The Company uses the Client’s information for the following purposes:

• • To operate and improve the Service.
  • To process and facilitate the Client’s transactions.
  • To communicate with the Client about the Service.
  • To comply with AML, legal and regulatory requirements.
  • The Company may use cookies to enable them to identify the Client as a return user and personalize and enhance their experience and their use of any of the Platform or the Website. For example, a cookie may be used to pre-populate a registration form, or avoid details having to be entered more than once. Declining cookies may impact the experience of the Service, or limit the use or functionality of the Platform or the Website.

The Company may disclose the Client’s information to the following third parties:

• Service providers who assist in the operation of the Service
• Financial institutions and payment processors who facilitate Client’s transactions
• Law enforcement or government authorities who request Client’s information for legal or regulatory purposes
• Measurement and Analytics Service providers. Company’s Partners who use its analytics services like Google Analytics (Non-Personally Identifiable Information Only). The Company does not share information that personally identifies the Client with advertising, measurement or analytics partners

The Company transfers information to service providers (processors), and other partners who globally support its business, such as providing technical infrastructure services, trading platforms, client identity verification, including PEPs and sanctions, services related to its website management.

The Company may need to transfer data to recipients outside its country of incorporation: these activities can include dealings with foreign public entities (only when necessary and under request), the outsourcing of services to external providers located outside its country of incorporation and/or processing the data outside its country of incorporation (e.g. cloud computing, client identity verification and individuals from outside its country of incorporation accessing to our web-services), or when arranging staff work trips to countries outside its country of incorporation.

The Company’s website contains links to other websites. The Company cannot be held responsible for the privacy policies of other websites. The Company confirms that it has a strict policy of not sharing the Client’s Information with an unauthorized third party under any circumstances.

The Company implements reasonable security measures to protect the Client’s information from unauthorized access, disclosure, or use.

The Company has established an Internal Educational Training for its employees so as to mitigate any risks that may affect the Client’s data. The Company’s employees that are processing the Client’s data are being trained to respect the confidentiality of Client’s information and the privacy of individuals.

The Company has implemented procedures in respect to safeguarding the Client’s data. Access to the Client’s information is only provided to the Company’s employees and/or Partners that need to have access to the information in order to enable the continuity of the Client’s account.

The Company holds personal information in a combination of secure computer storage, secure servers and from time to time and if it is deemed necessary the Company will store them in paper-based files.

However, no data transmission over the internet can be guaranteed to be completely secure.

When the Client’s Data is no longer required, it will be destroyed either by shredding or other approved destruction methods to prevent unauthorized parties from gaining access to the information during and after the process.

The Company retains the Client’s information for as long as necessary to provide the Service and comply with legal and regulatory requirements.

The Company retains the Client’s Information for as long as it is required to do so subject to the relevant legal framework, including for the purposes of updating the product or services or as required by law. The Client has the right to request to erase their information; however this is subject to the 7 year retention period after closing the account.

The Client has the following rights with respect to their information:

• To access and review their information – The Client has the right to request that the Company provides them a copy of their information.
• To request the correction of any inaccurate or incomplete information – The Client has the right to request the Company to correct, amend or update any information they believe is inaccurate or incomplete.
• To request the deletion of their information, subject to legal and regulatory requirements – The Client has the right to request that the Company erases or destroys their personal information in certain circumstances, including where the Client withdraws their consent, where the data is no longer required for collection purposes or where the data has been unlawfully processed.
• To restrict processing – The Client has the right to request that the Company restricts the processing of their information under certain conditions, including where processing is inconsistent with the reason for which the personal information was collected.
• To object processing – The Client has the right to object to the Company processing their information under certain circumstances, including the right to object to profiling, automation and direct marketing.
• To transfer data – The Client has the right to request the Company transfers the data the last has collected to another organization or directly to the Client, under certain circumstances.

To the extent that the Company relies on its legitimate interests to use the Client’s information, the Client also has the right to object to such use (unless the Company can either demonstrate compelling legitimate grounds for the use that override the Client’s interests, rights and freedoms or where the Company needs to process the information for the establishment, exercise or defense of legal claims).

The Client must inform the Company at any time that their Information has changed via written notification.

The Company will change the Client’s Information in accordance with their instructions, except to the extent that the Company is required to hold the Client’s Information for regulatory or legal purposes, to provide the Client with the Services they have requested or to maintain adequate business records.

Any updates or changes to this Agreement will be communicated to the Client in writing. Notification is sent via email to the addresses provided by the Client. Updates or changes will become effective on the date specified in the notification, or if no date is specified, on the date the notification is sent. The Client is responsible for reviewing and acknowledging any updates or changes in a timely manner. Failure to do so may result in them being held responsible for any consequences resulting from the failure to comply with the updated or changed terms.

Any questions or concerns about this Agreement or the Service, should be addressed in written to the email contact@capitalwallet.com

By using the Service, the Client agrees to the terms of this Agreement and acknowledges that they have read and understood the Company’s privacy practices.