Privacy

Here you can read about how Capassa collects and uses personal data. 🔑

1. About Privacy statement

The Privacy Policy deals with how Capassa AS collects and uses information about you as a user of our digital services (websites, apps, social media pages, email and sms) and our regulated financial services. The statement contains information you are entitled to when data is collected from our services and information about how we process personal data.

Capassa, by CEO, is the data controller for the processing of personal data. It is voluntary for those who visit the websites to provide personal information in connection with services such as receiving newsletters, using the part and tip service, etc. The basis for this processing is the consent of the individual unless otherwise specified.

For the use of Capassa’s services on logged-in sites, including booking and managing Capassas regulated financial services, additional information will be collected. The basis for this is based on regulatory requirements, the consent of the individual, and Capassas’s need to provide our services.

2. About Treathment Manager

Capassa AS is a limited liability company registered in Norway with company registration number 913 978 617. Capassa’s address is Soelvolds vei 7 B, 0275 Oslo. Our website is www.capassa.com  and we can be contacted at info@capassa.com.

3. How we collect and use your personal data

Capassa will collect various information about you, depending on whether you are a customer or visitor to our digital services. Some of this information goes under the category of personal data and is described here.

3.1 To carry out Capassa’s operational services

In order for us to provide our services to you and thereby fulfill our share of the agreements we have with you as a customer in Capassa, we will collect the following information about you:

  • Your contact information
  • Your agreements with Capassa
  • Your purchases of services via Capassa

We will delete this information for this purpose when customer relationships are terminated and your agreements with Capassa have been terminated.

Upon completion of the funding campaign, your contact information, account numbers, social security numbers and the relevant agreements and investments may be disclosed to the funding customer in which you have invested. If a security agent has been appointed in connection with the relevant funding, this information may also be disclosed to it, so that both Capassa and the security agent can fulfil their duties and agreements.

In the event of suspected fraud or fraud, either by Capassa or our customers, we will register and retain information about this up to 10 years after the suspect was registered. This information may include the basis for the suspect and the suspect’s contact details.

3.2 To meet our regulatory requirements

Capassa AS has been by Financial Supervisory Authority of Norway accepted to operate as an agent in order to perform and be a loan intermediary. This makes us required by law to register and retain certain information about you if you are a customer with us, whether as an investor or a finance customer. The basis for the treatment is based on the Money Laundering Act and regulations.

If you are only a subscriber to our newsletter or visitors to our website or app without establishing yourself as a customer (investor/financial customer), you do not need to provide this information.

3.2.1 Private individual as a customer through personal undertaking

For private individuals registered with their personal company investors, we collect the following information:

  • Your contact information
  • Your citizenship and where you are a resident
  • Your agreements with Capassa
  • Your purpose with the customer relationship
  • Your PEP status (whether you or someone in your immediate family or circumference may be considered politically exposed persons)

We may also collect information about your PEP status from information services that use information from public records.

3.2.2 Private person as a representative of the company

For private individuals acting as a representative of companies that register as either an investor or a financial customer, we collect the following personal data:

  • Your contact information
  • Your social security number
  • Your citizenship and where you are a resident
  • Your relationship with the company you represent
  • Your PEP status (whether you or someone in your immediate family or circumference may be considered politically exposed persons)
  • Your agreements with Capassa
  • Proxy from the signature law holder, if the representative does not have the right to signature alone
  • Copy of signature law holder’s id
  • Credit rating from external credit reference companies that may include stated income, wealth, debt, tax paid and any payment notices.

We may also collect information about your PEP status from information services that use information from public records.

3.2.3 Other private individuals affiliated with companies seeking financing (real rights holders, persons with signature rights and members of the Board and management)

If you as a private individual are a real rights holder, person with a signature right or a member of the board or management of a company seeking to become a financial customer with us, we will register the following information about you:

  • Your contact information
  • Which company you are a real licensee in
  • Your citizenship and where you are a resident
  • Your PEP status (Whether you or someone in your immediate family or circumference may be considered politically exposed persons)
  • Credit rating from external credit reference companies that may include stated income, wealth, debt, tax paid and any payment notices.

We may collect this information both from the company that is our customer and from information services that use information from public records. You will not necessarily be asked or informed about our collection of your information.

3.3 Function to share Capassa’s content with others

The “Share” feature can be used to forward links to the website by email, or to share the content on social networking sites. Information about the sharing is logged with us and used to post the sharing with the community. How the network in question handles the data further is governed by your agreement with the community. If you use the email feature, we use the email addresses provided to pass the message on, and to personalize our digital services to create a more relevant experience for recipients when they access the pages that you have shared with them. These email addresses will be deleted within three months, unless they are registered as a recipient of newsletters and/or as a customer of Capassa’s services.

3.4 Comments and questions on funding campaigns

As a logged-in customer on our website, it is possible to post comments and questions on funding campaigns. These must first be approved by Capassa or the funding customer before they can be published. To show the sender of the comment, your first name and any middle name will appear along with your registered city to both Capassa and the funding customer when approval is considered, and for anyone who visits the website if the comment is published. When you post your question, you agree that this information may be recorded and published.

3.5 Comments on articles or blogger

Where it is possible for users to comment on articles or blogs, a name and email address are required. The name and email address may be published with the comment and saved by Capassa in order to be able to maintain our editorship.

3.6 Brukeranmeldelser of Capassa

We want to receive both rice and praise from our customers. In addition, we want to be transparent so that others can see our customers’ user reviews. Therefore, Capassa’s customers may, in some cases, receive a request from Capassa by email to write their user review of Capassa on external vendors for this. The relevant provider’s privacy policy will apply. By registering your feedback, you agree to the provider’s privacy policy.

3.7 Customer Service

We offer our customers individual guidance via multiple channels: Email, Facebook Messenger and chatbots on our website. In connection with enquiries between you and Capassa, we may ask you for your contact information, typical name, email address and phone number. We may also ask for other information needed to provide you with the guidance you want. We only use this information in connection with the dialogue we have with you. The information is kept throughout the life cycle of the customer relationship and any loan agreements, possibly for three years after the last contact.

In our emails to you, we may use analytics tools that measure when the email is opened and if you click on links in the email. We do this to learn and improve our communication.

3.8 Use of cookies

We want to offer our users the best possible experience in our digital services. That’s why we use cookies to improve the user experience in our digital channels. Cookies are small text files that the website stores on your computer when you visit our websites.

When you visit our website, you can choose to give your consent to setting cookies in your browser, unless you have already reserved against it. You can choose to delete already downloaded cookies at any time. You can also opt out of using cookies in most browser settings.

By using our websites and loading our cookies, you consent to our use of cookies. In the following, we describe what information we collect, the purpose of the processing and who processes the data.

3.8.1 Page and service functionality

We use cookies in the operation and presentation of data from websites. Such cookies may contain information about language code for language selected by the user. There may be cookies with information about the load balancing of the system so that all users are ensured the best possible experience.

We may also store information about what keywords our users use on our digital services. The search usage pattern is stored and processed anonymously in aggregated form to improve our information offering.

3.8.2 To improve the user experience in our digital services

As part of the work of creating an easy-to-use website, we look at the user pattern of those who visit the site. To analyze the information, we use analytics tools that collect user cookies issued by trusted third parties. These third parties are Google, Hotjar and Segment.

The analytics tools use third-party cookies that record users’ IP address and provide information about the individual user’s interactions with our digital services. Examples of what the information gives us answers to are; how many people visit different pages, how long the visit lasts, the time of the visit, whether users visit the websites repeatedly, the user’s geographical location (down to the county level), which websites the users come from and which browsers are used. For this purpose, we use Google Analytics, Hotjar and Segment.

With Google Analytics, we use this information to analyze your and others’ online behavior. An IP address is defined as a personal data because it can be traced back to a specific hardware and thus to an individual. Capassa uses Google Analytics’ tracking code that anonymizes the IP address before the information is stored and processed by Google. Thus, the IP address stored at Google cannot be used to identify the individual user. For more information about Google Analytics’ use of cookies, visit the Official Google Analytics page.

In addition to Google Analytics, we use Hotjar and Segment. Hotjar records user sessions to create heat maps of usage patterns. Your gestures with mouse pointers and clicks are recorded so that we can analyze how our websites are used. Everything that is stored is anonymous. Segment helps Capassa gather information about you as a customer or website user.

Capassa also uses conversion pixels from Xandr and Schibsted, among others, for the purpose of collecting behavioral data on their own pages, related to users’ defined activity. These activities can be purchases, orders, registrations, or other click-based activities that can be measured to be a conversion in terms of marketing. The conversion data is anonymized and is not used for the processing of personal data; they are only used for learning to define the effect of the different market activities, and to optimise them.

Issuer of the cookie and link to their privacy policy:

Google Analytics â€“ Personvernerklæring

Hotjar â€“ Personvernerklæring

Segment â€“ Personvernerklæring

Xandr – Personvernerklæring

Schibsted –  Privacy Policy

3.8.3 Relevant marketing in ad networks

We use cookies issued by trusted third parties to provide you with relevant marketing.

In order to provide you as a recipient of newsletters targeted information, we use Intercom cookies to become better acquainted with how you use our digital services: Your county-level geographic location, which parts of our websites or app you have visited, when you visited them, what buttons you pressed and which funding campaigns you have invested in. Capassa uses this information both to analyze the effectiveness of each newsletter and to adapt the message to each user so that you as a recipient experience our marketing as relevant to you as possible. In the next chapter, we describe our newsletters and targeted marketing.

We also do marketing in ad networks, such as through Google, Facebook and LinkedIn, to show our ad campaigns on relevant websites. To do this, we use cookies or pixel issued thereby so that they can show our ads in their services to specific audiences, such as people who have visited Capassa.no. The information these cookies collect about you can be what kind of device you use (tablet, type of smartphone, type of laptop etc.) and browser. For offline marketing, we use the following providers and their cookies on our websites:

AdAction Interactive â€“ Personvernerklæring

Adform –  Personvernerklæring

Google AdWords –  Personvernerkl’ring

Delta Projects â€“ Personvernerklæring

DoubleClick â€“ Personvernerklæring

Fyber â€“ Personvernerklæring

AOL Advertising â€“ Personvernerklæring

AppNexus â€“ Personvernerklæring

OpenX â€“ Personvernerklæring

Pubmatic â€“ Personvernerklæring

Smaato â€“ Personvernerklæring

Rubicon Project â€“ Personvernerklæring

WideOrbit â€“ Personvernerklæring

Unruly â€“ Personvernerklæring

Facebook Connect â€“ Personvernerklæring

Linkedin –  Personvernerklæring

3.9 Newsletters and targeted marketing

It is possible to subscribe to newsletters and targeted marketing from Capassa for anyone who wants to receive such information. If you choose this, you give your consent to us using your email address to send you marketing. In order for us to send email to the right person, we need to register your name and email address. Intercom is the data processor of the newsletter on behalf of Capassa by handling the recipients’ email addresses and distributing newsletters to them. Intercom also registers whether you as a registered recipient have opened the email, when you did this, whether you have printed the email links and whether you have used the email’s newsletter deregistration feature. All this information is deleted when we are notified that you no longer wish to receive information from us. The information is also deleted if we receive feedback that the email address is no longer active.

If you both subscribe to our newsletters and have accepted our use of cookies, we will also collect information about how you use our digital services using Intercom, as described in the previous cookie chapter. Capassa uses this information both to analyze the effectiveness of each newsletter and to adapt the message to each user, so that you as a recipient experience our marketing as relevant to you as possible.

We do not record your investment amounts for marketing purposes.

3.10 Sensitive Personal Data

Capassa does not collect any sensitive personal information about you, either from you or from third parties. We ask that you as a user or customer of Capassa’s services do not provide any kind of sensitive personal information in your communication with Capassa.

4. Changes to your personal data

If you discover or suspect that we have incorrect or inadequate personal data about you, you are entitled to access, erasure and rectified thereof, to the extent that it does not conflict with our legal requirements. This also applies if the correct information has changed after we registered it. You may report to Capassa on info@capassa.comand we will change your information.

5. How we share personal data with others

We do not sell, rent or share your personal data with others, beyond what we believe is necessary to provide our services and described in this Privacy Policy. In cases where we disclose personal data with others, we will enter into an agreement with them that defines, among other things, what information it should be about and how it should be processed.

Capassa will disclose information in cases required by law.

6. Your rights

As a user of Capassa’s digital services, you are entitled to:

  • access your registered information at Capassa,
  • correct your registered information at Capassa,
  • transfer your registered information at Capassa,
  • delete your registered information at Capassa,
  • gain insight into how we process your information and set restrictions on this,
  • withdraw your consents,

as long as this does not conflict with the regulatory obligations imposed by Capassa. If you wish to exercise these rights, please contact us via info@capassa.com.

7. Security

Capassa will at all times take advantage of best practices to secure your personal data. This data will only be stored in the systems that need it, given the approvals you have given about the use of data. This will mainly be Capassa’s core system, which is operated on Amazon Web Service’s solution in Ireland. Amazon is one of the most professional suppliers of safe operation and is used by large parts of both Norwegian and international companies. We closely follow up their recommendations for the secure processing of personal data, including encryption, password protection, firewall, etc. for all platforms where we handle personal data.

8. Use of suppliers

Capassa only uses suppliers that we trust. All suppliers who process personal data on behalf of Capassa are considered data processors and we have therefore entered into a data processing agreement (DPA/Data Protection Addendum) with these. For the suppliers who process this personal data outside the EU/EEA, we have also entered into agreements with them that ensure that the personal data is handled in accordance with EU regulations on this matter.

9. Changes to the Privacy Policy

To keep our Privacy Policy in force, we will update or make changes. There is always the latest version that will be on the Capassa.no and with major updates, we will go out with information about this.

10. Contact information

If you would like to contact Capassa please contact us via privacy@capassa.com. Here you will also get in touch with Capassa’s Data Protection Officer (DPO) Aage Thorsen

11. Your right to complain to authorities

You have the right to complain to the supervisory authority Data Protection Authority. Their website is www.datatilsynet.no  and they can be contacted at the following address:

  • The Norwegian Data Protection Authority
  • P.O. Box 458 Sentrum
  • 0105 Oslo

You can read more about how to complain to the Norwegian Data Protection Authority here: https://www.datatilsynet.no/om-datatilsynet/kontakt-oss/hvordan-kan-jeg-klage-til-datatilsynet/