The Privacy Notice describes how we collect and use your personal information
in relation to
Capillary websites, applications, products, services, events, and experiences that reference this
Privacy Notice.
What data do we collect?
Our Company collects the following data:
Personal identification information (Name, email address, phone number, etc.) pursuant to or in
connection with service offerings and as instructed by you (the entity assuming the role of
“Controllership”)
How do we collect your data?
You (the entity assuming the role of “Controllership”) directly provide Our
Company with the data we
collect. We collect and process data that is required in connection with our service offerings on the
basis of your Company’s documented instructions.
How will we use your data?
We use personal information to provide and deliver Capillary Offerings and
process transactions
related to Capillary Offerings pursuant to or in connection with service offerings and as instructed by
the respective entity assuming the role of Controllership.
Capillary provides CRM and Loyalty Services to its customers, registering members to the customers’
loyalty programs, managing the loyalty and reward points of the members of the loyalty programs of
our customers, and digital communication with the members about points, coupons, and discounts.
Members are end consumers (Data Subjects) of our immediate customers of Capillary.
How do we store your data?
Capillary uses Amazon Web Services (AWS) Cloud Computing environment to
securely store and
process your data. Apart from the security controls of AWS, Capillary has an in-house Information
Security Management System (ISMS) certified to ISO 27001 information security standard and GDPR
compliant Privacy Management System (PMS).
Retention of personal information
We keep your personal information to enable your continued use of Capillary
Offerings, for as long as
it is required in order to fulfill the relevant purposes described in this Privacy Notice, as may be
required by law (including for tax and accounting purposes), or as otherwise communicated to you.
How long we retain specific personal information varies depending on the purpose for its use, and
we will delete your personal information in accordance with applicable law.
What are your data protection rights?
Capillary would like to make sure you (the entity assuming the role of
“Controllership”) or your end
consumers are fully aware of all of your data protection rights. You and your end consumers are
entitled to the following:
The right to access – Have the right to request Our Company for copies of your personal data. We
may charge you a small fee for this service.
The right to rectification – Have the right to request that Our Company correct any information
you
believe is inaccurate. You also have the right to request Our Company to complete the information
you believe is incomplete.
The right to erasure – Have the right to request that Our Company erase your personal data,
under
certain conditions.
The right to restrict processing – Have the right to request that Our Company restricts the
processing
of your personal data, under certain conditions.
The right to object to processing – Have the right to object to Our Company’s processing of your
personal data, under certain conditions.
The right to data portability – Have the right to request that Our Company transfer the data
that we
have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have 1 - 3 months to respond to you. If you would like to exercise any of
these rights, please contact us at our email: guardians@capillarytech.com
What are Cookies?
Cookies are small data files that are placed on your computer or mobile device
when you visit a
website. Cookies are widely used by website owners in order to make their websites work, or to work
more efficiently, as well as to provide reporting information. For more information about cookies and
how we use them, please read our Cookie Notice.
Changes to our privacy notice
Capillary keeps its privacy policy under regular review and places any updates
on this web page. This
privacy policy was last updated on 8 November 2021.
Please reach out to the Capillary Privacy team for Capillary’s Data Processing Agreement (DPA) and
Standard Contractual Clauses (SCC).
How to contact us?
If you have any questions about Our Company’s privacy policy, the data we hold
on you, or you
would like to exercise one of your data protection rights, please do not hesitate to contact us.
Email us at: guardians@capillarytech.com
