We use necessary cookies to make our website work. We, and our partners, would also like to set analytics cookies that help us make improvements by measuring how you use the site . To learn more, visit our Privacy Policy. Necessary cookies & analytics cookies Necessary cookies enable core functionality such as security, network management, and accessibility. You may disable these by changing your browser settings, but this may affect how the Website functions. Our analytics cookies to help us understand how our website is performing and being used. Specifically, we use Google Analytics to collect information about how users use our website, which we then use to compile reports that disclose trends without identifying individual visitors, and help us improve our website.

Privacy Policy

Policy last updated October 2023

Capital D Privacy Policy

PLEASE READ THIS PRIVACY POLICY AS IT APPLIES TO ANY INFORMATION WHICH DIRECTLY OR INDIRECTLY IDENTIFIES YOU (REFERRED TO AS “PERSONAL DATA”) WHICH YOU PROVIDE US OR WE COLLECT ABOUT YOU, THROUGH THE WEBSITE AT WWW.CAPITALD.COM OR ANY OTHER WEBSITE OWNED, OPERATED OR PROVIDED BY CAPITAL D MANAGEMENT LLP, AND/OR ANY OF ITS ASSOCIATED UNDERTAKINGS (REFERRED TO EITHER AS “CAPITAL D,” “WE” OR “US”) (THE “WEBSITE”).

1.     Information Collection

Information you provide to us

You may provide us with Personal Data in connection with our Website. For example, you may provide us with information during meetings or telephone calls with us, or via electronic communications with us, such as email or via the Contact Us page on our Website. If you do so, you may provide us with your contact information and professional details, including your name, email address, mailing address, phone number, business role, job title and company name, and the content of your messages, including testimonials.

When you provide us with Personal Data about yourself or another person, you are confirming to us that you are authorised to provide us with that information and that any Personal Data you give us is accurate and up-to-date. Given the nature of our business, we do not generally ask for “sensitive” or “special categories of personal data,” such as information about your health, political opinions, racial origins or sexual life and we ask you not to send any to us unless specifically requested to do so.

Information we obtain from third parties

We may obtain your Personal Data from third parties. For example, your colleagues at the business you represent may give us Personal Data about you.

Information which is automatically collected

We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with the Website, such as:

  • Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disc size, CPU usage, device type (e.g. phone, tablet), IP address, language settings, mobile device carrier, and radio/network information (e.g. WiFi, LTE, 3G).
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Website, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our marketing emails or clicked links within them.

We collect this information using cookies and other similar technologies. For more information, please visit our Cookies section below.

 

2.     Information Use

We use your Personal Data for one or more of the following purposes:

 

  • To provide you with support, and to respond to your questions, requests, and complaints. If you reach out to us for support, to request a demo, or to ask us a question, it is in our legitimate business interests to use Personal Data to respond and resolve your queries, and to facilitate support.

 

  • Providing, improving, monitoring, personalising, and protecting our Website. It is in our legitimate business interests to improve and keep our Website safe for our users, which includes:
  • understanding your needs and interests, and personalising your experience with the Website and our communications;
  • troubleshooting, testing and research, and keeping the Website secure; and
  • investigating and protecting against fraudulent, harmful, unauthorised, or illegal activity.

 

  • We may collect and use Personal Data about you for marketing purposes, including for direct marketing as permitted by law. You can opt out of such communications by following the unsubscribe mechanism on any communication, or by otherwise emailing us at [email protected]. Except where consent is required, we undertake such marketing on the basis of our legitimate business interests. Where we seek your consent, you may withdraw your consent at any time.

 

  • Compliance and protection. We may use Personal Data to comply with legal obligations, and it is in our legitimate business interests to use your Personal Data to defend ourselves against legal claims or disputes, including to:
  • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
  • audit our internal processes for compliance with legal and contractual requirements and internal policies;
  • enforce the terms and conditions that govern the Website;
  • prevent, identify, investigate and deter fraudulent, harmful, unauthorised, unethical or illegal activity, including cyberattacks and identity theft; and
  • comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

 

3.     Information Sharing

We will only share your Personal Data with third parties in the ways set out in this privacy policy. We do not give, sell, or rent your Personal Data to third parties for them to market their services to you. Nor do we accept advertising from third parties on the Website.

We may provide your Personal Data to our service providers to help us with our business activities, such as inputting your contact information into our CRM or email marketing system. In all cases we will have a processor agreement with these companies safeguarding your Personal Data, including that it may only be processed for the purposes of that agreement and on our instructions. We may also disclose your Personal Data as follows:

  • We may disclose Personal Data or the operation of our business, to other entities in the Capital D group.
  • For provision of the Website, and for our own disaster recovery and business continuity purposes, we may share Personal Data with third party providers, such as with our contractors and advisors (including lawyers, bankers and insurers), IT service providers, data hosting providers, to help us operate, secure, and analyse our business.
  • We may be obliged to disclose your Personal Data to comply with a law, order, or request of a court, government authority, other competent legal or regulatory authority, or any applicable code of practice or guideline.
  • We may also be obliged to disclose Personal Data when we believe in good faith that disclosure is necessary for our legitimate interest such as investigating fraud, to make or defend a legal claim, to protect your safety or the safety of others, or to maintain our compliance or that of our personnel with applicable laws, regulations and/or professional obligations, all in accordance with applicable law.
  • If Capital D is involved in a merger, acquisition, or sale of all or a portion of its assets, we may disclose such Personal Data as is necessary for our legitimate interests in completing that transaction and always provided that appropriate safeguards are in place including limitations and restrictions on use, access, and retention.

4.     International Data Transfers

We may transfer your Personal Data to Capital D entities or service providers outside the EEA or the UK for the purposes set out in this privacy policy. Please note that such jurisdictions may not provide the same protections as the data protection laws in your home country.

When we engage in international data transfers, we will ensure that relevant safeguards are in place to afford adequate protection for Personal Data and we will comply with applicable data protection laws, in particular by relying on an EU Commission or UK government adequacy decision/regulation for transfers outside of the EEA and the UK, or on contractual protections for the transfer of Personal Data. For more information about how we transfer Personal Data internationally, please contact us as set out in the Contact Us section below.

5.     Your Rights

Opt out of marketing communications. We may send you marketing information about Capital D and its activities by post or by email. You may choose to stop receiving such correspondence by contacting us at [email protected] or by following the unsubscribe language in such communications.

Personal Data requests. We offer you choices that affect how we handle the Personal Data that we control. You may request the following in relation to Personal Data:

  • Access to a copy of the Personal Data that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, and readily usable format.
  • Correction of Personal Data that is inaccurate or out of date.
  • Deletion of Personal Data that we no longer need to provide the Website or for other lawful purposes.
  • Withdrawal of consent, where we have collected and processed your Personal Data with your consent. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
  • Additional rights, such as the rights to object to and request that we restrict our use of Personal Data.

To make a request, please email us or write to us as provided in the Contact Us section below. We may ask for specific information from you to help us confirm your identity.

 

 

6.     Cookies

We use cookie and similar technologies on our Website. Cookies are text files that we store and access on your device to uniquely identify your browser or to store information or settings in the browser to allow us distinguish you from other users of our Website for the purpose of helping us understand activity and patterns.

We use the following categories of cookies:

Essential cookies. Necessary cookies enable core functionality such as security, network management, and accessibility. You may disable these by changing your browser settings, but this may affect how the Website functions.

Analytics cookies. We use these cookies to help us understand how our Website is performing and being used. Specifically, we use Google Analytics to collect information about how users use our Website, which we then use to compile reports that disclose trends without identifying individual visitors, and help us improve our services. For more information on Google Analytics, click here. For more information about Google’s privacy practices, click here. You can opt out of by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.

You will be presented with a cookie banner or other tool to provide permissions prior to non-Essential cookies being set. In this case, we only set these non-Essential cookies with your consent.

You can also limit cookies by blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org. Use the following links to learn more about how to control cookies and online tracking through your browser: Firefox; Chrome; Microsoft Edge; Safari (Mac); Safari (Mobile/iOS).

Note that if you disable or remove tracking technologies, some parts of the Website may not function correctly.

 

7.     Security

We take care to protect the Personal Data submitted to us, both during transmission and once we receive it, by using reasonable organisational, technical, and administrative measures designed to protect against unauthorised access, misuse, loss, disclosure, alteration, and destruction of Personal Data. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about the security of your Personal Data, you can contact [email protected].

8.     Retention

We retain Personal Data only for as long as is necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention policies, in accordance with applicable laws and regulatory obligations, or until you withdraw your consent (where applicable). Note that we may retain some Personal Data about you even when we know that you have left the organisation that you represent, so that we can maintain a continuous relationship with you if and when we are in contact with you again, representing a different organisation.

If you opt-out of communications, we will retain your name and contact details to enable us to respect your request.

9.     Other sites and services

Our Website may include links to other websites whose privacy practices may differ from those of Capital D. If you submit Personal Data to any of those sites, your Personal Data is governed by their privacy policies. We encourage you to carefully read the privacy policy of any such third-party website you visit.

10.  Children’s privacy

Our Website is not directed at children, and we do not knowingly collect Personal Data from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us as set out in the “Contact us” section below.

11.  Contact Us

You can contact us by email at [email protected] or by mail at 1A Heienhaff, Senningerberg, L-1736, Luxembourg  You have the right, at all times, to notify a complaint to the competent regulator, such as the UK Information Commissioner, although we would welcome the opportunity to discuss and resolve any complaint with you first.

12.  Changes to this privacy policy

Any changes we make to this privacy statement in the future will be posted to this website (at www.capitald.com) and will also be available if you contact us. Please check back frequently to see any changes.