Privacy Policy

Last updated: Tuesday February 19th, 2019

This document describes how Septa Communications LLC (‘Company’, ‘we’, ‘us’, ‘our’) collects information about users of https://captaingrowth.ai website (‘Website’).

Owner of Website
SEPTA COMMUNICATIONS LLC
Address: 01054, Ukraine, Kyiv, Pavlivska str, of 79
Contact email: support@captaingrowth.ai

Types of Information collected
The information collected on this Website may be freely provided by the user, or, in case of usage data, collected automatically when using this Website.
Information that user provides to us:
Account registration information. This information includes user name, e-mail address, and password. This information will be used to create the user account on our Website, provide the user with our services, and contact him/her regarding the user account or the work of our services. If we obtain a relevant consent from the user, we can also send him/her commercial e-mails.

Contact or subscription forms. Our Website may contain forms for contacting us or receiving our newsletters. For this, the user will be asked to provide his e-mail address. We will use this address to contact the user or to send him our newsletters with useful insights or articles.

Social networks. The user has an option to connect his account on our Website to his profiles in social networks, such as Facebook or Google. If the user chooses so, we will obtain the link to his/her social network account, and some general information, such as name, e-mail address, and the profile photo. The user will be provided with a full list of information before connecting his profile. Connecting will allow him to log-in to our Website through the social networks and use his accounts for marketing and advertisement analysis on our Website.
Advertisement and marketing statistics. To use our analytical services, the user must provide us with access to his advertisement statistics on Google and/or Facebook. We will use this data to analyze the efficiency of advertisements and help the user to optimize it. Please note, that this data is in aggregate form and does not contain any identifiable information about end-users/viewers of advertisements. We cannot review the profiles of separate persons who viewed the advertisements.

User comments. In certain places, such as the blog on our Website, the users have an option to comment the blog. If the user leaves comments, they will be tied to his/her Facebook profile. The other users will be able to see the comments and the link to Facebook profile publicly.

Data we collect automatically through the Website:
Cookies. A cookie is a small text file that is stored on the user’s computer for record-keeping purposes. We collect cookies from users on our Website to optimize the work of the Website, personalize its content and for analytical purposes. To learn more, please read our Cookie Policy.

We or our service providers may collect information about the use of the Website, such as information about devices, IP-addresses (including geolocation data) from which users access our Website, time, duration, and character of the use. We collect this information to better understand the efficiency and usability of our Website. Learn more about it in the section “Analytics” of this notice.

This information is being collected in an anonymized and aggregate form to better understand the efficiency and usability of our Website. Learn more about it in the section “Analytics” of this notice.

Legal Basis of Processing
We process information about Website users on the following legal basis:
If the information is necessary for the provision of our services. For example, without account information and advertisement and marketing statistics from users, we will be unable to provide our marketing analytics services. We use account information, e-mail addresses (to contact the user regarding his/her account or work of our Website), social networks information with advertisement and marketing statistics, and cookies that are necessary for running the Website on this basis;

Users have given their consent for one or more specific purposes. We obtain the prior consent from users for: (a) using marketing cookies; (b) send to users our commercial e-mails with discounts and special offers. The user can withdraw the consent to cookies or commercial e-mails by contacting us at any time. Also, it can be done on the settings page. The withdrawal of consent will not affect the lawfulness of processing based on consent before.
Use of the information is in our legitimate interests. In particular, such legitimate interests are our marketing processing of information. We conduct marketing research and can send marketing (with no commercial offer) e-mails based on our legitimate interests.

Also, we may be required to process the information for compliance with a legal obligation or in relation to a task that is carried out in the public interest or in the exercise of official authority. Latter are exceptional cases, and we do not do it regularly.

Third-party Access
E-mail notifications
We are using third parties’ notifications and mailing services for sending our e-mail notifications, newsletters, announcements, and other products and service offers from us. These third parties may only use information about users to perform services on our behalf. They are not allowed to use it for their own purposes.

Analytics
Our third-party providers, such as Amplitude (https://amplitude.com/) and Hubspot (https://www.hubspot.com), collect details of the Website use, including, but not limited to traffic data, location data, user ID, length visit, other communication data, IP address, device information (such as hardware model, operating system version, unique device identifiers). We use this data to improve the Website usability and for marketing purposes.
Also, services like Google Analytics can collect Non-Personally Identifiable Information (in an anonymized and aggregate form) to provide us with statistics on the use of the Website.
Google Analytics is a web analytics service that tracks and reports traffic on the Website. Google Analytics uses the data collected to track and monitor the use of our Website. This data may also be shared with other Google services.
For more information on the privacy practices of Google, please check its Policies at www.google.com/analytics/policies/.

Payments
For processing the payments on our Website, we use third-party services. We will not store or collect payment card details. That information is provided directly to our third-party payment processors whose use of personal information is governed by their Privacy Policy. These payment processors ensure the security and confidentiality of payment information.

Other Disclosures
In addition to the disclosures for the purposes identified before, we may disclose information:
if we are required to do so by law, in connection with any legal proceedings or to establish, exercise or defend our legal rights; and
in case we sell, license or otherwise assign our Company, corporate rights, the Website or its separate parts or services provided on the Website to third parties.
Except as provided in this privacy notice, we will not sell, share or rent user information to third parties.

Retention time
We process and store collected information for as long as required by the purpose of collection.
We will not store/process user information if he/she deletes the account or we do not use it anymore for the purposes listed in this privacy policy.
We will delete user information within one month after the deletion of his account / receiving the request to do so. We will delete the user account if he/she has not been using it for more than two years (24 months). We will delete information after we no longer use it for our purposes.
However, we can retain information to comply with our legal obligations (for example, if we are required to retain data to comply with financial regulations), resolve disputes, and enforce our legal agreements and policies, or in an anonymized and aggregate way.

Rights of Users
Users may exercise certain rights regarding their information processed by us.
In particular, users have the right to do the following:
Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing, for example, for commercial e-mails or marketing cookies;
Object to the processing of their information. Users have the right to object to the processing of their information if the processing is carried out on a legal basis other than consent.
Access their information. Users have the right to learn if their information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of the information and ask for it to be updated or corrected.
Restrict the processing of their information. Users have the right to temporarily restrict the processing of their information to check if the processing was lawful. In this case, we will not process the information for any purpose other than storing it.
Have their information deleted or otherwise removed.
Receive their information and have it transferred to another organization.
Users can complete their requests to exercise their rights by contacting us at support@captaingrowth.ai
If the user believes that our use of personal information violates his/her rights, the user can lodge a complaint with national data protection authority.

Security of information
We store the users’ information on the servers of the cloud provider inside the European Union. These servers have all technical measures to store the data securely and protected against unauthorized access. However, we may also transfer users’ information locally across different jurisdictions to perform processing activities. In this case, we ensure the appropriate safeguards are in place to protect the information, such as Standard Contractual Clauses signed with processors. To learn more about international transfers of information, contact us by our contact e-mail address.
We take necessary and sufficient organizational measures to protect users’ information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.
Immediate access to some amount of the data is only allowed to our authorized employees involved in maintaining our services. Such employees keep strict confidentiality and prevent unauthorized third-party access to personal information.

Changes to this privacy policy
We can make changes to this privacy policy at any time by giving notice to our users on this page and possibly within this Website and – as far as technically and legally feasible – sending a notice contact information. It is strongly recommended to check this page from time to time.

Should the changes affect processing activities performed on the basis of the user’s consent, we will collect new consent from the user, where required.

Third-party services
Our Website may contain links to third-party services and platforms. Although we choose our partners thoroughly and diligently, we cannot be responsible for the content, terms and conditions or privacy policies of third-party services.
We encourage users to be aware when they leave our Website and to read the privacy statements of the services that collect personally identifiable information.
Third-party websites may contain their own cookies. We are not responsible for their usage of cookies.

Information not contained in this policy
More details concerning the collection or processing of users’ information may be requested from us at any time. Please see the contact information at the beginning of this document.