privacy policy
additional EEA privacy disclosures
Effective date: 08/07/2021
Unless otherwise expressly stated, capitalized terms in these Disclosures have the same meaning as defined in the Privacy Policy.
scope of disclosures
These Additional European Economic Area (EEA) Privacy Disclosures supplement the information contained in our Privacy Policy, and provides additional information about how we collect, use, disclose and otherwise process personal data of individuals based in the EEA.
Captions, LLC. is the data controller responsible for the collection and use of such personal data. Please refer to the Contact Us section for information on how to contact us.
When we use the term “personal data in these Disclosures, we mean any information relating to an identified or identifiable natural person.
Personal Data We Collect and Process
We collect the categories of personal data that you voluntarily submit to us when you use the services we provide pursuant to our Captions Terms andConditions including the Captions Platform (the “Services”), as set forth in our Privacy Privacy under the sections entitled Our Collection of Personal Information and Our Use of Personal Information. We will indicate to you if the provision of certain personal data is mandatory for use of the Services, or optional. If you choose not to provide any personal data marked as mandatory (which usually means that it is either necessary to provide the Services or respond to your queries), we may not be able to respond to your queries or provide the Services to you.
In addition to the personal data submitted by you, we also process personal data that we automatically collect or collect from other sources, which we may combine with personal data submitted by you.
The table below (Table1) sets out in detail the categories of personal data that are collected as mentioned above and how we use that information when you use our Services, as well as the legal basis which we rely on to process the personal data.
Category of Personal Data
How We Use the Personal Data
Legal Bases for Processing
Except for personal data which is mandatory for us to provide the Services (such as your PlatformAccount Information), you are not required to provide personal data to us.However, we do rely on your personal data to provide certain of our Services and products. If you choose not to provide us with your personal data, we may not be able to provide you with a service or product you request.
We may anonymise and/or aggregate any of the personal data we collect (so that it no longer qualifies as personal data). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, and improving the services.
Users are responsible for all user-generated content and other information they provide through the Services pursuant to article 2 of Captions Terms and Conditions and in particular with regard to the respect of the privacy and data protection rights of others.
Retention of Personal Data
We will retain personal data for as long as necessary to provide the Services and for the other purposes set out under Table 1 of theseDisclosures. We also store information when necessary to comply with contractual and legal obligations, when we have a legitimate interest to do so (such as improving and developing our Services, and enhancing the safety, security and stability of our Services).We may also store your personal data in order to defend or ascertain our legal rights, respond to valid legal requests, in the context of a merger/acquisition or in order to implement our Terms and Conditions.
In all cases, in addition to the purposes, we consider the amount, nature and sensitivity of the personal data, as well as the potential risk of harm from unauthorized use or disclosure of your personal data, in determining how long to retain personal data.
Upon withdrawal of consent or upon expiry of the retention period for the personal data collected for the purposes referred to in Table 1, whichever is the earlier, the data will be automatically deleted or permanently anonymized.
recipients of personal data
We may also share your personal data with the following third parties and/or in the following circumstances.
Third Parties to which we transfer your personal data
Concerned personal data
Profile Information
User-Generated Content
Demographic Information
Support Information
Location Information
We may also share your personal data with third parties in the following circumstances:
- In Connection with a Business Transaction or Reorganization. We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal data to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal data may also be disclosed in the event of insolvency, bankruptcy, or receivership.
- To Comply with Legal Obligations and Rights: We may disclose personal data to third parties, such as legal advisors and law enforcement:
- in connection with the establishment, exercise, or defense oflegal claims;
- to comply with laws or to respond to lawful requestsand legal process;
- to protect the rights and property of us, our agents, customers, and others, including to enforce our agreements, policies, and terms of use;
- to detect, suppress, or prevent fraud;
- to reduce credit risk and collect debts owed to us;
- to protect the health and safety of us, our customers, or any person; or
- as otherwise required by applicable law.
- With consent or direction: We may disclose personal data about an individual to certain other third parties or publicly with their consent or direction.
transferring personal data
The personal data we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations. If you are located in the EEA, your personal data may be processed outside of those regions, including in the United States.
In the event of such a transfer, we ensure that: (i) the personal data is transferred to countries recognized as offering an equivalent level of protection; or (ii) the transfer is made pursuant to appropriate safeguards, such as standard contractual clauses adopted by the European Commission (including additional safeguards as recommended by the European data Protection Board).
- Adequacy Decisions pursuant to Article 45 of the GDPR: we may transfer personal data about you to countries that the European Commission has deemed to adequately safeguard personal data.
- Standard Contractual Clauses pursuant to Article 46 of the GDPR: the European Commission has adopted Standard Contractual Clauses, which provide safeguards for personal data transferred outside of the EEA. We may use these Standard ContractualClauses when transferring personal data from a country in the EEA to a country outside the EEA that has not been deemed to adequately safeguard personal data.You can request a copy of our Standard Contractual Clauses by contacting us asset forth in the Contact Us section below.
If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of these Privacy Disclosures.
your rights in respect of your personal data
You have the following rights in relation to your personal data (subject to certain limitations at law):
(i) confirmation of whether, and where, we are processing your personal data;
(ii) information about the categories of personal data we are processing, the purposes for which we process your personal data and information as to how we determine applicable retention periods;
(iii) information about the categories of recipients with whom we may share your personal data; and
(iv) a copy of the personal data we hold about you.
Depending on where you are located, you have the right to provide instructions regarding the retention, deletion and disclosure of your personal data after your death. In the absence of instructions from you, it is possible for your heirs to request the disclosure or deletion of your personal data by sending an email to us as provided under the Contact Us section.
You also have the right to lodge a complaint to your local data protection authority. If you are based in the European Union, information about how to contact your local data protection authority is available here.
If you wish to exercise one of these rights, please fill out our Privacy Rights Requests Form.
children’s personal information
As provided under our Terms and Conditions, any use or access to the Service by anyone under 15 is strictly prohibited and in violation of this Agreement. Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal data from children under the age of 15. If you are under the age of 15, please do not use our websites or online services or otherwise provide us with any personal data either directly or by other means.
updates to these disclosures
We may update these Disclosures from time to time. When we make changes to these Disclosures, we will change the date at the beginning of these Disclosures. If we make material changes to these Disclosures, we will notify you by email to your registered email address, by prominent posting on our online Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.
contact us
If you have any questions or requests in connection with these Disclosures or other privacy-related matters, please send an email to: legal@getcaptions.app.