Privacy Policy

Capway, L.L.C. (“we” or “us“) wants you to be familiar with the information we collect about you, how that information is being used, how that information is disclosed to third-parties, and the choices you have regarding the collection, use, and disclosure of such information.  This Privacy Policy (this “Policy“) describes our practices in connection with the information that we collect through CapWay, a mobile device application (the “App“), our website, and related electronic communications.  Please, take a moment to review this Policy and feel free to contact us at info@demoaspire.com/2017/capway with any questions or complaints you may have regarding our practices under this Policy.

This Policy applies to all users of our sites, products, and services (collectively, “Services“) that link to this Policy, including without limitation the App and our website.  By using the App, our website, or other Services, you agree to this Policy and agree to be bound by our Terms of Use.  If you do not agree with any term in this Policy, please do not provide us your personal information or use any Services to which this Policy applies.

This Policy may change from time to time.  Your continued use of any Services to which this Policy applies after we make changes is deemed to be acceptance of those changes, so please check this Policy periodically for updates.

Information We Collect and How We Collect It

As we explain in more detail below, we collect information about you (“personal information“) in three main ways: (1) directly from you when you provide it to us; (2) automatically when you use certain Services, including the App; and (3) from others when we ask them for it.
Information You Provide to Us
When you download, register with, access, or use the App or other Services, or otherwise contact us and provide us with feedback, we may ask you to provide certain information to us through various forms, features or other means.  Such information may include any of the following:

  • information by which you may be personally identified, such as your name, postal address, email address, telephone number, social security number (used for identification purposes), or any other identifier by which you may be contacted online or offline (“personally identifiable information“);
  • information about you or your household that does not identify you personally, such as your age, gender, race, education level, income, what types of financial products you are interested in, or other similar types of information that you provide as answers to questions in the App’s programs (“non-personally identifiable information“); and
  • information that you input into the App regarding your non-public personal or business finances, such as your financial services providers, account identification numbers, and transaction types and amounts (“personal financial information“).

Information We Automatically Collect

We automatically collect certain information about how you access and interact with our Services (“usage information“).  Such information may include any of the following:

  • information about how you access our Services, such as the operating system, hardware model, application or browser type and version, and unique identifiers associated with your device (“device information“);
  • information we automatically collect in system logs or similar files about how you interact with our Services, such as which features you visit or click on, or other information like your Internet Protocol (“IP“) address, browser or device configuration, date and time of access, and cookie information (“log information“); and
  • information like your IP address or other device information or log information to estimate your location (e.g., your city or state) (“location information“). We may also request to use location-enabled services on your device (which typically provide GPS or Wi-Fi access point details) to enhance our Services.  However, we will only use these location-enabled services on your device with your consent.

We and our business partners may use various technologies to collect and store usage information in connection with our Services, including cookies, browser web storage (e.g., HTML5), web beacons, and similar technologies.  We may also integrate with built-in device features (e.g., when you turn on fingerprint access for your App account).

Information Third Parties Provide About You

We may also collect information from other companies or third parties, such as when you sync a third party account or service with the App or when we may use service provides to supplement the information you give us (e.g., validate your mailing address) to help us maintain the accuracy of your data and provide you with better Services.

How We Use the Information We Collect

We may use personally-identifiable information and personal financial information we collect in the following ways:

  • to provide you with products, services or information that you request;
  • to send you important information regarding the App and other Services, or changes to our terms, conditions, and policies (because this information may be important to your use of the App and other Services, you may not opt-out of receiving such communications);
  • to inform you of products, programs, services and promotions that we believe may be of interest to you (if you would prefer that we do not send such email marketing messages to you, please see the “Your Choices About Our Collection, Use, and Disclosure of Your Information” section below);
  • to fulfill your purchases;
  • to enhance our information and to aid us in providing our customers with targeted promotions;
  • to conduct internal research; and
  • for our internal business purposes, such as data analysis and audits.

Because non-personally identifiable information and de-identified usage information does not personally identify you, we may use such information for any purpose.  In addition, we reserve the right to disclose such non-personally identifiable information and de-identified usage information to other third parties, for any purpose.

In some instances, we may combine non-personally identifiable information with personally identifiable information. If we combine non-personally identifiable information with personally identifiable information so that it personally identifies you, the combined information will be treated by us as personally identifiable information as long as it is combined.

When We Share the Information We Collect

We may disclose information about you to affiliated and non-affiliated third parties.

Affiliates

We may disclose the information that we collect to our affiliated companies to provide the Services you request, to enhance our Services to better suit your needs, for research purposes, and from time to time for marketing purposes.

Business Partners

We may partner or collaborate with other companies to offer you products or services, to fulfill the products or services that you order, and for research purposes.  We may disclose the information that we collect to such third-party partners or collaborators for the purposes described in this Policy.

Sponsors of Programs and Services

Third parties sponsor programs and other content in association with the App.  We may disclose to those sponsors the information that is collected through or in accordance with such programs or content, as well as any non-personally identifiable information, de-identified information, and anonymous information.

Service Providers

We work with third parties who provide services including but not limited to data analysis, list enhancement and other administrative services.  We may disclose the information that we collect to such third parties for the purpose of enabling these third parties to provide services to us.  Such services may include: marketing distribution, email list management services, advertising, certain product functionalities, customer support, web hosting, customer data management and enhancement, research and surveys, data analysis and email service.

Assignment

We reserve the right to transfer any and all information that we collect to an affiliate or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or membership interests (including without limitation in connection with any bankruptcy or similar proceedings).

Law Enforcement; Emergencies; Compliance; Other Purposes Permitted by Law

Notwithstanding any other provision of this Policy to the contrary, we reserve the right to disclose any information we collect to others as we believe appropriate: (a) to comply with legal process; (b) to respond to governmental requests; (c) to enforce our Terms of Use or applicable license agreement; (d) to protect the rights, privacy, safety or property of our affiliated companies, you or others; (e) to permit us to pursue available remedies or limit the damages that we may sustain; and (f) for any other purpose permitted by applicable law.

Aggregate, Non-Personal, or De-identified Information

We may share aggregated information (i.e., information about you and other customers collectively, but not specifically identifiable to you) and other non-personally identifiable information, de-identified information, or anonymous information we collect with third parties, including affiliates to develop and deliver targeted advertising on our Site and on the websites of third parties.  If you would prefer that we do not utilize cookies with your website experience, or would prefer to restrict the use of cookies with network advertising partners, please see the “Your Choices About Our Collection, Use, and Disclosure of Your Information ” section below.

Your Choices About Our Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the personally identifiable information and personal financial information you provide to us.  This section describes mechanisms we provide for you to control certain uses and disclosures of your information.

Tracking Technologies

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent.  If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App or our website may then be inaccessible or not function properly.

Location Information

You can choose whether or not to allow the App to collect and use real-time information about your device’s location through the device’s privacy settings.  If you block the use of location information, some parts of the App may then be inaccessible or not function properly.

Promotion by the Company

If you do not want us to use your email address to promote our own or our affiliates’ products or services, you can opt-out by following the un-subscribe link in the e-mail. You can also always opt-out by logging into the App and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to info@demoaspire.com/2017/capway.

Business Partners

If you do not want us to share your personally identifiable information or personal financial information with companies that we partner with or collaborate with to offer you products or services, to fulfill the products or services that you order, or for research purposes, you can opt-out by sending us an email stating your request to info@demoaspire.com/2017/capway.

We do not control third parties’ collection or use of your information to serve interest-based advertising.  However, these third parties may provide you with ways to choose not to have your information collected or used in this way.  You can opt-out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

How You May Access and Correct Your Personal Information

You can review and change your personal information by logging into the App and visiting your account profile page.

How We Protect Your Information

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you.  Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential.  We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure.  Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App.  Any transmission of personal information is at your own risk.  We are not responsible for circumvention of any privacy settings or security measures we provide.

A Special Notice Regarding Individuals Under 18 Years Old

The App and our website are not directed to individuals under the age of eighteen (18), and we request that such individuals not provide personally identifiable information or personal financial information through the App or our website.  If you are under 18 years of age, you may browse the App and our website; however, you may not provide personally identifiable information or personal financial information to us such as name, address, or email address, and you may not register for, enroll in, and/or make product purchases.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: info@capway.co.