Terms of Use and Privacy Policy
1. Who are we, a field of our activity and legitimate interests?
1.1 Limited company “Captains of Promotion” (hereinafter also referred to as the Company, Captains Promotion, we) – the Company that was created, registered, and carries out its activities by the national legislation of England, company number in England: 13409571, location: England, London, 63-66 HATTON GARDEN, contacts: admin@captainspromotion.com.
1.2 The company manages the website https://captains-promotion.com/, which is the digital marketing agency that presents clients with deeply researched creative solutions and offers a full circle of marketing services to customers - market analysis, consumer research, branding, advertising, website, mobile app.
2. What is regulated by this Privacy policy?
2.1 Captains Promotion values the privacy, personal life, and data protection rights of everyone who visits our website and uses the services provided. We are committed to respecting and safeguarding personal data in accordance with the applicable legal requirements, ensuring that your experience on our platform remains as secure and comfortable as possible.
2.2 To achieve this, we have established rules and procedures outlined in this Privacy Policy. Here, you will find information on the purposes, legal grounds, and conditions under which the Company may process your personal data. Additionally, we explain how your data is protected, who it may be shared with, your rights as a data subject, and other important details regarding data processing.
3. Terms used in this Privacy Policy
3.1 Personal Data Subject – an individual whose personal data is being processed.
3.2 Personal Data – any information or collection of information that relates to an individual who is either identified or can be identified based on that information.
3.3 Personal Data Controller – Limited Liability Company "Captains of Promotion," responsible for determining the purpose of processing personal data, defining its scope, and setting the procedures for its processing.
3.4 Website – a collection of graphic and informational materials, ECM (electronic computing machine) programs, and databases made accessible on the Internet at the following address: https://captains-promotion.com/.
3.5 User – any visitor to the Website accessing it from any device.
3.6 Consumer – a client interested in purchasing or obtaining products (goods, services) from advertisers as a result of interactions facilitated by affiliates using the Website’s services.
3.7 Consent to Personal Data Processing – the voluntary expression of will by the personal data subject, giving permission for the processing of their personal data for a specific purpose, provided either in written or electronic form.
3.8 Legitimate Interest – a legal basis for processing personal data, which relies on the legal permission for the data controller to collect and process personal data to safeguard the legitimate interests of either the controller or a third party to whom the data is transferred. This is subject to the condition that the rights and freedoms of the data subject are not overridden by such interests. The Company's legitimate interests are described in paragraph 1.3 of this Privacy Policy. When determining these interests, we balance the rights and freedoms of the data subjects against the Company’s legitimate objectives.
3.9 Personal Data Processing – any operation or series of operations, such as collecting, recording, accumulating, storing, adapting, altering, updating, using, sharing (distribution, implementation, transfer), depersonalizing, or destroying personal data, whether automated or manual.
3.10 Automated Personal Data Processing – operations carried out wholly or partially using automated tools, such as data storage, logical and/or arithmetic operations, data modification, destruction, selection, or distribution.
3.11 Third Parties (Personal Data Recipients) – any individuals other than the personal data subject, data controller, or data processor, who receive personal data from the controller or processor.
3.12 Redirect Domain – a component of the tracking system, which is a URL that automatically redirects consumers from an affiliate’s link to the advertiser’s website.
4. What is your personal data, and for what purpose can we process it? Method of obtaining personal data.
4.1 We can collect and process several types of personal information related to the use (visit) of the Website by users, as well as information related to the provision of services on the Website:
-information about users (visitors) of the Website;
-information about consumers;
-information about potential users.
4.2 During your interaction with the website as a user, we may collect and process the following information: the IP address of the user’s device from which the website is accessed, the date and time the user visited the website, the technical characteristics of the web browser and operating system the user’s device from which the Website is accessed, the Website from which the user was redirected to the Website, other similar information.
The information indicated in this paragraph can be collected and processed for analytics, optimization, and improvement of the Website, to create safe conditions for using the Website, for historical and statistical purposes (including for the formation of registers of users of the Website and their data, specified in this paragraph).
4.2.1. When you contact the Company using the feedback forms on the Website, we may collect and process the following personal information: first name, last name and (if available) patronymic, email address, country, phone number, messenger contact details, any what other data the user provides in an email through a feedback form or online chat.
The information indicated here may be collected and processed to establish contact and provide the requested information, for communication and interaction between the Company and the user, for analytics, optimization, and improvement of the Website, for creating safe conditions for using the Website, for historical and statistical purposes (including for the formation of user registers and their data specified in this paragraph), for marketing and advertising of services, offers of the Company, including new offers and services (messages and offers of services and products of the Company, other types of marketing and advertising activities of the Company)
4.3 The Company may use your personal data to provide services and information about new services, products, and services offered by our company. You have the right to refuse to receive such communications at any time.
4.4 We may use the personal data we collect to provide and improve our services, respond to your inquiries, and communicate with you about our products, services, and promotional offers.
4.5 The Company may process your personal data for historical and statistical purposes.
4.6 We may collect personal data through:
-Voluntary submission via contact forms or service contracts
-By obtaining personal data using the tracking functionality of the captains-promotion.com domain and redirect domains (The company uses the following redirect domains: caphen.xyz, capikl.xyz, capjoy.xyz, capkel.xyz, caplor.xyz, capnom.xyz, capque.xyz, capren.xyz, capsaw.xyz, capwow.xyz)
-Website visits (IP address, visit details, technical data)
-Cookies (see our [Cookie Policy] for more details)
4.7 Providing personal data is voluntary but necessary for the Website’s functionality and service provision. Without the necessary data, we may be unable to fulfill service contracts or provide services.
4.8 We may process your personal data using both manual and automated methods.
5. On what basis and for what purpose can we process your personal data?
5.1 We process personal data in accordance with the national laws of England and international regulations.
5.2 The legal bases for processing your personal data include:
-Your consent to the processing of your personal data.
-The necessity to perform a contract with you or to take steps at your request before entering into a contract.
-Protection of vital interests.
-Compliance with a legal obligation.
-Our legitimate interests or those of a third party.
6. Duration of Personal Data Processing
6.1 We will store and process your personal data only as long as necessary to fulfill the purpose for which it was collected. We strive to ensure that personal data is not retained longer than required for its intended purpose.
6.2 In certain circumstances, we may retain your personal data beyond the initial purpose of processing, such as to comply with legal obligations, protect your rights and interests, for statistical or historical purposes, or to interact with governmental authorities.
7. Protection of Your Personal Data
7.1 We implement widely accepted technological and operational standards to protect your personal data from loss, unauthorized access, or misuse. Despite our rigorous efforts, we cannot guarantee absolute security against threats beyond our control.
7.2 We apply necessary confidentiality obligations and security measures, both technical and organizational, to prevent unauthorized or illegal access, processing, loss, destruction, or damage to your personal data.
8. Who can your personal data be transferred to?
8.1 We may share your personal data with our employees, partner companies, and third parties including advertisers, service providers, and government authorities (such as regulatory, law enforcement). This is done as necessary for our business processes, service provision, legal obligations, and other reasons in accordance with national law and the GDPR.
8.2 Our employees are bound by confidentiality agreements and are trained in responsible data handling. Access to personal data is restricted to those who need it to perform their job functions related to data processing and according to its intended purpose. For instance, employees responsible for data processing, advertising, marketing and user communication may have access to your personal data.
8.3 Personal data may be transferred to partner companies when required for business operations and service delivery, provided this aligns with the data processing purpose. These entities must adhere to strict conditions and obligations regarding data protection and usage.
8.4 We may also share personal data with third-party service providers necessary for our business functions, such as analytics, social media advertising, document exchange, data storage, hosting, and payment processing. These third parties are only granted access to personal data necessary for their services and must comply with data protection requirements.
8.5 External consultants (auditors, accountants, lawyers, etc.) and contractors (software development, system management, website maintenance, advertising, lead generation, translation, etc.) may also access personal data. They are permitted to access only the data required for their services and must adhere to data protection standards.
8.6 Personal data may be provided to government authorities (including regulatory, law enforcement, and judicial entities) as required by law or to fulfill legal obligations.
8.7 You have the right to inquire about your personal data that has been shared, including the basis for sharing and the recipients. To request this information, please contact us at admin@captainspromotion.com. We may ask you to verify your identity to prevent unauthorized access.
9. Your rights as a personal data subject.
9.1. As a personal data subject, you have the following rights as guaranteed by law:
Awareness: To be informed about the sources of collection, location, purpose of processing, and the data owner’s location.
Access Conditions: To receive details about how access to your personal data is provided, including information about third parties to whom your data has been disclosed.
Access to Data: To access your personal data.
Information Request: To receive confirmation within thirty calendar days of your request, unless otherwise specified by law, regarding whether your personal data is being processed, and to obtain the content of such data.
Objection to Processing: To make a reasoned objection to the processing of your personal data.
Rectification or Deletion: To request that your personal data be corrected or deleted by any data owner or processor if it is processed unlawfully or is inaccurate.
Protection: To protect your personal data from unlawful processing and accidental loss, destruction, or damage, as well as from the provision of inaccurate or defamatory information.
Complaints: To file complaints regarding the processing of your personal data with the relevant authority or the courts.
Legal Remedies: To seek legal remedies in the event of violations of personal data protection laws.
Consent Limitations: To impose limitations on the processing of your personal data when providing consent.
Withdrawal of Consent: To withdraw your consent to the processing of your personal data.
Automated Processing: To understand the mechanism of automated personal data processing.
Automated Decisions: To challenge decisions made solely based on automated processing that have legal effects on you.
Right to be Forgotten: To request the deletion of all personal data from our databases.
9.2. To exercise your rights or if you have any questions related to your personal data, please contact us at admin@captainspromotion.com. We may ask you to verify your identity to prevent unauthorized access.
10. Sensitive Personal Data
10.1. Generally, the Company does not process sensitive personal data such as information on racial or ethnic origin, political, religious, or ideological beliefs, political party or trade union memberships, criminal convictions, or data related to health, sexual life, biometric, or genetic information.
11. Third-Party Sites
11.1. For user convenience, our Website may contain links to other sites, including those of partners or suppliers, which have their own privacy policies. This Privacy Policy does not apply to such external websites. We are not responsible for the content, products, services, or privacy practices of these third-party sites. We encourage you to review the privacy policies of any external sites you visit.
12. Social Networks
12.1. Our Website may include links to social networks such as Facebook, Twitter, YouTube, Instagram, or LinkedIn. These networks may collect information about your IP address and the pages you visit on our Website, and may set cookies. Your interactions with these networks are governed by their own privacy policies.
13. Data Transmission to Third Countries
13.1. Personal data may be transferred to foreign entities only if the recipient country ensures adequate data protection as established by law or international agreements with England.
13.2. We may transfer personal data to foreign entities if they comply with data protection laws and the transfer aligns with the purpose of data processing.
13.3. To inquire whether your personal data has been transferred to third countries, contact us at admin@captainspromotion.com. We may require identity verification to prevent unauthorized access.
14. Updates to This Privacy Policy
14.1. This Privacy Policy may be updated periodically to reflect changes in our practices or legal obligations. Please review this Policy regularly for any updates. The “Effective Date” at the top of this Policy indicates its most recent update.
15. Contact Us
15.1. For any questions regarding this Privacy Policy or the processing of personal data, please reach out to us at admin@captainspromotion.com.
Cookies policy
1. General information
1.1 We use cookies to enhance and optimize the functionality of our Website. This Cookie Policy explains what cookies are, how we use them, and the reasons we store them.
2. What Are Cookies?
2.1 Cookies are small text files placed on your device (such as a computer, tablet, or mobile phone) when you visit our Website. These files hold information about your interactions with the Website, allowing it to remember your preferences and actions.
2.2 Cookies help maintain your session on the Website, meaning you won’t need to re-enter your login details on every page after signing in.
3. Third-Party Cookies
3.1 Our Website may include cookies from third parties. These cookies are set by trusted partners to help analyze traffic, deliver targeted ads, and enable social networking features. We do not control these cookies; their use is governed by the privacy policies of the respective third parties.
4. Types of Cookies We Use
4.1 Internet technologies are continually evolving, which means the specific cookies we use may change over time. As a result, we cannot guarantee that the cookies described in this Policy will remain consistent.
This Cookie Policy outlines the general categories of cookies we use on our Website and provides examples of these cookies.
4.2. We use such types of cookies as analytical cookies. We use analytical cookies to collect information about how visitors interact with our Website. This helps us understand and improve the performance and usability of our Website. Examples of analytical cookies: _ga – records the unique identifier of a website visitor. This identifier makes it possible to track how the visitor uses the website. This data is used for statistics in Google Analytics, for example, GA1.1.413885605.1690818789. __utmc – records the time of the website visit and stores this data in Google Analytics, for example, 134756461.
5. What Data Is Collected?
5.1 When you visit our Website, we automatically gather certain data from your device, including:
a) Your IP address.
b) The date and time of your visit.
c) The duration of your session.
d) The number of times you have visited our site within a month.
e) The operating system of your device.
6. Data Protection and Storage
6.1 Information collected via cookies may include personal data. We handle your personal data in accordance with our Privacy Policy. Cookie data is retained only for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is mandated or permitted by law.
7. Updates to This Policy
7.1 We may update this Cookie Policy periodically. We recommend reviewing it occasionally for any changes. The “Effective Date” at the top of this Policy reflects the most recent update.
8. Contact Us
8.1 If you have any questions regarding this Cookie Policy or the use of cookies, please reach out to us at admin@captainspromotion.com.
