This Privacy and Data Protection Policy (this “Privacy Policy”) sets forth how CapitalNetwork and its affiliates (collectively, “CapitalNetwork,” “we,” “our,” or “us”) collect and process personal information that we receive.  We are providing this Privacy Policy to satisfy disclosure requirements required under data protection and privacy regulations adopted by regulatory authorities in the jurisdictions in which CapitalNetwork does business.  Please note that certain of these disclosures may not apply in all circumstances.

This Privacy Policy applies to visitors to and users of this website and any other website maintained by us (collectively, our “Sites”), visitors to our offices, job applicants, individuals who contact CapitalNetwork personnel in certain locations (via phone, video conference or other electronic means), prospective and existing customers and investors, business contacts, third-party service providers, vendors and suppliers.  If you provide personal information to CapitalNetwork about any person other than yourself, it is your responsibility to ensure that the other person understands how such information will be used, including the purposes set out in this Privacy Policy, before it is provided to us.  If you provide us with such information, we are entitled to, and will, assume without confirmation that you have obtained such consent.

If you visit any of our Sites, please review this Privacy Policy carefully and in conjunction with the Terms of Service, which provide other important information regarding your use of our Sites.  By accessing or using our Sites, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy.

1. Information we collect

We collect your personal information in a variety of ways.

• Information you provide to us directly. We may collect personal information, such as your name, address, email address, telephone number and other contact details, when you sign up with CapitalNetwork or otherwise contact or communicate with us.  If you set up a login for any of our Sites, we may also collect your username and password (if applicable).  If you visit our offices or telephone or teleconference any CapitalNetwork employees, we may also collect personal information such as name, organization and other contact details; video images of you from CCTV footage (if in our offices) or via screen shots or electronic recordings of teleconferences; date and time of your visit to CapitalNetwork's offices; and telephone numbers and voiceprints if telephone calls are recorded.
• Information we receive from other parties. From time to time, we may receive information about you from persons other than you, including our customers, other users of our Sites, investors, data service providers, vendors and suppliers.  This information may include information required to process payments, such as tax ID numbers and wire instruction details, and information collected for anti-money laundering and terrorism sanction screening and know your customer databases.  We may combine this information with other information we collect from or about you.  In these cases, this Privacy Policy governs the handling of the combined information.  We may also collect information about you that is publicly available.
• Employment Information. When you apply for a job with us, we may receive information such as your name, address, email address, telephone number, current and post employers, job titles and other personal information you include in application documents, such as your resume.
• Location Information. We collect information about your location with varying degrees of accuracy through GPS/GNSS, WiFi, Bluetooth Low Energy, wireless network triangulation or other methods in order to obtain your location for the purposes of providing our services.  We may also approximate your location by your IP address.

For information on how we use and process tracking technology on the Sites, please see the section titled “Use of Tracking Technology” below.

‍2. Use of personal information

‍Your personal information will be used:  (i) in order to comply with our legal and regulatory obligations, (ii) because we need the information for reasons of substantial public interests, (iii) in order to comply with our obligations under contract, (iv) because we have a legitimate business interest in using it, (v) as otherwise permitted by law or (vi) for any other purposes we may describe when you provide the information, including for the following purposes (as applicable):

• to respond to your questions and handle and resolve requests for customer service or other complaints;
• to perform research with respect to the usage of the Sites (applicable to Site visitors);
• to operate, maintain and provide the features and functionalities of the Sites, including providing customer support and analytics from the Sites, or diagnose or fix technology problems (applicable to Site visitors);
• to understand our visitors and customers, to tailor our product offerings and to analyze statistics and trends to make our Sites and products better and to develop new services or features;
• to inform our machine learning algorithms to enhance or customize our Sites;
• to communicate with you about employment opportunities for which you’ve applied or to fill open job positions as part of a recruiting process (if applicable);
• to maintain the security of our premises, personnel, assets, systems and intellectual property and to manage access to our premises and our disaster recovery procedures (applicable to office visitors);
• to pay you for your services (applicable to third-party service providers, vendors and suppliers);
• in order to comply with our obligations in connection with record-keeping requirements and applicable anti-money laundering, anti-corruption and bribery, terrorism financing rules, sanctions, and the prevention and detection of crime or other applicable laws or regulations of jurisdictions in which Capital conducts business (applicable to office callers, third-party service providers, vendors and suppliers);
• to maintain and provide appropriate management of our relationship with you, including to discuss your account;
• to exchange mail correspondence or documentation which may involve providing your contact details to couriers and service providers in charge of the delivery service;
• to engage your services in the future (applicable to third-party service providers, vendors, suppliers and business contacts);
• to contact you to set up meetings or phone calls between you and your CapitalNetwork business contact(s);
• to send you surveys and promotional materials; and
• to process your financing and subscription requests and to provide you with products or services that you request or in which you express interest and to alert you to product upgrades, special offers, updated information and other new products and services offered by CapitalNetwork, our customers or our third-party partners (please see the section titled “Control Over Your Information” below for more information on your choices about marketing communications) (applicable to Site visitors, business contacts and prospective and existing customers and investors).

For information on how we use and process technology and cookies on the Sites, please see the section titled “Use of Technology and Cookies” below.

‍3. How we share and disclose your information

‍We may share your personal information in the instances described below.  For further information on your choices regarding your information, please see the section titled “Control Over Your Information” below.

We may share, and have shared, personal information we receive about you with the following categories of recipients:

CapitalNetwork affiliates or partners and advisors;

Prospective and existing third-party service providers, vendors, contractors and agents of CapitalNetwork as part of normal business operations, including providers:

• engaged to assist in know your customer and identity verification and anti-money laundering and terrorism screening (applicable to third-party service providers, vendors and suppliers);
• of accounting, banking and other data processing services;
• of information technology services and platforms/applications;
• of courier services or other package delivery services;
• of call recording and storage services (applicable to office callers);
• third-party outsourcing providers;
• building security personnel (applicable to office visitors);
• third parties acting on your behalf such as consultants and other agents;
• governmental authorities or law enforcement officials where required;
• financial institutions to wire payments to you (applicable to third party service providers, vendors and suppliers);
• advisors who provide audit, tax, financial and legal advice to CapitalNetwork; and
• other parties to a merger, acquisition, reorganization, funding/investment round or similar transaction or proceeding involving CapitalNetwork, or steps in contemplation of such activities.

Personnel employed by service providers generally may have access to your personal information for the purpose of performing duties for CapitalNetwork but are prohibited from using such information for other purposes.

CapitalNetwork may also disclose your personal information (i) to particular parties, including potential customers or investors, pursuant to your consent, (ii) to fulfill your instructions, (iii) to comply with applicable laws and regulations or the reasonable requests of law enforcement, (iv) to enforce our Terms of Service or to protect the security or integrity of our Sites, (v) to exercise or protect the rights, property or personal safety of CapitalNetwork, our visitors or others or (vi) to fulfill other applicable requirements.

We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.

Your personal information may be transferred to or shared with entities in countries where data protection laws might not exist or be of a lower standard than in the United States.  This includes the transfer of personal information among CapitalNetwork affiliated entities and the jurisdictions in which they operate.   In addition, we may transfer or share your personal information with non-affiliated parties located in the same jurisdictions as CapitalNetwork entities as well as other jurisdictions, and information may be stored and processed manually and electronically through global systems and tools for the purposes outlined in this Privacy Policy.

‍4. Control over your information

‍Email communications preferences:  From time to time, we may send you emails regarding updates to our Sites, products or services, notices about our organization or information about products/services we offer.  If you wish to unsubscribe from such emails, simply click the “unsubscribe” link provided in such communications.  We make every effort to promptly process all unsubscribe requests.  Please note that you may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Sites, or technical or security notices).

Modifying or deleting your information:  If you have any questions about reviewing, modifying or deleting your information, you can contact us directly at gc@capitalnetwork.co. We may not be able to modify or delete your information in all circumstances.

Other rights you may have:  The rights described in this subsection are applicable to you only if you reside in a jurisdiction where the provision of such rights is required by the data protection and privacy laws and regulations of the governing regulatory authority.  As such, where required by applicable law or regulation, you may ask CapitalNetwork for a copy of your personal information, to correct it, to erase it or to transfer it to other organizations.  You may also have rights to object to some processing and, where we have asked for your consent to process your personal information, to withdraw this consent.  In particular, you have rights to object to direct marketing at any time.

You should also be aware that these rights may be limited (for example, access to personal information may be denied if making the information available would reveal personal information about another person or if we are legally prevented from disclosing such information).  In addition, CapitalNetwork may be able to retain data even if you withdraw your consent if we can demonstrate that we have a legal requirement to process your personal information. If you do not provide personal information in circumstances in which we must collect and process such information in order to comply with applicable law or enter into and perform services under an agreement with you, we may not be able to enter into the agreement or provide services as contemplated by any agreement we have in place.  If we are not able to fulfill a request you make because your rights are limited, we will inform you of the reasons why when responding.

We will need to verify your identity prior to addressing your request.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to personal information collected about you.  To designate an authorized agent, the authorized agent must provide sufficient information that allows us to reasonably verify that they have been authorized by you to act on their behalf.

Should you have any questions or requests in relation to your rights, please email gc@capitalnetwork.co. We will attempt to deal with all requests at the earliest opportunity.  In addition, if you have unresolved concerns you have the right to complain, where permitted, to competent data protection authorities.

‍5. How we safeguard and retain your information

Data safeguards:  We care about the security of your information and employ physical, administrative and technological safeguards designed to preserve the integrity and security of all information collected through our Sites.  However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%.  In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

‍Data retention:  We will retain your personal information only for as long as we consider necessary in connection with the purposes set out in this Privacy Policy, unless applicable law or regulations require or permit a longer retention period.  In addition, we may retain your personal information for the duration of any period necessary to establish, exercise or defend any legal rights.  We may anonymize or aggregate personal information and store it indefinitely in order to analyze aggregate metrics and trends.

‍6. Information collected through tracking technologies

‍To provide a personalized and high-quality experience for our users, we and our third-party partners may use various technologies that automatically record certain technical information from your browser or device when you visit or use our Sites, read our emails or otherwise engage with us.  This information is typically collected through a variety of tracking technologies, including cookies, Web beacons, embedded scripts, location-identifying technologies, file information and similar technology (collectively, “tracking technologies”).

We and our third-party providers use these tracking technologies to automatically collect usage and device information, such as:

Your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account and other such information.

We also collect information about the way you use our Sites.  For example, the Website from which you came and the Website to which you are going when you leave our Sites, the pages you visit, the links you click, how frequently you access the Sites, whether you open emails or click the links contained in emails, whether you access the Sites from multiple devices and other actions you take on the Sites.

When you access our Sites from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (or IDFA), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address.

We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Sites and to understand more about our users by monitoring aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website.  You can learn more about Google’s practices at https://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.  Some of this data may be used for advertising purposes.We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.

‍Do Not Track Signals:  Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser or mobile application at this time.

‍Managing Cookies and Flash Cookies:  If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it, (ii) disable existing cookies or (iii) set your browser to automatically reject cookies.  Please note that not accepting cookies may negatively impact your experience using the Sites, as some features and services on our Sites may not work properly.  Depending on your mobile device and operating system, (a) you may not be able to delete or block all cookies, (b) you may not be able to block non-cookie technologies, and (c) these browser settings that block cookies may have no effect on such techniques.  You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

Our reference to any third party or their software or services is not an endorsement by us of such third party or their products and services, and we disclaim any liability for the use or operation of any third-party software or services.

‍7. Links to third-party websites

‍The Sites may contain links to and from third-party Websites of our business partners, advertisers and social media sites, and our users may post links to third-party Websites.  Such links are provided for convenience only, and you access them at your own risk.  If you follow a link to any of these Websites, please note that these Websites have their own privacy policies and that we do not accept any responsibility or liability for their policies.  We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the Websites of third party.

‍8. Children’s online privacy protection rule‍

The Sites are not intended for or targeted towards, and we do not knowingly collect personal information via the Sites from children under the age of 13 years.  If we learn we have collected or received personal information via the Sites about a child under the age of 13 years, we will delete that information as quickly as possible.  If you believe that we may have any personal information from a child under the age of 13 years, please contact us at gc@capitalnetwork.co.

‍9. How to contact us ‍

‍If you have any questions about this Privacy Policy or the Sites, please contact us at gc@capitalnetwork.co.

10. Changes to our privacy policy

We may modify or update this Privacy Policy from time to time, so you should review this page periodically. If we change the policy in a material manner, for example if we seek to use personal information in a materially different way than we had previously, we will let you know and update the ‘last modified’ date at the top of this page. Continuing to use our Sites after we publish changes to this Privacy Policy means that you are consenting to the changes.

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