Privacy Notice

VIDADO Privacy Notice

Effective: January 1, 2020

We at Captricity, Inc. dba Vidado (“Vidado”) respect your privacy concerns and value your trust in protecting your information.  This Privacy Notice is meant to help you understand what kind of information we collect, how we use it, and your rights concerning the data we have collected.

SCOPE

This Privacy Notice applies to the processing of personal data or personal information associated with the following activities:

  • Using our products and services (the “Services”)
  • Visiting our website where this Privacy Notice is posted
  • Signing up for an account
  • Contacting us
  • Signing up to receive communications from us
  • Participating in a promotion or survey

Our products and services allow users to convert business documents and other materials into digital data that is organized and stored within our software platform (the “Services”).  Information is provided to the Services by individuals or entities that have signed up for our Services (the “Customers”). We process data provided by our Customers in accordance in accordance with our Customers’ instructions (“Customer Data”).

Your information may be provided to us as a part of the Customer Data. We do not categorize personal data submitted to our Services for processing by our Customers. The nature of our Services prevents us from being able to identify specific personal data processed by our Services, and conclusively attribute it to a specific individual without assistance from our Customers.

You may also provide us with your information directly (“Authorized User Data”) when you use our Services as a user authorized by the Customer to access and use our Services under the Customer’s agreement with us (the “Authorized Users”).

If you reside in the European Economic Area, the United Kingdom, or Switzerland (collectively, “EEA Residents”), you have additional rights with respect to your personal data, which include rights under the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

If you reside in California, USA, you have additional rights with respect to your personal information as granted by the California Consumer Privacy Act of 2018, as amended from time to time, (“CCPA”).

We are the data processor or the service provider, as defined under the GDPR and CCPA, processing personal data/person information on behalf of and in accordance with the instructions provided by our Customers who are the controller or the business of your personal data/personal information. In some limited instances, we are the controller or the business, as defined under GDPR or CCPA. This Privacy Notice does not apply to the extent we process personal data/personal information in the role of a processor or service provider on behalf of our Customers. This Privacy Notice only applies to the personal data/personal information that we process in the role of a controller or business, as defined in the GDPR and CCPA, respectively.

TYPES OF PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT PERSONAL INFORMATION

Personal information or personal data is data that identifies an individual or relates to an identifiable individual or a household. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties, such as Customers.

We may have collected the following categories of data personal data from you:

Category
A. Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). YES
C. Protected classification characteristics under California or federal law. YES
D. Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES
E. Biometric information. YES
F. Internet or other similar network activity, including, but not limited to, browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES
G. Geolocation data. YES
H. Audio, electronic, visual, thermal, olfactory, or similar information YES
I. Professional or employment-related information. YES
J. Education information, defined as information that is not publically available personally identifiable information as defined in the Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). NO
K. Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. YES

Specifically, we collect the following information from you:

Personal information that you provide to us

We collect personal information that you provide to us directly, such as:

  • Personal Identification Information: We may collect your real name, alias, postal address, online identifier (social media handles), Internet Protocol address, email address, account name, or phone number if you establish an account to access our Services. If you are an employee of Vidado, a job applicant, or a contractor, we may already have or require you to provide us, as applicable, with information related to your education and employment history, and other personal identification information.
  • Government Issued Identification: If you are applying for a job, under the applicable laws, we may be required to collect copies of your government-issued identification.
  • Correspondence: If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses, unless it is a request for deletion, in which case we will delete all your personal information in your request after completion of the same.

Personal information that we collect automatically when you use our Services

Similar to applications on other commercial website, our application utilizes a standard technology called “cookies” (see explanation below, “What Are Cookies?”), IP addresses and web server logs to collect information about how our Services are used. Information gathered through cookies and web server logs may include the date and time of visits, the pages viewed, time spent at our website, and the websites visited just before and just after our website.

Personal information given to us from our partners, or our Customers

In providing our Services, as a processor, to our Customer, we may be given personal information about individuals (the “Other Data”) and Authorized User Data for processing. If you believe that a Customer may have given us your information, please contact that Customer.

WHAT ARE COOKIES?

A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites.

How Do We Use Information We Collect From Cookies?

Our cookies are used to differentiate you from other users in order to ensure that you receive personalized recommendations. In some cases, we also use cookies to prevent you from having to enter the same information repeatedly. Cookies, in conjunction with our web server’s log files, allow us to calculate the aggregate number of people visiting our website and which parts of the site are most popular. This helps us gather feedback in order to constantly improve our Service. Cookies also allow us to anonymize and aggregate data for statistics and to measure key performance indicators. Cookies do not allow us to gather any personal information about you and we do not generally store any personal information that you provided to us in your cookies.

Can You Opt-Out Of Cookies?

You may only opt-out of the cookies if you disable cookies in your browser and clear your browser history each time you visit the website. Please follow your browser’s documentation for instructions on how to disable cookies.

HOW YOUR PERSONAL INFORMATION IS USED

Our primary purpose in collecting personal information is to provide our Customers and their Authorized Users with a secure, efficient, and customized experience. We generally use personal information to create, develop, operate, deliver, and improve our services.

We may use the information collected by us or given to us in the following ways:

  1. To process the transaction. We use personal information for processing the transaction.
  2. To provide Customer service. We process personal information when we are contacted to resolve any questions, disputes, collect fees, or to troubleshoot problems. Without processing personal information for such purposes, we cannot respond to requests about our Services.
  3. To ensure quality control. We process personal information for quality control and for staff training to make sure that we continue to the service.
  4. To provide communication. We may send administrative or account-related information to Authorized Users, on behalf of the Customer, to keep you updated about the transaction and our Services, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account and the applicable transactions. You may not opt-out of receiving critical service communications, such as emails sent for legal or security purposes.
  5. To engage in marketing activities. Based on your communication preferences, we may send you marketing communications (e.g. emails) to inform you about our events or our partner events; to deliver targeted marketing; and to provide you with promotional offers. Our marketing will be conducted in accordance with your advertising marketing preferences and as permitted by applicable law.
  6. For research and development purposes. We process your personal information to better understand the way you use and interact with our services. In addition, we use such information to customize, measure, and improve our products and services. Without such processing, we cannot ensure your continued enjoyment of our products and services.
  7. To facilitate corporate acquisitions, mergers, or transactions. We may process any information regarding your account and use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions. You may contact us at privacy@captricity.com , if you do not want us to use your information for this purpose.
  8. For recruitment and/or engaging third-party contractors. We process your personal information when you apply for a job, become an employee of Vidado, or become our third-party contractor.
  9. For any purpose that you have consented to. We may disclose your personal information for any purpose you consent to.

Sharing Information With Third Parties

We may share your personal information may be processed with or stored on the following third-party service providers.

  • Cloud storage
  • Customer support
  • Authorized User support
  • Data analytics
  • Document repository services
  • Internet (e.g. ISPs)
  • Marketing
  • Network infrastructure
  • Security
  • Business Development
  • Product Development

We may also share your personal information in the following circumstances:

  • With companies or other entities that we plan to merge with or be acquired by. You will receive prior notice of any change in applicable policies.
  • With companies or other entities that purchase Vidado’s assets pursuant to a court-approved sale or where we are required to share your information pursuant to insolvency law in any applicable jurisdiction.
  • With our professional advisors who provide banking, legal, compliance, insurance, accounting, or other consulting services in order to complete third party financial, technical, compliance and legal audits of our operations or otherwise comply with our legal obligations.
  • With law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of any other applicable policies.

ANONYMIZED AND AGGREGATED DATA

Anonymization is a data processing technique that removes or modifies personal information so that it cannot be associated with a specific individual. Except for this section, none of the other provisions of this Privacy Notice applies to anonymized or aggregated Customer or Authorized User Data.

We may use anonymized or aggregate Customer Data, Authorized User Data and Other Data for any business purpose, such as to better understand needs and behaviors of our Customers, improve our Services, conduct business intelligence and marketing, and detect security threats. We may perform our own analytics on anonymized data or enable analytics provided by third-parties.

Legal Basis For Processing Information

We rely on contract and legitimate interest for providing our Services.

We are based in the United States (the “U.S.”) and the information we collect is governed by U.S. law. If you are an EEA Resident, please see the section on GDPR below. By accessing or using our websites or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries.

PROTECTING YOUR INFORMATION

Security

We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Certain Disclosures

We may disclose your personal information if required to do so by law or subpoena or if we believe that such action is necessary to (a) conform to the law or comply with legal process served on us or Affiliated Parties; (b) protect and defend our rights and property, the Site, the users of the Site, and/or our Affiliated Parties; (c) act under circumstances to protect the safety of users of the Site, us, or third parties.

What About Other Websites or Services Through Which Our Services Are Available?

We are not responsible for the practices employed by any other entities that may/may not link or provide access to our Services.

Please remember that this Privacy Notice is applicable only with respect to our Services. Your browsing and interaction on any other feature on a website that also offers our Services, including websites which have a link to our Services, is subject to that website’s own rules and policies. Please read over those rules and policies before proceeding.

CHILDREN

We do not knowingly collect any personal information from children under the age of 13. We do not sell products for purchase by children and all children’s products we sell are for purchase by adults only.

European Economic Area (“EEA”) ResidentS’ DATA SUBJECT RIGHTS

If you are an EEA Resident, you have certain rights with respect to your personal data, as defined under GDPR. Please note that in some circumstances, we may not be able to fully comply with your requests, or we may ask you to provide us with additional information in connection with your request, which may be personal data, for example, if we need to verify your identity or the nature of your request. In such situations, however, we will still respond to let you know of our decision.

If we are the processor, under GDPR, you will have to contact the Customer who provided us with your information, to exercise your data subject rights under GDPR.

To make any of the following requests, contact us using the contact details referred to in the “Contacting Us” section of this notice.

  • Access:You can request more information about the personal data we hold about you. You can also request a copy of the personal data.
  • Rectification:If you believe that any personal data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging into your service account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
  • Objection:You can contact us to let us know that you object to the collection or use of your personal data for certain purposes.
  • Erasure:You can request that we erase some or all of your personal data from our systems.
  • Restriction of Processing:You can ask us to restrict further processing of your personal data.
  • Portability:You have the right to ask for a copy of your personal data in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
  • Withdrawal of Consent:If we are processing your personal data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, it may limit your ability to use some/ all of our Services and you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your personal data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
  • Right to File Complaint:You have the right to lodge a complaint about our practices with respect to your personal data with the supervisory authority of your country or EU Member State.

Pursuant to GDPR you have the right to file a complaint with your Data Privacy Authority (DPA), or if you are in the UK, with the Information Commissioner’s Office.

Individuals wishing to find out more about the Data Protection Officer’s and locate the appropriate office, please go to https://ec.europa.eu/commission/priorities/justice-and-fundamental-rights/data-protection/2018-reform-eu-data-protection-rules/eu-data-protection-rules_en.

UK individuals wishing to find out more about the Information Commissioner’s Office may go to https://ico.org.uk/.

  • Transferring personal data from the EU to the U.S.

Vidado is headquartered in the United States. Information we collect from you will be processed in the U.S. The U.S. has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. Vidado relies on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, Vidado collects and transfers to the U.S. personal data only: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of Vidado in a manner that does not outweigh your rights and freedoms. Vidado endeavors to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with Vidado and the practices described in this Privacy Notice. Vidado also enters into data processing agreements and model clauses with its vendors whenever feasible and appropriate.

CALIFORNIA Residents’ rights and choices

The CCPA provides California residents, except for the employees, contractors, and job applicants of the business who are California residents, with specific rights regarding their personal information. This section describes the rights of California residents and explains how to exercise those rights. In this section, “you” refers only to California residents, as described above. Under the CCPA, businesses are required to give California employees, contractors, and job applicants a notice about the categories of data collected and its purpose, which we have provided in the following sections above – TYPES OF PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT PERSONAL INFORMATION, and HOW YOUR PERSONAL INFORMATION IS USED.

Please note that WE DO NOT SELL OR RENT YOUR DATA TO ANY THIRD-PARTY. If this ever changes, we will properly inform you in accordance with this Privacy Notice and the CCPA.

  • Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm that you are verifiable consumer, we will disclose to you the following:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

We do not provide these access and data portability rights for business-to-business (“B2B”) personal information.

  • Deletion request

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (“VCR”), we will delete your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with Customer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We do not provide these deletion rights for B2B personal information.

  • Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a VCR to us by either:

Emailing us at privacy@captricity.com

All requests must contain your full and complete legal name and any alias or other names or nicknames that you use; your contact information, including mailing address, email and phone number; and the description of your request.

Only you, or someone legally authorized to act on your behalf, may make a VCR related to your personal information. You may also make a VCR on behalf of your minor child.

You may designate an authorized agent to make a request to access or a request to delete on your behalf. A response will be furnished to your authorized agent’s request if they submit proof that they are registered with the California Secretary of State to be able to act on your behalf, or submit evidence you have provided them with power of attorney pursuant to California Probate Code section 4000 to 4465. Authorized agents may not be provided with the response pertaining to the request if the authorized agents fail to submit a proof of authorization or are unable to verify their identity.

You may only make a VCR for access or data portability twice within a 12-month period.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a VCR does not require you to create an account with us.

We will only use personal information provided in a VCR to verify the requestor’s identity or authority to make the request.

  • Response Timing and Format

We endeavor to respond to a VCR within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the VCR’s request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your VCR.

  • Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
  • However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

OTHER CALIFORNIA RESIDENTS RIGHTS

Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of such data, the names and addresses of those businesses with which we shared for the immediately prior calendar year. To request a notice, please email your request to privacy@captricity.com . Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response. Please also note that we do not share your personal information with any other business for that business’s marketing use.

HOW TO CONTACT US

Email:  privacy@captricity.com

Postal Mail:

Attention:  Privacy
Captricity, Inc. dba Vidado
130 Webster St, 2nd Floor
Oakland, California 94607

CHANGES TO OUR PRIVACY NOTICE

From time to time it may become necessary to update or change our Privacy Notice and we encourage you to periodically check here for the most current version.  If significant changes are made, we will provide you with appropriate notice, which may include conspicuous notice on our website, or email notification.

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