Capital Space, Inc. (“CapitalSpace” or “We”) respects your privacy and is committed to protecting it through our compliance with this policy.
This policy applies to the information we collect:
- Through CapitalSpace Properties;
- Email, text, and other electronic messages between you and CapitalSpace
- Through mobile and desktop applications, you download, which provide dedicated non-browser-based interaction between you and a CapitalSpace site.
It does not apply to information collected by:
- Offline communication with CapitalSpace parties or through any other means outside of the CapitalSpace Properties; or
- Any third party, including through any application or content (including advertising) that may link to or be accessible from or on a CapitalSpace site.
Information we collect about you and how we collect it
We collect several types of information from and about users of CapitalSpace Properties, including information:
- By which you may be personally identified, such as name, postal address, e-mail address, and telephone number (“Personal Data“); and/or
- About your internet connection, the equipment you use to access CapitalSpace Properties, and usage details.
We collect this information:
- Directly from you when you provide it by filling in forms on CapitalSpace Properties, sending correspondence to us, or completing transactions through CapitalSpace Properties.
- Automatically as you navigate through the CapitalSpace site, information collected automatically may include usage details, traffic data, location data, logs, other communication data the data regarding the resources that you access and use on the CapitalSpace site, and information about your computer and internet connection, including your IP address, operating system, and browser type.
Your opt-in will be required for any automatic data collection that isn’t purely for CapitalSpace internal analytics or necessary for using the CapitalSpace site. The information we collect automatically is statistical data and does not include personal information. Still, we may maintain it or associate it with personal information we collect in other ways or receive from third parties.
How we use your information
We use information that we collect about you or that you provide to us, including any Personal Data:
- To present CapitalSpace app and their contents to you;
- To provide you with information, products, or services that you request from us;
- To improve the CapitalSpace site by storing information about your preferences, customizing elements of the CapitalSpace app to your interest, speeding up your searches, and recognizing you when you return to the CapitalSpace site.
- To fulfill any other purpose for which you provide it;
- To provide you with notices about your account/subscription, including expiration and renewal notices;
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
- To notify you about changes to the CapitalSpace site or any products or services we offer or provide through it;
- To allow you to participate in interactive features on the CapitalSpace site.
- In any other way we may describe when you provide the information;
- For any other purpose with your consent.
CapitalSpace will only use your Data in ways compatible with the limited purpose for which it was collected unless we receive your permission otherwise. Before we use your Personal Data for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out of such usage. We maintain reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete, and current.
Disclosure of your information
We may disclose aggregated information about our users that does not identify any individual without restriction.
- To our subsidiaries and affiliates;
- To contractors, service providers, and other third parties we use to perform functions on our behalf and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. We take reasonable and appropriate steps to ensure that third-party agents and service providers process Personal Data in accordance with our obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of Personal Data that we transfer to them;
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of CapitalSpace assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by CapitalSpace about users of the CapitalSpace Properties is among the assets transferred;
- To fulfill the purpose for which you provide it;
- For any other purpose disclosed by us when you provide the information;
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including responding to any valid government or regulatory request;
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of CapitalSpace, our customers, or others.
Data processing and GDPR
CapitalSpace core offering is the CapitalSpace app, which allows customers to upload and manage their commercial real estate portfolios. Data input into the CapitalSpace app is known as “Platform Data.” Under GDPR, CapitalSpace is a Data Processor of CapitalSpace Platform Data. Users of the CapitalSpace Platform are the Controllers of Platform Data. They are responsible for all Controller obligations, such as choosing the appropriate legal basis for collecting and using tenants’ data.
Data controlling and GDPR
CapitalSpace collects, stores, and processes business contact data (used for direct marketing, demonstrations, and business development) and user usage data (used for internal analytics, user experience tracking, and marketing purposes.) Under GDPR, CapitalSpace is a Data Controller with regard to business contact data and usage data. CapitalSpace obtains business contact data on the basis of your consent (where you affirmatively provide it to CapitalSpace, for example, when requesting a product demonstration) or for CapitalSpace legitimate interest in responding to your queries, assisting you in your use of the CapitalSpace Properties, and otherwise communicating with CapitalSpace users, customers, and potential customers. User usage data is obtained for CapitalSpace legitimate interest in providing customer support, improving the CapitalSpace Properties, and communicating with CapitalSpace customers or potential customers. Individuals can opt out of using business contact data at any time by making a request to [email protected]. User usage data is a part of the CapitalSpace platform. Therefore, when an individual would like to opt out of the collection of usage data, the individual will no longer be able to use the CapitalSpace platform.
Accessing, correcting your information and exercising GDPR data rights
CapitalSpaceoperations are based in the United States, which is the geographic location for all CapitalSpace data processing.
You can review and change your personal information by logging into CapitalSpace Property and visiting your account profile page.
You may also send us an email at [email protected] to request access to, correct, or delete any personal information that you have provided to us or request execution of the following rights:
- Receive a copy of your personal data;
- Correction of your personal data;
- Deletion of all of your personal data;
- Restricting or ending the use or processing of your personal data for a particular purpose;
- Obtaining a copy of your personal data in a machine-readable ‘open format’ (e.g., XML, JSON, CSV, text file format);
- Opt out of automated decision-making.
CapitalSpace cannot delete all of your Personal Data except by deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. Suppose you do not opt to have your data deleted. In that case, CapitalSpace may retain your Personal Data only for so long as we have a legitimate business purpose to use that data, but in no event longer than seven years from your last interaction with CapitalSpace.
Third-Party data controllers
We may only transfer Personal Data to unaffiliated third-party data controllers when you have opted-in to that transfer. These third parties do not act as agents or service providers and are not performing functions on our behalf. We will enter into written contracts with any unaffiliated third-party data controllers requiring them to provide the same level of protection for Personal Data as we do. We will also limit their use of your Personal Data so that it is consistent with any consent you have provided and with the notices you have received. If we transfer your Personal Data to one of our affiliated entities within our corporate group, we will ensure that your Personal Data does not receive any less protection.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted.
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 a CapitalSpace site, 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 is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to CapitalSpace over the internet. Any transmission of personal information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on CapitalSpace site.
Questions or complaints
You can direct any questions or complaints about the use or disclosure of your Personal Data to us at [email protected]. We will investigate and resolve any complaints, disputes, or rights requests regarding the use or disclosure of your Personal Data within thirty (30) days of receiving your inquiry.
CapitalSpace is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
In compliance with the Privacy Shield Principles, CapitalSpace commits to resolving complaints about our collection or use of your personal information. We further commit to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider. Under certain conditions as outlined in Annex I of the Binding Arbitration Mechanism in the Privacy Shield Framework
You may invoke binding arbitration for privacy-related complaints. If you live in the EU or Switzerland and are unsatisfied with the resolution of your complaint, you may contact the EU and Swiss data protection authorities at https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for further information and assistance. The services of JAMS are provided at no cost to you.