Types of “Personal Information” we collect. In addition to the types of information described above, we may also collect Personal Information about you when you directly submit it to us. First Capital Cashflow may provide you the opportunity to do such things as subscribe to email alerts regarding First Capital Cashflow events, products, services or company news, to request company information, or to request product or service information through an email contact form. You may opt-out of receiving these solicitations at any time. Such information may include your name, your company’s name, your personal or company email address or other contact information. It is up to you whether to provide this information. Such information will be used and disclosed as reasonably necessary to meet your needs and respond to your requests, such as disclosing it to our email service provider to send you emails or to one of our affiliated entities to provide you with product information. Parties with whom we share Personal Information are bound to contracts requiring them to use and disclose the information only for the permitted purposes and to use reasonable security measures to protect Personal Information from unauthorized access and use. First Capital Cashflow may also use and disclose Personal Information to comply with application U.S. and/or International laws, regulations, Court orders and lawful instructions from government agencies, to protect the personal safety of Site users or the public, to prevent and defend claims, to resolve disputes, to troubleshoot problems, to enforce the Terms, and to protect our rights and property. If you register for a service offered through the Site, First Capital Cashflow may collect additional Personal Information and use it for additional purposes reasonably related to that service; you will be given a supplemental privacy disclosure as part of the registration process.
Contained within our website is a tracking code provided by Lead Forensics. This code enables Lead Forensics to track activity on the website and provide us with information on the IP address of the requesting computer, the date and duration of the user’s visit, and the web pages which the user visits.
The Lead Forensics tool uses IP tracking for identifying businesses and is not the same as cookies. The Lead Forensics tracking code only provides information that is readily available in the public domain. It does not, and cannot, provide individual, personal or sensitive data regarding who has visited our website. It provides information on what companies have visited our website by identifying them from their IP address. This data may be used by us to contact the business about their experience or for marketing purposes. We will not pass this data to third parties for any reason. More information can be found at www.leadforensics.com
Cookies & Related Issues. When you visit the Site, we may receive certain standard information that your browser sends to every website you visit, such as the originating IP address, browser type and language, access times and referring website addresses, and other such information. This data may be used, among other reasons, to improve the operation and security of the Site by assisting in “authenticating” who you are when you access this Site, particularly if you register for access to part of the Site and are issued or create a username and password. We may receive additional technical data about the device used to access the Site (“Device Data”) (such as device ID, device model, operating system version, application types and versions, browser type, language, and plug-ins, originating IP address, and time zone and geolocation information). Device Data may be used as part of our security controls to uniquely identify the device and authenticate the user when accessing the Site. Device Data may be shared (along with information about any fraudulent transactions using the device) with one or more third-party service providers. These providers will compare and add the Device Data and fraud data to a database of similar device and fraud information in order to identify and block access to the Site by devices associated with fraudulent or abusive activity.
Additionally, we may receive additional information about your visit to the Site, including the pages you view, the links you click and other actions you take in connection with the Site and any products and services offered through it. This data may be used, among other reasons, to improve the operation of the Site and/or provide you marketing information. We may use third parties to provide advertisements that may be of interest to you, based on that’s your activity while visiting our website and/or third-party websites.
Links & Frames. Links to other sites may be provided on any of First Capital Cashflow Site for your convenience. By providing these links, First Capital Cashflow is not endorsing, sponsoring or recommending such sites or the materials disseminated by or services provided by them, and are not responsible for the materials, services or other situations at or related to or from any other site, and make no representations concerning the content of sites listed in any part of this Site. Consequently, First Capital Cashflow cannot be held responsible for the accuracy, relevancy, copyright compliance, legality or decency of material contained in sites listed in any search results or otherwise linked to this Site. For example, if you “click” on a banner advertisement or a search result, your “click” may take you off this Site. This may include links from advertisers, sponsors, and content partners that may use First Capital Cashflow’s logo(s) as part of a co-branding agreement. These other sites may send their own cookies to users, collect data, solicit Personal Information, or contain information that you may find inappropriate or offensive. In addition, advertisers may send cookies to users that First Capital Cashflow does not control. First Capital Cashflow reserves the right to disable links from any third-party sites to this Site.
Interactive Features. This Site may include opportunities for you to access, view and provide content for this Site, such as blogs, comment sections, discussion forums and other similar interactive features (“Interactive Features”). If you have any questions specifically regarding the Interactive Features (or the related portions of this Site), please contact First Capital Cashflow at firstname.lastname@example.org. You alone are responsible for your use of any Interactive Features and you use them at your own risk. Any content questions, comments, suggestions, information, ideas, concepts, photographs, graphics or other materials, whether oral, written or electronic (collectively, “Content”) which you submit through an Interactive Feature must pertain to the designated topic or theme of the applicable Interactive Feature. You may not use this Site or any Interactive Features in any way that (as determined by First Capital Cashflow) impairs, restricts or inhibits anyone else from enjoying or using this Site or the Interactive Features.
Amendments. First Capital Cashflow may amend this Policy at any time by posting a revised version on this Site, which will be effective at the time it is posted for all Personal Information collected thereafter unless a delayed effective date is expressly stated in the revision. By using this Site after such additions or modifications are posted, you are agreeing to accept and comply with the Policy as modified.
How we work out what marketing you receive. We use marketing to let you know about products, services and offers that you may want from us. This section tells you how we decide what marketing to show or send you. It also explains how we work out what you may be interested in. We may use your Personal Information to make decisions about what products, services and offers we think you may be interested in.
We can only use your Personal Information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. The Personal Information we have for you is made up of what you tell us, and data we collect when you use our services, or from outside organizations we work with. We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You can contact us at any time and ask us to stop using your Personal Information this way. If you allow it, we may show or send you marketing material online (on our own and other websites including social media), in our app, or by email, mobile phone or post. What you get will depend on marketing choices that you set. You can change these at any time and tell us to stop sending you marketing. We do not sell the information we have about you to outside organizations. We may ask you to confirm or update your choices, if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business. If you change your mind you can contact us to update your choices at any time.
Privacy Shield Framework and General Data Protection Regulation (GDPR). The United States Department of Commerce and the European Commission have agreed on a set of data protection principles (the “EU-U.S. Privacy Shield Framework”) and frequently asked questions (collectively the “EU-U.S. GDPR Framework”) to enable U.S. companies to satisfy the requirement under GDPR that adequate protection be given to Personal Information transferred from the EU to the United States or other non-EEA countries. The EU also has recognized the EU-U.S. GDPR Framework as providing adequate data protection. The United States Department of Commerce and the Federal Data Protection and Information Commissioner of Switzerland have agreed on a similar set of data protection principles (the “Swiss-U.S. Privacy Shield Framework”) and frequently asked questions (collectively the “Swiss-U.S. GDPR Framework”) to enable U.S. companies to satisfy the requirement under Swiss law that adequate protection be given to Personal Information transferred from Switzerland to the United States. Consistent with its commitment to protect personal privacy, First Capital Cashflow adheres to the EU-U.S. GDPR Framework and the Swiss-U.S. GDPR Framework.
In order to provide these services, First Capital Cashflow receives information about the customers of these EEA Clients including but not limited to Personal Information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life or name, office and personal telephone numbers, company and home address, account numbers and transaction details, website login credentials, and email address (collectively, Personal Information).
Use of Personal Information. First Capital Cashflow uses Personal Information to perform its obligations under its EEA Client agreements, including the following activities:
- Processing opening, change or closing requests for individuals on behalf of the EEA Client;
- Processing opening, change or closing requests for accounts on behalf of the EEA Client;
- Processing transaction information on behalf of the EEA Client;
- Providing transaction screening services to EEA Clients;
- Providing data security services to EEA Clients;
- Providing account management services to EEA Clients; and
- Providing EEA Client support or implementation services for the above activities and for First Capital Cashflow software.
If First Capital Cashflow intend to use your information for a purpose that is incompatible with these purposes or if we intend to disclose it to a type of third party not previously identified, we will notify you and offer you the opportunity to opt out of such uses and/or disclosures. First Capital Cashflow will obtain assurances from its agents that they will safeguard Personal Information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the GDPR. Where First Capital Cashflow has knowledge that an agent is using or disclosing Personal Information in a manner contrary to this Policy, First Capital Cashflow will take reasonable steps to prevent or stop the use or disclosure.
Third-Party Content. First Capital Cashflow receives some of the Materials on this Site from third parties, including other users. All statements, opinions, advice, criticisms, offers or other information stated or expressed by any such third parties reflect solely the opinion and belief of the respective third party making such statement, and not that of First Capital Cashflow or any of its affiliates. First Capital Cashflow makes no endorsement, guarantee or other statement, express or implied, about such third-party Materials, including that any such third-party Materials are accurate, complete, timely, corroborated or otherwise useful or appropriate for any use or circumstance. You must independently evaluate any such third-party Materials yourself if you intend to rely in any way on the information contained in or provided in connection with such third-party Materials, and you alone must engage any appropriate professionals necessary or prudent in making that evaluation (which First Capital Cashflow recommends you do).
Third-Party Site Links. First Capital Cashflow Sites may provide links to other sites operated by third parties over whom First Capital Cashflow has no control and whose privacy policies may differ from ours. These links are provided for your convenience. If you browse on or submit Personal Information to any of those sites, information about you may be collected by them and will be governed by their privacy policies.
Eligibility. This Site is not offered to any person under the age of 13. If you are over the age of 13 but under the age of 18, you must either: (i) be an emancipated minor, or (ii) have obtained the legal consent of your parent or legal guardian to use this Site and enter into these Terms. Please do not submit such information to us, and as a parent or legal guardian, please do not allow your children to submit personal information without your permission.
Copyright Notice. Materials may be made available to you via this Site that comes from third parties not within First Capital Cashflow’s control such as, but not limited to a message board. In connection with the Digital Millennium Copyright Act (DMCA), while First Capital Cashflow fully respects the copyright interest of all of First Capital Cashflow’s users and all such third parties, First Capital Cashflow has no obligation to, and does not, scan Materials or any content uploaded, provided, posted or otherwise used in connection with this Site for the inclusion of illegal, infringing, improper, unauthorized or impermissible content. However, as a matter of policy, First Capital Cashflow does not allow Materials it knows are infringing another person or entity’s copyright to remain on this Site. Our agent for notice of claims of copyright or other intellectual property infringement can be reached as follows:
Attn: Copyright Agent
First Capital Cashflow Ltd.
16 Daresbury Court
Regional Information & Product / Services Marketing. Information First Capital Cashflow publishes on this Site may contain references or cross references to First Capital Cashflow products and services that are not announced or available in your country or region of the world. Such references do not imply that First Capital Cashflow intends to announce such products or services in your country. Please consult your local First Capital Cashflow business contact for information regarding the products and services which may be available to you.
How to withdraw your consent. You can withdraw your consent at any time. Please contact us if you want to do so. This will only affect the way we use information when our reason for doing so is that we have your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.
Data Protection Statement. In accordance with our responsibilities under the Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 you should be aware that the Personal Information you choose to provide will not be passed to any person or organization outside First Capital Cashflow. It will be taken that, in providing the information you agree to the use of your personal details to that extent.
How long we keep your Personal Information. We may also keep your data for longer than 10 years if we cannot delete it for legal, regulatory or technical reasons. We will only use your Personal Information for those purposes and will make sure that your privacy is protected.