Last Updated: April 14, 2023
Capsule Labs, Inc. (“Capsule,” “we,” “us,” or “our”) is a toolkit for transaction signing and permissioning that enables developers to offer safe and intuitive crypto UX. This Privacy Notice is designed to help you understand how we collect, use, process, and share your personal information, and to help you understand and exercise your privacy rights.
This Privacy Notice applies to personal information processed by us, including on our websites, services, and other online or offline offerings (collectively described as the “Services”). Unless specifically described herein, this Privacy Notice does not apply to personal information that our customers provide in using our Services (“Customer Data”), which is instead governed by the customer’s respective privacy policies regarding their collection and use of Customer Data. Our processing of Customer Data is governed by the contracts that we have in place with our customers, not this Privacy Notice. Any questions or requests relating to Customer Data should be directed to the relevant customer’s legal or privacy team.
Changes to our Privacy Notice. We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you to the extent required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use our Services after the new Privacy Notice takes effect.
The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.
A. Personal Information You Provide to Us Directly
We may collect personal information that you provide to us, including the following as applicable:
B. Personal Information Collected Automatically
We may collect personal information automatically when you use our Services.
Our uses of these Technologies fall into the following general categories:
C. Personal Information Collected from Other Sources
Third-Party Services and Sources. We may obtain personal information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect personal information about you from that third-party application that you have made available via your privacy settings.
We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
A. Provide Our Services
We use your information to fulfill our contract with you and provide you with our Services, such as:
B. Administrative Purposes
We use your information for various administrative purposes, such as:
C. With Your Consent
We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
D. Other Purposes
We also use your personal information for other purposes as requested by you or as permitted by applicable law.
We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
A. Disclosures to Provide our Services
The categories of third parties with whom we may share your personal information are described below.
B. Disclosures to Protect Us or Others
We may access, preserve, and disclose any information associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.
Your Privacy Rights. In accordance with applicable law, you may have the right to:
If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. However, we do not warrant or guarantee the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information.
By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.
All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to the United States or other countries that may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of the applicable laws. If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.
We store the personal information we collect as described in this Privacy Notice for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services,resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
Additional Privacy Rights for California Residents
“Sales” of Personal Information under the CCPA. For purposes of the CCPA, Capsule does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
De-Identified Information. If we create or receive de-identified information, we will not attempt to reidentify such information, except to comply with applicable law.
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. To the extent applicable, you can exercise this right by contacting us at the email address listed in Contact Us below with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in Contact Us below.
The Services are not directed to children under 16 (or other age as required by local law), and we do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has used Capsule, you may contact us. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, if applicable.
Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
Supervisory Authority. If your personal information is subject to the applicable data protection laws of the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your personal information violates applicable law.
Capsule is the controller of the personal information we process under this Privacy Notice. If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at hello@usecapsule.com
