We collect personal data and other data (as defined below) through:
(1) websites operated by us and other websites owned or controlled by Capitalise (collectively, the “Websites”);
(2) through our social media pages that we control (collectively, our “Social Media Pages”); By using the Services, you agree to the terms and conditions of this Privacy Statement. Please read this Privacy Statement carefully.
Capitalise serves as a Data Controller and in some other cases, also serves as a data processor (depends on the brokers terms\agreement) of Personal Data about you. You are aware that your Personal Data as defined below, may be stored in Capitalise database and that providing the Personal Data is subject to your wish and your consent. However, if you do not provide us with the Personal Data that we request, or prohibit us from collecting such data, we may not be able to provide you with the Services.
Collection of Personal Data and of Other Data:
“Personal Data” means data that identifies you as an individual or relates to an identifiable individual. We collect Personal Data, such as:
– Contact information (Name, IP address, email address, phone number);
– Demographic data (Regional and language settings);
– Cookie information, search history, device ID, software and hardware attributes.
“Other Data” means data that does not reveal your specific identity or does not relate to an individual directly. We collect Other Data, such as, browser and device data including data collected through cookies, pixel tags and other technologies, aggregated data relative to your online activity on the platform, and responses to promotional offers and surveys.
In some instances, we may combine Other Data with Personal Data (such as combining your name with your location). If we do, we will treat the combined data as Personal Data as long as it is combined.
If you submit any Personal Data about other people to us or our service providers, you represent that you have the authority to do so and you permit us to use the data in accordance with this Privacy Statement.
How We Collect Personal Data and Other Data:
We collect Personal Data and Other Data in a variety of ways:
– Online platform. We collect Personal Data when you use our platform or receive our services, communicate with us, or otherwise connect with us or post to social media pages, or sign up for a newsletter or participate in a survey, promotional offer or submit a job application.
– Other Sources. We may receive Personal Data about you from other third parties. This may include information from your broker, state authorities in order to meet legal requirements, surveys companies and our sub-contractors and services providers, etc.
– Automatic Information: When you use or interact with our website and/or use any apps that we may make available on our website, we receive and store information generated by your activity and information automatically collected from your browser or mobile device. For example, like many websites, we obtain certain information when your web browser accesses our website including your IP address, browser type, operating system, mobile network data, pages viewed and access times. This information helps us to communicate with our customers and provide them with our Services.
– Support service. We collect Personal Data when you communicate with our support center over the web, communicate with us by email, or via online chat services or contact customer service. These communications may be recorded for purposes of quality assurance.
– Aggregated Data. We may aggregate data that we collect and this aggregated data will not personally identify you or any other user.
Use of Personal Data and Other Data:
We use Personal Data and Other Data for one or more of the purposes detailed below:
– Usage of our platform: We may process information relating to transactions that you enter into with us and/or through brokers’ websites (“Transaction Data”). The transaction data may be processed for the purpose of supplying our services, customizing our services to your preferences, and keeping proper records of those transactions.
– Response to inquiries: We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping.
– Internal Business Purposes: For our internal business purposes, enhancing the website, improving our services, identifying usage trends and visiting patterns, determining the effectiveness of our promotions, predicating our yield and occupancy, and meeting contractual obligations.
– Administrative and other communications: To send you important information regarding our platform, changes to our terms, conditions, and policies, or other administrative information.
– Marketing and promotions: To communicate news and promotions to you regarding Capitalise related services we think may be of interest to you.
– Safety and security: To maintain your safety and security as well as that of other users, while you use Capitalise’s services.
– Our legal duties: To comply with legal and regulatory requirements or demands in accordance with applicable law, regulations, or other legal process.
– We may use some or all of the Personal Data and Other Data in order to perform certain statistical calculations, this research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our affiliates, agents and business partners.
However, that none of these calculations shall include any personally identifiable information or details.
The legal basis for processing your Personal Data is made up of one or more of the following reasons:
– Your consent.
– Providing the Services.
– Compliance with applicable laws, regulations or other legal process.
– Legitimate Business Interest.
Disclosure of Personal Data and Other Data:
We share Personal Data and Other Data with the following:
– Brokers, in order to provide better service experience based upon your preferences and strategies;
– Service Providers and suppliers that assist us in providing services. Examples of such service providers and suppliers are legal advisers, accountants, suppliers of payment services etc.
– Our marketing and advertisement partners to provide you with more-relevant ads and to encourage you to keep using the platform. These partners will not use your data for any other purpose than our legitimate interest of direct marketing and you will always have the right to object.
– We may disclose or transfer your Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Capitalise business and assets (including any bankruptcy or similar proceedings).
We may also disclose Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities, (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect the rights, privacy, safety or property of Capitalise , of you or of others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
– As a general principal, any data processing is held within European Union (“EU”) and Israel borders including processing by our third parties.
– Notwithstanding, some information might be held on a cloud which might be held outside the borders of Israel or in the EU. The operator of such services undertakes to comply with the General Data Protection Regulations provisions. In this specific case, be sure that we will verify that appropriate measures have been put in place to ensure that your Personal Data benefits from an adequate level of protection (in particular through standard contractual clauses of the European Commission, the Internal Company Rules or the Data Protection Shield set up between the European Union and the United States).
How You Can Access, Change, or Limit the Use of Your Personal Data
If you reside in the EU the following provisions will apply to you:
– The right to information on the processing of your Personal Data. We strive to provide you with concise, transparent, understandable and easily accessible information on the conditions for processing your personal data, in clear and simple terms.
– The right to access, rectify, delete your Personal Data. The right of access allows you to obtain from us confirmation that your Personal Data have or have not been processed as well as the conditions of such processing, and to receive an electronic copy (for any additional copy, we are entitled to demand payment of any reasonable fees based on the administrative costs incurred).
– The right to obtain from us the rectification of your Personal Data.
– Subject to the exceptions provided by applicable law, you have the right to ask us to delete your Personal Data, when one of the following grounds applies:
Your Personal Data are no longer necessary for the purposes for which they were collected or otherwise processed;
You wish to withdraw your consent on which the processing of your Personal Data was based and there is no other basis justifying such processing;
You consider and can establish that your Personal Data has been unlawfully processed;
Your Personal Data must be deleted in accordance with a legal obligation.
The right to restrict the processing of your Personal Data; The applicable regulations provide that this right may be invoked in certain cases, in particular the following:
When you dispute the accuracy of your personal data;
When you consider and can establish that the processing of Personal Data is unlawful but you oppose the deletion of Personal Data and demand instead that the processing be limited;
When we no longer need your Personal Data but they are still necessary for you to establish, exercise or defend your legal rights;
When you object to the processing that would be based on the legitimate interest of the controller, during the verification whether the legitimate grounds pursued by the controller prevail over those of the person in question.
– The right to data portability.
When the processing is based on your consent or a contract, this right to portability allows you to receive the Personal Data you have provided to us with in a structured, commonly used format, and to transmit this Personal Data to another data controller without us hindering it.
– The right to withdraw consent.
When we process your Personal Data on the basis of your consent, this latter may be withdrawn at any time using the means provided for this purpose (procedure indicated below of this Policy). On the other hand, and in accordance with applicable law, the withdrawal of your consent is only valid for the future and cannot therefore call into question the lawfulness of the processing carried out before this withdrawal.
– The right to decide the fate of your Personal Data after your death
To organize the fate of your personal post-mortem data through the adoption of general or specific guidelines. We are committed to respecting these guidelines. In the absence of directives, we recognize the possibility for heirs to exercise certain rights, in particular the right of access, if it is necessary for the settlement of the deceased’s estate; the right to object to the closure of the deceased’s user accounts; and the right to object to the processing of their data.
– The right to lodge a complaint with a supervisory authority. If, despite our effort to preserve the confidentiality of your personal data, you feel that your rights are not respected, you have the right to lodge a complaint with a supervisory authority. A list of control authorities is available on the European Commission’s website.
– If you reside anywhere outside the EU (including Israel) your rights to review, edit or amend Personal Data held in our Databases will be governed applicable Israeli law, including the provisions of the Protection of Privacy Law, 5741-1981.
We implement reasonable administrative, organizational and technical safeguards and security measures to protect Personal Data from unauthorized access, disclosure, destruction or alteration, accidental loss, misuse or damage. We regularly review and monitor such safeguards and security measures.
When disclosure of data to third parties is necessary and authorized, we ensure that these third parties guarantee the same level of data protection as that offered to them by us and requires contractual guarantees so that the data are exclusively processed for the purposes you have previously accepted, and with the required confidentiality and security.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contact Us” section, below.
To the extent permissible by applicable law, we will retain your Personal Data for such period as necessary to satisfy or to fulfill the following:
– The purposes for which that Personal Data was provided;
– An identifiable and ongoing business need, including record keeping;
– A requirement to retain records that may be relevant to any notified regulatory investigations or active legal proceedings;
– Comply with any applicable law, regulation, legal process, including, without limitation, court orders and/or compulsory disclosures required by governmental authorities;
– Fulfill legitimate interests of Capitalise and third parties, such as, defend in cases of legal procedures, etc.
Unless specifically requested, we ask that you do not send us, or disclose, on or through the Services or otherwise, to us, any Sensitive Personal Data (e.g., social security numbers, national identification number, data related to racial or ethnic origin, political opinions, religion, ideological or other beliefs, health, biometrics or genetic characteristics, criminal background, trade union membership, or administrative or criminal proceedings and sanctions).
Use of Services by Minors
Capitalise does not knowingly collect Personal Data from any person under the age of 18.
Like many other websites, in order to enhance your experience on our web site, some of our web pages may use “cookies”. Cookies, by themselves, do not tell us your personally identifiable information unless you choose to provide this information to us (by, for example, registering for one of our services). However, once you choose to furnish the site with your personally identifiable information, this information may be linked to the data stored in the cookie.
A cookie is a small text file containing small amounts of information which is placed by a website onto a computer or device. Cookies are designed to assist a computer or device to remember something the user has done within that website, for example remembering that the user has logged in, or which buttons have been clicked.
We may use various types of Cookies:
– Session Cookies. These Cookies are stored only temporarily during a browsing session and are deleted from your device when you close the browser. We use Session Cookies to support the functionality of the site and to understand your use of the site, for example which pages you visit, how long you stay on each page, etc.
– Functional Cookies. We use Functional Cookies to save your settings on the site, we also use Functional Cookies to store data so that you can easily find it the next time you visit. Some Functional Cookies are essential to viewing maps or videos on our site.
– Persistent Cookies. These Cookies are not deleted when you close your browser but are saved on your device for a fixed period or until you delete them. Each time you visit the site, the server that set the Cookie will recognize the persistent Cookie saved on your device. We and others use persistent Cookies to store your preferences, so that they are available for your next visit, for example if you’ve already logged in, these cookies will skip the log-in when you visit our site again.
– Targeting and advertising Cookies. These cookies are used to collect information from you to help us to improve our products and services as well as serve you with targeted advertisements that we believe will be relevant to you. We use targeting cookies on our websites for various marketing initiatives and campaigns. We also may use some Analytics Cookies and Other Technologies to facilitate advertising.
– Analytics Cookies. These cookies collect information about your use of the site, and enable us to improve the way it works. These Cookies give us aggregated information that we use to monitor site performance, count page visits, spot technical errors, see how users reach the Site, and measure the effectiveness of advertising & Targeted ads
The Website uses the following third party cookies:
Capitalise uses Mixpanel, a business analytics service which tracks user interactions with web and mobile applications and provides tools for targeted communication with them.
General information about Mixpanel and privacy protection at Mixpanel can be found on the following website: https://mixpanel.com/legal/privacy-policy/
Capitalise uses Inspectlet which records videos of the website’s activity as the visitors use Capitalise’s site, allowing Capitalise to track the activity, see mouse movement, scroll, click, and keypress on the site.
General information about Inspectlet and privacy protection at Inspectlet can be found on the following website: https://www.inspectlet.com/terms-of-service#privacy
Capitalise uses Intercom in order to send targeted messages to onboard and activate users, and also to provide personalized technical\site support at scale with a collaborative inbox, automation and self-service support.
General information about Intercom and privacy protection at Intercom can be found on the following website: https://www.intercom.com/terms-and-policies#privacy
– Google Analytics
Capitalise uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). By using cookies, Google Analytics collects and stores certain data. By using a browser plugin provided by Google, you can opt out of Google Analytics.
General information about Google Analytics and privacy protection at Google can be found on the following Google website: https://support.google.com/analytics/answer/6004245?hl=en
User can prevent the collection of data generated by the cookie regarding User’s use of the website by the mentioned above as well as the processing of this data by downloading and installing the add-on available under the following link for User’s current web browser: https://tools.google.com/dlpage/gaoptout?hl=en.
If User uses different web browsers on User’s computer (e.g. Internet Explorer and Mozilla Firefox), User should download the add-on for each web browser User uses to visit this website.