technologies. We use various technologies to collect information which may include saving cookies to your computers
- Call Detail Records of data record produced by a telephone call or other telecommunications transactions. The record contains various attributes of the call, such as time, duration, completion status, source number and destination number
- Meta data, which is data created about other data which can include size, formatting, other characteristics of a data item
- Emails/Communications with us
- Billing data, which includes any payment data; an
- Publicly available data from End User accounts
Cookies and other similar technologies – We use various technologies to collect information which may include cookies when you visit our Website or use our Apps or Services. Please see the Capstone Wireless Cookies Notice for further information.
Information we collect from third parties
We may collect the names, e-mail addresses, postal addresses and city of residence of individuals from third parties to market our products / services to these individuals. This collection of information and marketing is always carried out in compliance with applicable law. We only receive this information where we have checked that these third parties either have your consent or these third parties are otherwise legally permitted or required to disclose your personal information to us.
We may receive personal information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you, in accordance with applicable laws. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you.
We may collect personal information about you from other applications you may use if you choose to integrate Capstone Wireless Apps or Services with other Apps or Services.
INFORMATION WE USE
Information that directly identifies or can be reasonably used to figure out the identity of, a customer or user, such as a name, address, phone number, and e-mail address. Personal Information does not include published listing information.
- Administer, operate, protect and maintain the Website, Apps or Services
- Process and complete transactions, and send related information, including transaction confirmations and invoices
- Manage and improve your use of the Website, Apps or Services
- Prepare and provide you testimonials regarding the Website, Apps and / or Services
- To help deliver our Website, Apps, or Services to Customers for service and support
- Investigate and prevent fraudulent activities, unauthorized access to the Website, Apps or Services, and other illegal activities
- For any other purposes about which we notify and receive your consent from you
- To help personalize your experience and retarget you for advertising purposes
- Respond to inquiries and requests and to provide you with information and access to resources that you have requested
- Aggregate and analyze your and use of the Website, Apps or Services for trend monitoring, marketing advertising purposes
- Send you technical alerts, updates, security notifications, and administrative communications.
We and our third-party marketing service providers may also use the information Customers send to us for our marketing purposes, if this is in accordance with your marketing preferences and applicable law. However, you may opt out of our marketing. For further information, see the “Unsubscribe from our mailing List” section below.
Legal basis for processing personal information (EEA only)
If we collect personal information from you in connection with offering our Website, Apps or Services within the European Economic Area (EEA), our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the personal information in question.
If we ask you to provide personal information to comply with a legal requirement or enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
Similarly, if we collect and use your personal information in reliance on our or a third party’s legitimate interests and those interests are not already listed above (see “Information We Use” section), we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contact Us” section below.
SHARING AND DISCLOSURE OF INFORMATION TO THIRD PARTIES
We will not rent or sell personal information about you. We may share and disclose your information that we collect with the following third parties, solely for a legitimate business or legal purposes and in accordance with applicable law:
- Capstone Wireless or any of its worldwide affiliates consistent with this notice for data processing business partners, contractors, vendors, and authorized third party agents, to operate, deliver, improve and customize our services
- Provide support and technical services
- Send marketing and other operational communications related to our services
- Enforce our acceptable use policy
- Law enforcement agencies, regulatory or governmental bodies, or other third-parties in order to respond to legal process, comply with any legal obligation; protect or defend our rights, interests or property or that of third parties; prevent or investigate wrongdoing in connection with the Website, Apps or our Services
- Any third-parties in connection with prospective or actual, sale, merger, acquisition, financing or reorganization of our business.
Note that, for California residents, we define “sale” and “personal information” in accordance with applicable California law.
YOUR PRIVACY RIGHTS
Update and access to your information
Where we process personal information collected via our Website or Apps or via our Services for our own account management, billing or marketing purposes and where required by applicable law, we provide individuals with the opportunity to access, review, modify, and delete any such personal information that we process.
Requests from End Users
If you believe Capstone Wireless may have collected or stored personal information from you on behalf of a Capstone Wireless customer, please contact the Capstone Wireless customer with any requests related to your personal information.
Your Privacy Rights as a data subject protected by EEA law or California Resident
In addition, if you are an EEA person, a person located in the EEA, or in certain circumstances if you are a California resident, you may have broader rights to access and delete your personal information, to object to or restrict processing of your personal information, to correct your personal information, or request portability of your personal information.
If you are an End User who’s personal data we collected on behalf of a Capstone Wireless customer, please contact the relevant Capstone Wireless customer directly to make such requests. In other circumstances, you can submit a request through our online portal. We will consider and handle all requests in accordance with applicable laws.
If we have collected and processed your personal information with your consent and it is protected by EEA law, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You also have the right to complain to your local data protection authority at any time. In general, when processing personal information to provide our Services, we do so only on behalf of our EEA Customers and in accordance with their instructions. This means that if you wish to access, review, modify or delete any personal information we process on behalf of a Capstone Wireless Customer, under applicable EEA law or otherwise, you should contact that Customer with your request. We will then help them to fulfill that request in accordance with their instructions.
Additional Privacy Rights as a California Resident
If you are a California resident and receive Capstone Wireless Services or visit our Website or Apps solely as a private individual—in other words, not as the member or representative of a company or other organization—you may have the right to receive a free, yearly accounting of:
(1) information identifying each third-party company to whom we may have disclosed, within the past year, personal information pertaining to you for our direct marketing purposes; and
(2) a description of the categories of personal information disclosed.
If you are a California resident who qualifies to receive such an accounting and would like to make one, please email email@example.com. We do not engage in the sale of personal information within the meaning of California law.
Unsubscribe from our mailing list
We give you the choice of receiving a variety of information related to our Apps and Services. You can manage your communication preferences through the following methods:
By following the instructions included in each promotional email from us to unsubscribe from that particular mailing or send us an email at firstname.lastname@example.org with the subject line, Unsubscribe.
These choices do not apply to service notifications or other required communications that are considered part of certain Apps/Services, which you may receive periodically unless you stop using or cancel the App/Service in accordance with its terms and conditions.
This Notice does not apply to, nor are we responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Website links including but not limited to social media sites. The inclusion of a link on the Website does not imply our endorsement of the linked site or service. You should check the privacy notices of those sites before providing your personal information to them.
BLOGS AND FORUMS
Our Website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas is public and may be read, collected, and used by others who access them and may remain on the public forum indefinitely. To request removal of your personal information from our blog or community forum, you can submit a request through our online portal. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. We encourage all Users to exercise caution when providing personal information in blogs and community forums.
Keeping your information secure is important to us. We maintain a variety of appropriate technical and organizational safeguards to protect your personal information both during transmission and once it is received. Capstone Wireless has no control over or responsibility for the security or privacy policies or practices of other sites on the Internet you might visit, interact with, or from which you might buy products or Services, even if you visit them using links from our Website.
Please note that no website, mobile app or service is completely secure and so, while we endeavor to protect our Customers’ information using the measures described above, we cannot guarantee that unauthorized access, hacking, data loss or a data breach will not occur.
We will retain your personal information for no longer than is necessary to fulfill the purposes for which the information was originally collected unless a longer retention period is required or permitted by law, for legal, tax or regulatory reasons, or other legitimate and lawful business purposes.
Where we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it.
INTERNATIONAL DATA TRANSFERS
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. Specifically, information collected outside the United States, including in the European Economic Area (“EEA”), may be transferred to and stored on our servers in the United States, Switzerland, and Netherlands, and potentially in other countries where our group companies and third-party service providers and partners operate. These countries may have data protection laws that are different to the laws in your country (and in some cases, may not be as protective).
However, we have taken appropriate safeguards to ensure that your personal information will remain protected in accordance with this Notice and applicable laws. For example, in respect of personal information originating from the EU and Switzerland, Capstone Wireless has self-certified to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks. Please click here to view our Privacy Shield Notice.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Capstone Wireless does not provide products or services that are designed for use by children under the age of 16, or knowingly collect personal information from or about children under the age of 16. If you believe that a child under the age of 16 has disclosed personal information to Capstone Wireless, please contact email@example.com.
UPDATES TO THIS NOTICE
We may update this Notice from time to time in response to changing legal, technical, or business developments. If we change our Notice, we will post those changes on this page in addition to updating the “Last Updated” date at the top of this webpage. If we make changes, we will notify you more directly, for example by posting a notification or message on the Website or by emailing you prior to such changes taking effect. We encourage you to review this Notice regularly to stay informed of the latest modifications.
If you have any questions, comments or concerns about this Notice, please e-mail our data protection officer at firstname.lastname@example.org. Or, you can write to us at:
Capstone Wireless, LLC.
Attn: Data Protection Officer
11450 Pagemill Road,