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Privacy Policy

Last Updated: November 11, 2019 

This App is operated by Captis Holdings LTD,a Delaware limited liability company, (hereinafter “Captis”). This Privacy Policy governs your access to the Captis Mobile Application (the “App”). 

The term “you”, “your” or “User(s)” shall refer to any entity or person that accesses, views, uses our App, and/or starts an account with us. The terms “we,” “our”, “us” shall refer to Captis. 

Since we may gather certain types of information about our users, we feel you should fully understand our policy and the terms and conditions surrounding the capture and use of that information. This Privacy Policy discloses what information we gather and how we use it. The private information you provide on the App will be used only for its intended purpose. 


INFORMATION WE COLLECT We will collect information, including both Personal Informationand Non-Personal Information, when you interact with us and the App, for example when you: 

PERSONAL INFORMATION Personal Information” means information about you that specifically identifies you or, when combined with other information we have, can be used to identify you. As a general rule, we do not collect Personal Information about you when you visit and/or use the App, unless you choose to provide such information to us. Submitting Personal Information through the App is voluntary. By doing so, you are giving us your permission to use the information for the stated purpose. 


We collect, process and use your information for the purposes described in this Privacy Policy, based at least on one of the following legal grounds: 


Through the App, we may collect information that can identify you when you voluntarily submit it to us. Your Personal Information may include: 


We will take reasonable precautions, as well as physical, technical, and organizational measures in accordance with industry standards, as described herein, to protect your Personal Information from loss, misuse, unauthorized access, disclosure, alteration, or destruction. 

Computer safeguards, such as firewalls and data encryption may be used to protect your information. We authorize access to your information only for those employees or agents who require it to fulfill their job responsibilities and these individuals are required to treat this information as confidential. 

However, the security of information on or transmitted via the Internet cannot be guaranteed. Unauthorized entry of use, hardware or software failures, and other factors may compromise the security of your Personal Information. All information you send to us electronically or through email is not secure. Any transmission is at your own risk as the transmission of 

information via the Internet is not completely secure. Users are solely responsible for protecting their passwords, limiting access to their computers, and signing out of the Account after their sessions. Your information will be retained for as long as your Account is active or is needed to provide you with the App, having regard to the purposes described in the Privacy Policy and the legal and regulatory requirements. 

NON-PERSONAL INFORMATION We collect and temporarily store certain information about your usage of the App. Non-Personal Information means information that alone cannot identify you, including data such as cookies, pixel tags, web beacons and device information. The information includes, without limitation: 

If you do not want us to collect this information, you may either change your device’s privacy settings or DO NOT ACCESS OR USE THE APP. 

INFORMATION COLLECTION TECHNOLOGIES The technologies we use for automatic information collection may include: 

CHANGING YOUR DATA COLLECTION SETTINGS We strive to provide you with choices regarding the Personal Information you provide to us. You may need to adjust the settings on your computer and/or device to restrict the collection of information by the App, but this may prevent you from accessing all of the features of the App. 

In addition, if you wish not to receive ads from us based on information we obtain from use of cookies and pixel tags, please send us an e-mail and we will respond within a reasonable timeframe and in accordance with applicable laws. 

THIRD-PARTY AUTOMATIC INFORMATION COLLECTION When you use the App or its contents, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include: 

These third parties may use tracking technologies to collect information about you when you use the App. The information they collect may be associated with your Personal Information or they may collect information about your online activities over time and across different websites, mobile applications and other online sites. They may use this information to provide you with interest- based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. 

HOW WE USE YOUR INFORMATION We use information collected as described in this Privacy Policy for the following: (1)Operation 

(2) Usage and Analytics 

(3) Location: We will use location data for the following reasons: 

HOW WE DISCLOSE YOUR PERSONAL INFORMATION The Personal Information you provide to us whether voluntarily or automatically, may be used and disclosed without limitations, in the following instances: 

HOW WE DISCLOSE YOUR NON-PERSONAL INFORMATION We may also disclose Non-Personal Information: 

HOW TO ACCESS, UPDATE, WITHDRAW CONSENT OR DELETE YOUR INFORMATIONIf the law applicable to you grants you such rights, you may ask to access, correct, or delete your Personal Information that is stored in our systems or that we otherwise control. You may also ask for our confirmation as to whether or not we process your Personal Information or ask to withdraw any consent you have previously provided to Captis in connection with our use and processing of your Personal Information. Subject to the limitations in law, you may request that we update, correct, or delete inaccurate or outdated information. You may also request that we suspend the use of any Personal Information the accuracy of which you contest while we verify the status of that data. 

If you wish to exercise any of these rights or withdraw your consent, please contact us at: handling these requests, we may ask for additional information to confirm your identity and your request. Please note, upon request to delete your Personal Information, we may retain such data in whole or in part to comply with any applicable rule or regulation and/or response or defend against legal proceedings versus us or our affiliates, or as we are otherwise permitted under such law applicable to you. While we strive to honor all reasonable requests, please be aware that we backup the data to prevent accidental or malicious destruction of your information. Information on backup servers may take some time to be completely deleted from the system. If you request that we remove you from our system and delete all your information, please note that you may still receive materials while your request is being processed. 

If you request that your information be deleted, we will keep your information for a period of time in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you request to 

delete your information, your Personal Information will not be used by us or our third- party providers for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy. 

SECURITY We take reasonable steps to protect the personal data provided to us from unauthorized access, use or disclosure. The safety and security of your information also depends on you. Unfortunately, the transmission of information via the internet and mobile services is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of Personal Information is at your own risk. We are not responsible for any third-party circumvention of any privacy settings or security measures we provide. If you suspect that there has been a breach of the security of your data you should contact us and include details of the nature of the breach, the date of the breach, and the full circumstances of the breach. 

COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS We represent and warrant that we will comply with all applicable laws, rules, regulations, directives and guidelines regarding the collection, use and disclosure of data collected from or about Users or specific devices which apply to the services utilized hereunder (collectively, the “Rules”). The term “Rules” shall include, without limitation, (i) United States Federal Trade Commission Laws regarding the collection, use and disclosure of data from or about users and/or specific devices; (ii) the Children’s Privacy Protection Act of 1998 (COPPA) and (iii) if applicable, the Rules of any other jurisdiction, including and European Union General Data Protection Regulation (“EU GDPR”), rules, regulations and/or directives promulgated by a pertinent Data Protection Act, and all amendments and updates to them or regulations as replaced or superseded from time to time. 

NOTICE CONCERNING CHILDREN We do not direct our App directly or indirectly towards children. We do not target the App towards children, nor do we knowingly collect information about children. If we learn that the information of a child under the age of thirteen (13) is stored within its system, we will promptly delete any information in that Account. If you become aware that a child under the age of 13 has provided us with Personal Information, please notify us immediately and we will terminate the Account and delete such information. 

UPDATES TO THIS POLICY We reserve the right to change, modify, update, add, or remove portions of this Privacy Policy at any time. Any changes or updates will be effective immediately upon posting to this page. When we do update it, for your convenience, we will make the updated policy available on this page. If you opt out of receiving communications, you may not receive certain notifications, however, they will still govern your use of the App, and you are responsible for proactively checking for any changes. We encourage you to check this Privacy Policy frequently to stay up to date on any changes. You can determine if changes have been made by checking the effective date on the 

Privacy Policy. Continued use of the App after the effective date of any change in this Privacy Policy will constitute acceptance of such changes and it will signify that you agree to abide by and be bound by the modified Privacy Policy. 

CONTACT US If you have questions, comments, or concerns regarding this Privacy Policy, please contact us and we will respond to your request within a reasonable timeframe. Please include the following information in your request (a) Your name; (b) Your contact information, including phone number and email address; and (c) The precise nature of your request, inquiry, or complaint. You may contact us at: 

CONTACT US We welcome your questions or comments regarding these Terms: 

Captis Holdings LTD 

By Mail: 2035 Sunset Lake Rd. Suite B-2 Newark, DE 19702 

By E-mail: