Privacy Policy

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Captiva handles two different kinds of personal data, and the law treats them differently. Information about You as a business using Captiva — Your account, Your business details, how You use the app — is data We decide the use of, so We are the controller of it. Information about the people who ring Your business and speak to the AI receptionist is handled on Your instructions, so for that data You are the controller and We are Your processor. The section Your Customers' Data (Call Answering) covers the second kind in full.

Interpretation and Definitions

Interpretation

The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.

• Caller means a person who telephones a Captiva number and speaks with the AI receptionist. A Caller is normally a customer or prospective customer of a business that uses Captiva, not a user of the Service.

• Company (referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy) refers to Captiva LTD.

  The Company is the Data Controller of Personal Data about users of the Service and visitors to the Website. In respect of Caller Data the Company acts as a Data Processor on behalf of the business the Caller contacted, which is the Data Controller of that data.

• Caller Data means the personal data of Callers processed through the Service, including their name, telephone number, the location of the work enquired about, the transcript of the call, and any details of their enquiry.

• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

• Country refers to: United Kingdom

• Data Controller means the person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

• Data Processor means a person which processes Personal Data on behalf of, and on the instructions of, a Data Controller.

• Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.

• Facebook Fan Page is a public profile named Captiva AI specifically created by the Company on the Facebook social network, accessible from https://www.facebook.com/share/18rr7LdCzu/

• GDPR refers to the UK General Data Protection Regulation, read together with the Data Protection Act 2018, and — where it applies to Personal Data of people in the European Economic Area — the EU General Data Protection Regulation. Where this Policy refers to a right or an obligation "under the GDPR", it means the equivalent provision of whichever of those applies to You.

• Personal Data (or "Personal Information") is any information that relates to an identified or identifiable individual.

  For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

  We use "Personal Data" and "Personal Information" interchangeably unless a law uses a specific term.

• Service refers to the Website, the Captiva mobile and web application, and the Captiva call-answering service.

• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purposes of the GDPR, Service Providers are considered Data Processors (or, in respect of Caller Data, sub-processors).

• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

• Website refers to Captiva, accessible from https://www.captiva.uk.

• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

  Under GDPR, You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number, including the mobile We send notifications to and any of Your own business numbers that forward calls to Captiva
• The details You give Us about Your business so the AI receptionist can speak on Your behalf — business name, trading address and service area, opening hours, the services You offer, and, where You switch it on, Your price guide
• If You register interest in Captiva before signing up: Your business name, email address, phone number, website address and how You heard about Us
• If You try the voice demo on Our Website: the details described under The voice demo on Our Website

We do not ask for, receive or store Your payment card details — see Payments.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device's unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit Our Service or when You access the Service by or through a mobile device.

Diagnostic reports from the app

When the Captiva app cannot reach Our servers, it queues a short failure report and sends it the next time it gets through. The report says which request failed and when, and identifies the device and app version (for example the platform, operating system, device model, the name You have given the handset, the app build, and the IP address the report arrived from). It is emailed to Our own support address so We can see faults that would otherwise be invisible to Us — an owner cut off from the Service cannot tell Us about it from inside the Service. These reports do not contain enquiry details or call transcripts.

Tracking Technologies and Cookies

We use Cookies and similar technologies to operate Our Service and store certain information. We do not currently use any third-party analytics, advertising, or remarketing trackers on the Website. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.

We do not use web beacons, tracking pixels or similar technologies in Our emails, and We do not track whether You have opened an email We send You.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

Where required by law, we use non-essential cookies (such as analytics, advertising, and remarketing cookies) only with Your consent. We do not currently set any such cookies. If that changes, they will be set only after You consent through Our cookie banner, and You can withdraw or change Your consent at any time using Our cookie preferences tool or through Your browser/device settings. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.

We use both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies

  Type: Session Cookies

  Administered by: Us

  Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

• Cookies Policy / Notice Acceptance Cookies

  Type: Persistent Cookies

  Administered by: Us

  Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

• Functionality Cookies

  Type: Persistent Cookies

  Administered by: Us

  Purpose: These Cookies allow Us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookie Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.

• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

• To operate the AI receptionist on Your behalf: the business details You give Us are used to build the assistant that answers Your calls, and to deliver the resulting enquiries to You.

• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

• To provide You with news, special offers, and general information about other goods, services and events which We offer that are similar to those that you have already purchased or inquired about unless You have opted not to receive such information.

• To manage Your requests: To attend and manage Your requests to Us.

• To keep the Service working and honest: to monitor faults and delivery failures, to check the quality of what the AI captured, to prevent abuse of the Service, and to account for what each call costs Us.

• For business transfers: We may use Your Personal Data to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, and evaluating and improving our Service, products, marketing and your experience.

We may share Your Personal Data in the following situations:

• With Service Providers: We may share Your Personal Data with the Service Providers listed under Service Providers We Use, so that they can perform the part of the Service We use them for — running calls, sending texts and emails, hosting Our systems, delivering notifications and, in future, processing payments.
• For business transfers: We may share or transfer Your Personal Data in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Your consent: We may disclose Your Personal Data for any other purpose with Your consent.

We do not sell Personal Data. We do not share it with advertising networks, data brokers or "business partners" for their own marketing, and the Service has no public areas in which what You enter is visible to other users.

Legal Bases for Processing

Under the GDPR We must have a lawful basis for each thing We do with Your Personal Data. Ours are:

• Performance of a contract — creating and running Your Account, answering Your calls, delivering enquiries to You, sending You service messages about Your Account, and taking payment for the Service.
• Legitimate interests — keeping the Service secure and available (fault reports, server logs, delivery monitoring, rate limiting and anti-abuse measures), checking the quality of what the AI captured, accounting for the cost of calls, and marketing Our own similar services to existing customers. We balance these against Your interests, and You can object at any time.
• Consent — non-essential cookies (if We ever set any), marketing to people who are not yet customers, and the voice demo, which You start yourself. You can withdraw consent at any time.
• Legal obligation — keeping accounting and tax records, and responding to lawful requests from public authorities.
• Vital interests — only in the rare case where processing is needed to protect someone's life or safety.

Caller Data is processed on the instructions of the business the Caller contacted; that business is responsible for having a lawful basis for it.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if We are required to retain Your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Where possible, We apply shorter retention periods and/or reduce identifiability by deleting, aggregating, or anonymizing data. Unless otherwise stated, the retention periods below are maximum periods ("up to") and We may delete or anonymize data sooner when it is no longer needed for the relevant purpose. We apply different retention periods to different categories of Personal Data based on the purpose of processing and legal obligations:

• Account Information

  • Your Account, business profile, settings and price guide: kept while Your Account is open. When You delete Your Account, they are deleted straight away, along with Your login — not held for a further period. See Delete Your Personal Data.
  • Registered notification devices: kept while the device is registered, and deleted with Your Account.

• Enquiries and Calls

  • Captured enquiries and call transcripts: kept while Your Account is open so You can work Your leads, and deleted when You delete the enquiry, when Your Account is deleted, or on request.
  • Records of texts We sent (the number texted and whether it was delivered): kept while Your Account is open, and deleted with Your Account. The number is removed from the record as soon as the enquiry it relates to is deleted; We keep the anonymous fact that a text was sent and whether it arrived, so a delivery failure does not disappear from Our monitoring.
  • Call metering records — the length and cost of each call, which contain no Caller name, number or enquiry details: kept for up to 6 years for accounting purposes.

• Prospects and Enquiries to Us

  • Register-interest details and demo enquiries: up to 24 months from Our last contact with You, unless You become a customer or ask Us to delete them sooner.
  • Demo verification codes: 10 minutes, after which they expire and are discarded.
  • Support correspondence: up to 24 months from the date the matter was closed, to handle follow-up questions and defend against potential legal claims.

• Usage Data

  • Server logs (IP addresses, access times): up to 24 months for security monitoring and troubleshooting purposes.
  • Diagnostic reports from the app: up to 24 months.

• Financial and Transaction Data

  • Payment information: credit/debit card details are not stored on Our servers; they are processed by our Payment Service Providers. We retain transaction records (invoice details, purchase history, amounts) for up to 6 years from the end of the financial year they relate to, as required by UK tax and company law.
  • Billing and invoice records: up to 6 years, to meet accounting and tax compliance requirements.

Usage Data is retained in accordance with the retention periods described above, and may be retained longer only where necessary for security, fraud prevention, or legal compliance.

Our Service Providers keep their own copies of the data they handle for Us, for their own retention periods — for example, the platform that runs the live call holds the call and its transcript for a short window (around 14 days) so faults can be investigated, and Our telephony provider keeps records of calls and texts it carried. Deleting data from Our systems does not by itself erase those copies, though We will pass on a deletion request where a provider supports one.

We may retain Personal Data beyond the periods stated above for different reasons:

• Legal obligation: We are required by law to retain specific data (e.g., financial records for tax authorities).
• Legal claims: Data is necessary to establish, exercise, or defend legal claims.
• Your explicit request: You ask Us to retain specific information.
• Technical limitations: Data exists in backup systems that are scheduled for routine deletion.

You may request information about how long We will retain Your Personal Data by contacting Us.

When retention periods expire, We securely delete or anonymize Personal Data according to the following procedures:

• Deletion: Personal Data is removed from Our systems and no longer actively processed.
• Backup retention: Residual copies may remain in encrypted backups for a limited period consistent with our hosting providers' backup schedules, and are not restored except where necessary for security, disaster recovery, or legal compliance.
• Anonymization: In some cases, We convert Personal Data into anonymous statistical data that cannot be linked back to You. This anonymized data may be retained indefinitely for research and analytics.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from Your jurisdiction.

Where required by applicable law, We will ensure that international transfers of Your Personal Data are subject to appropriate safeguards and supplementary measures where appropriate. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

You may update Your business details at any time by signing in to Your Account and visiting the settings section.

You can delete Your Account yourself, from inside the Captiva app: go to Settings → Your account → Delete account, confirm, and type Your business name. Deletion happens immediately and cannot be undone. It removes Your business profile and settings, every captured enquiry and call transcript (including Your Callers' details), Your registered notification devices and text records, and Your login.

You can also ask Us to access, correct, export or delete any Personal Data We hold about You — including deleting Your Account — by contacting Us at hello@captiva.uk, and We will action Your request. You do not need the app to do this.

For a step-by-step guide to deleting Your Account — from the app or by email — see Delete your account.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so — for example the accounting records described under Retention of Your Personal Data, and copies held by Our Service Providers for their own retention periods.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially reasonable means to protect Your Personal Data, We cannot guarantee its absolute security.

The measures We take include: encrypting data in transit and at rest; holding Your data in a managed database that is not exposed to the public internet; requiring authentication for every request the app or dashboard makes; limiting access to live data to the Captiva personnel who need it to run and support the Service; and choosing established providers for the parts of the Service We do not run Ourselves.

If a personal data breach occurs, We will notify the Information Commissioner's Office within 72 hours where the law requires it, and We will tell You without undue delay where the breach is likely to result in a high risk to Your rights and freedoms. Where the breach affects Caller Data, We will notify the affected business without undue delay so that it can meet its own obligations as controller.

Your Customers' Data (Call Answering)

Captiva answers phone calls on behalf of the businesses that use Our Service. This section explains how We handle the personal data of the people who call those businesses ("Callers"). It applies both to You as a business using Captiva, and to You if You have called a business whose calls We answer.

What We collect from Callers

When Our AI assistant answers a call, it may collect the details needed to pass the enquiry to the business:

• The Caller's name
• The Caller's phone number (caller ID) and any callback number they provide
• The location or postcode where work is needed (only where the business travels to the customer)
• A description of the enquiry, and a written transcript of the conversation
• Whether the AI quoted a price on the call, where the business has switched price quoting on
• The date, time and length of the call, and the Captiva number that was dialled

From those details We also derive, and store alongside the enquiry:

• A category for the job (for example emergency, repair, installation, quote)
• How urgent the job appears, and a one-line reason for that rating
• A rough, best-effort estimate of what the job might be worth, based on typical pricing for that kind of work
• A score for how complete the captured details are, with short notes on anything missing
• Whether the Caller has rung the same business before, and whether this call is about the same job as a previous one

The business the Caller rang can also add its own notes to an enquiry as it follows the job up.

Calls are not audio-recorded. We keep a written transcript of the conversation instead; no recording of the Caller's voice is stored by Us.

How AI is used, and what We do not do with it

The conversation is held by an AI assistant, and the transcript is then processed by AI models to extract the enquiry details, categorise the job, judge how urgent it appears and estimate its rough value, so the business can respond appropriately. These are inferences made by software, and they may be wrong; they are there to help the business prioritise, and a person decides what to do about every enquiry. No decision with a legal or similarly significant effect on a Caller is made automatically.

Neither We nor Our AI providers use call transcripts, enquiry details or Your business data to train AI models. The models We use are accessed as a service on a basis that excludes training on the data We send.

How Caller data is used and shared

Caller data is used solely to deliver the enquiry to the business that was called — by push notification to the business's registered devices, and in that business's Captiva account — and, where enabled, to send the Caller a confirmation text and to recognise a returning Caller so they are not asked for the same details twice. We process Caller data on behalf of the business the Caller contacted; that business controls its own customer enquiries.

The push notification that tells the business about a new enquiry contains the Caller's name, what they need and roughly where, so it is readable on a phone's lock screen. It is delivered through Our notification provider and through Apple's or Google's push service, depending on the handset.

Captiva staff can see the enquiries and transcripts held in a business's account, in order to support that business, investigate a fault or check the quality of what the AI captured. Where an enquiry was captured poorly — for example no callback number was taken — a copy of the captured details may be sent to Our own support inbox so the problem can be looked into and fixed.

Caller data is never sold, never used for advertising or profiling for marketing purposes, and is shared only with the Service Providers needed to operate the call (listed under Service Providers We Use).

Where Caller data is stored and for how long

Enquiry details and transcripts are stored in Our database hosted in the European Union (Frankfurt, Germany), and Our application servers are hosted in the same region. Delivering the live call involves the specialist providers listed below, some of whom process data outside the UK/EEA; the International Transfer of Personal Data section describes the safeguards applied. Those providers also hold their own copies for their own retention periods — the platform that runs the call holds the call and transcript for roughly 14 days, and Our telephony provider keeps its own records of the calls and texts it carried.

Caller data is retained while the relevant business's account remains active so the business can manage its enquiries, and is deleted when the business deletes the enquiry, when the business's account is deleted, or on request.

If You have called a business that uses Captiva and would like Your details corrected or deleted, You can contact the business You called, or contact Us directly at hello@captiva.uk. Because We hold that data on the business's behalf, We will normally pass Your request to them and act on their instructions, and We will help them respond to You.

The voice demo on Our Website

Our Website offers a live voice demo, so a tradesperson can hear their own AI receptionist before signing up. The demo only runs if You start it.

To start it You give Us Your email address and mobile number, and details of the business You want the demo to imitate — its name, Your name, Your trade, the services You offer, Your website address, and anything else You choose to add. We email You a six-digit code, which You enter to begin; this exists to stop the demo (which costs Us money per minute) being abused.

During the demo Your browser connects directly to Our voice platform and Your microphone audio is streamed to it, where it is transcribed, answered by an AI model and spoken back to You. When the call ends, the transcript is sent to Our server once so it can be summarised into the "lead" card the Website shows You. We do not store the demo call or its transcript in Our database; the voice platform holds it for roughly 14 days. The details You entered, and the fact You tried the demo, are emailed to Us as a sales enquiry and kept as described under Retention of Your Personal Data.

If You enter a website address anywhere on Our Website so We can look at it and pre-fill Your business details, We fetch and read that page. We do not fetch anything else from Your Device.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Service Providers We Use

We use the following Service Providers to operate the Service. Where a provider processes Personal Data outside the UK and EEA, the safeguards described under International Transfer of Personal Data apply.

• Vapi — voice-call platform that runs the live AI phone call and the Website voice demo. Processes data outside the UK/EEA (United States). https://vapi.ai
• Anthropic — AI language model that holds the conversation and summarises enquiries. Processes data outside the UK/EEA (United States). https://www.anthropic.com/legal/privacy
• Deepgram — speech-to-text used to transcribe calls. Processes data outside the UK/EEA (United States). https://deepgram.com
• ElevenLabs — voice synthesis for the assistant's voice. Processes data outside the UK/EEA (United States). https://elevenlabs.io
• Twilio — phone numbers, call routing and SMS delivery. Processes data outside the UK/EEA (United States). https://www.twilio.com/en-us/legal/privacy
• Supabase — database, account authentication and email functions. Our database is hosted in the EU (Frankfurt, Germany); the provider is US-based. https://supabase.com/privacy
• Render — application hosting. Our servers are hosted in the EU (Frankfurt, Germany); the provider is US-based. https://render.com/privacy
• Vercel — website hosting. Processes data outside the UK/EEA (United States). https://vercel.com/legal/privacy-policy
• Resend — transactional email delivery. Processes data outside the UK/EEA (United States). https://resend.com/legal/privacy-policy
• Expo — mobile push notifications. Processes data outside the UK/EEA (United States). https://expo.dev/privacy
• Apple and Google — the push notification services that deliver notifications to iPhone and Android handsets. https://www.apple.com/uk/legal/privacy/ · https://policies.google.com/privacy
• CookieYes — cookie consent management on the Website. https://www.cookieyes.com/privacy-policy/
• Stripe — payment processing, when We take payment for the Service. Processes data outside the UK/EEA (United States). https://stripe.com/gb/privacy

Businesses using Captiva can ask Us at any time for the current list of sub-processors used to deliver the Service.

Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

• Stripe

  Their Privacy Policy can be viewed at https://stripe.com/gb/privacy

Your Data Protection Rights

International Transfer of Personal Data

We may transfer, store, and process Personal Data in countries other than the country in which You are located, including countries outside the European Economic Area ("EEA") and the United Kingdom ("UK"), where data protection laws may differ. The Service Providers We Use section says which of Our providers process data outside the UK and EEA.

Where we transfer Personal Data outside the EEA/UK to a country that has not been recognized as providing an adequate level of protection, We rely on appropriate safeguards, such as:

• The European Commission's Standard Contractual Clauses ("SCCs") and/or the UK International Data Transfer Agreement ("IDTA") or the UK Addendum to the SCCs (as applicable)
• Supplementary measures where appropriate, such as encryption in transit and at rest, access controls, data minimisation, and vendor security reviews.

We transfer Personal Data internationally only as needed to provide the Service and to work with our Service Providers (for example, running calls, hosting and email delivery). You may contact Us using the details in the Contact Us section of Our Privacy Policy to request further information about the safeguards We use for international transfers, including copies of relevant contractual protections (redacted where necessary).

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law, to:

• Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your Account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
• Request restriction of processing. You have the right to ask Us to restrict processing of Your Personal Data in certain circumstances (for example, while We verify accuracy or consider an objection).
• Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
• Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
• Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

If You are a Caller rather than a Captiva customer, these rights are exercised against the business You rang, which controls Your enquiry. Contact them, or contact Us and We will pass Your request on and help them answer it.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible. We generally respond within one month, and may extend by two further months where necessary, in accordance with applicable law.

You have the right to complain to a data protection authority about Our collection and use of Your Personal Data. In the United Kingdom this is the Information Commissioner's Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF — telephone 0303 123 1113, https://ico.org.uk/make-a-complaint/. If You are in the European Economic Area, You may instead complain to Your local data protection authority. We would appreciate the chance to deal with Your concerns first, so please do contact Us before You do.

Facebook Fan Page

Data Controller for the Facebook Fan Page

The Company is the Data Controller of Your Personal Data collected while using the Service. As operator of the Facebook Fan Page https://www.facebook.com/share/18rr7LdCzu/, the Company and the operator of the social network Facebook are Joint Controllers.

The Company has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php

Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information about how Facebook manages Personal Data or contact Facebook online, or by mail: Meta Platforms, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

Facebook Insights

We use the Facebook Insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about Our users.

For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.

Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.

For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/privacy/explanation

Children's Privacy

Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 16 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, or wish to exercise any of Your rights, You can contact us:

• By email: hello@captiva.uk