Introduction

Welcome! You have arrived at a website or mobile application operated by Coughlan Companies, LLC or Capstone Global Ltd. (collectively, “Capstone,” “we”, “our” or “us”).

Capstone is the nation’s leading educational publisher for digital solutions, children’s books, and literacy programs for school libraries and classrooms! Home of award-winning content platforms and easy-to-use creation tools, Capstone has a passion for creating inspired learning and intellectual curiosity in children.

At Capstone, we take your privacy and the privacy of your students very seriously. This Privacy Notice (“Notice”) describes the types of personal information (as defined below) that we collect in our Products (defined below), how we use it, how and when we share it, and the rights you have with respect to your information. It also explains how we communicate with you and how you can make inquiries and requests to us about your information. We strive to help you understand how we use your information to improve our products, services, marketing, and interactions with you, as part of our commitment to maintaining your trust.
 

Scope                                                                                                                                              

This Notice applies when you use the products PebbleGo (Including Add-Ons), Capstone Interactive, Capstone Connect, PebbleGo Create, Buncee, Raintree (Including Raintree Online and Engage Literacy), No Nonsense Literacy and other Capstone products (“Products”), via the websites, www.PebbleGo.com, www.mycapstonelibrary.com, www.buncee.com, www.online.raintree.co.uk, www.nononsenseliteracy.co.uk and their subdomains or portals (the “Sites”); our mobile applications (“Apps”); or otherwise provide Personal Information or interact with us online or in-person in connection with your use of such Products. We also support our Products by providing various “Services” such as customer support. By using our Products and Services, you agree to this Notice and our Product End User License Agreement. For the purpose of this Notice, "Personal Information" means any personal information relating to an identified or identifiable individual.

For the Privacy Notice for the Capstone Publishing, Capstone online store, or Raintree online store websites, please visit here. 

If you have any questions about this Privacy Notice, please contact us at privacy@capstonepub.com.
 

Children’s Privacy Policy

On select Products, Capstone collects a limited amount of Personal Information from children that is necessary for the Products to work. For more information about our practices regarding children’s Personal Information, please read our Children’s Privacy Policy.
 

What Information We Collect

In connection with your use of our Products or Services, we may collect information, including Personal Information, from you where you expressly provide us with the information and as you use and navigate through our Products and Services.  On occasion, we may obtain personal information about you from third parties. Examples of sources from which we collect information include information provided in our Products, via online chat or support services, web forms or inputs/uploads into our Products, telephone calls with you, letters, e-mails or other communications from you, documents you have provided to us, or references and referrals provided to us in connection with your electing to list as a service provider with us. This section describes the information we collect about you in connection with our Products and Services. 
 

Information That You Provide to Us

We collect the following categories of Personal Information.
 

Buncee

• Account and contact information. When you register an account to become a user of Buncee's Services, such as your name, email, birthdate, username and a password.
  • Under a Buncee Classroom subscription, student accounts can only be created by subscribers of the Buncee Classroom plan, and do not require the submission of email, gender or birth data.
  • Under a Buncee Schools & Districts subscription, educator and student accounts are created by syncing Google Classroom roster data with Buncee, by syncing Microsoft Office 365 roster data with Buncee, or by manual upload via CSV.
  • Free and Premium Buncee accounts require parent/guardian permission for those under 13 years of age under COPPA, or under 16 years of age under GDPR, to hold an account, and submission of any personally identifiable information such as contact information, gender or birth data is not required.
• Financial information. We collect information relating to your purchase, including your credit card or debit card number, bank account information and your payment, service and purchase history.
• Marketing information.  If you sign up to receive marketing communications from us or interact with our products and/or services, we collect the details regarding informational and promotional materials you may have requested or received from us, the services in which you are interested, your receipt of promotional communications, and information on your marketing or communication preferences.
• Classroom, school or district information. We collect information such as building address, district name, and administrative contact email address(es) and phone number(s).
• Communications information.  We collect copies of, and details regarding, communications and inquiries you have made to us, including when you communicate with us via telephone, email, through online chat or support services, web forms, or other inputs/uploads to our site.
   

PebbleGo Create with Buncee

• Account and contact information. When you register an account to become a user of Buncee's Services, such as your name, email, birthdate, username and a password.
  • Educator and student accounts are created by syncing Google Classroom roster data with PebbleGo Create, by syncing Microsoft Office 365 roster data with PebbleGo Create, or by manual upload via CSV.
• Financial information. We collect information relating to your purchase, including your credit card or debit card number, bank account information and your payment, service and purchase history.
• Marketing information.  If you sign up to receive marketing communications from us or interact with our products and/or services, we collect the details regarding informational and promotional materials you may have requested or received from us, the services in which you are interested, your receipt of promotional communications, and information on your marketing or communication preferences.
• Classroom, school or district information. We collect information such as building address, district name, and administrative contact email address(es) and phone number(s).
• Communications information.  We collect copies of, and details regarding, communications and inquiries you have made to us, including when you communicate with us via telephone, email, through online chat or support services, web forms, or other inputs/uploads to our site.
   

PebbleGo (Including Add-Ons), Capstone Interactive, Capstone Connect, Raintree (Including Raintree Online and Engage Literacy), and No Nonsense Literacy

• Account and contact information. We collect contact information such as your first and last name, email address, home or business address, shipping address, telephone numbers, mobile numbers.

• Financial information. We collect information such as your credit card or debit card number, bank account information and your payment, service and purchase history.
• Marketing information.  If you sign up to receive marketing communications from us or interact with our products and/or services, we collect the details regarding informational and promotional materials you may have requested or received from us, the services in which you are interested, your receipt of promotional communications, and information on your marketing or communication preferences.
• Classroom, school or district information. We collect information such as building address, district name, and administrative contact email address(es) and phone number(s).
• Communications information.  We collect copies of, and details regarding, communications and inquiries you have made to us, including when you communicate with us via telephone, email, through online chat or support services, web forms, or other inputs/uploads to our site.

Your decision to provide us with Personal Information is voluntary, but if you choose not to provide any requested information, you may not be able to take advantage of all the features of the Products or Services. 
 

User Content

The Buncee and PebbleGo Create Products allow users to submit, transmit, share, create, or post information. Such information may include personal information, such as photographs, video or audio files, or recordings of an individual’s voice. While this information may be submitted by a user to the Product, Capstone does not specifically collect this information about any user. Further, Capstone does not decide or control how any user-submitted information is used, published, or shared by users.
 

Information That Is Automatically Collected

Like many businesses, we and/or our service providers may automatically collect and/or store certain information when you use our Products and Services (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you use our Products or Services. Usage Information may include:

• Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;
• Your Device functionality (including browser, browser language, settings and behavior, operating system, hardware, mobile network information);
• Referring and exit web pages and URLs;
• The areas within the Products that you visit and your activities there, including remembering you and your preferences;
• Your Device characteristics;
• Certain other Device data, including the time of day you use our Products or other information used to provide analytics or other usage information;
• Information about your engagement with our emails; and
• Statistical information about how both unregistered and registered users, collectively, use the Products and Services. This aggregate information is derived from Personal Information but cannot be tied back to you or your web browser.

If you no longer wish for us or our service providers to collect and use the information described above, you may disable certain features on your Device. Consult your Device manufacturer settings for instructions. Please note that if you disable such features, your ability to access certain features on our Products and Services may be limited or disabled.
 

Information Collected Through Social Media

If you interact with Capstone or our other users regarding Capstone and its Products on any social media platform: (a) depending on your social media privacy settings, the personal information that you submit on the social media platform may be read, collected, or used by us as described in this Policy, and (b) where Capstone responds to any interaction with you on social media, your account name/handle may be viewable by any and all members or users of our social media accounts.  Social media platforms operate independently from Capstone and we are not responsible for the personal information that you choose to submit or link on any Social Media.  We encourage you to review the privacy policies and settings of any social media platform with which you interact to help you understand their privacy practices.
 

Information Collected from Third Parties

The Products may include functionality that permits certain kinds of interactions between the Products and your account on a third-party website or application, which may result in the third-party site providing information about you to us. For example, we might obtain information about the traffic and usage of our Products from third parties or we may use third parties to facilitate emails or postings to social media (like a “Share” or “Forward” button). These third parties use cookies and other tracking technologies to capture information about your interactions with our products. Our products do not have control over the information that is collected, used, and shared by these third parties. We encourage you to review the privacy statements of these third parties to understand their privacy practices.

We may also obtain information about you from our authorized sales representatives and resellers, business partners, contractors, suppliers, and other third parties and add it to your account information or other information we have collected.  We, and the third parties we engage, may combine information we collect from you over time, and across the Sites, with information obtained from other sources.  This helps us improve the information’s overall accuracy and completeness, and also helps us better tailor our interactions with you.
 

How We Use Your Information

We (and service providers acting on our behalf) use your information for the following purposes:
 

To Verify Your Age

We ask you to provide your date of birth and/or verify your age prior to entering PebbleGo Create and Buncee Products.
 

To Provide Our Services

When you use our Products or Services, we use your personal information to:

• provide educational services and content;
• register and verify user accounts;
• support and improve our Capstone Rewards loyalty program (for more information about the Capstone Rewards program, please see Notice of Financial Incentives section below or visit here); 
• facilitate the functionality of our Products, including any payments made via your Buncee, Raintree, or No Nonsense Literacy account;
• process your purchases of, distribution of, or requests for, products and Services;
• customize experiences and personalization when you are using our Products;
• deliver services you’ve requested, which include the interaction, communication, creation and sharing within the classroom/school/district account. The data is necessary to provide the administrator-educator-student hierarchy within the account;
• allow subscribers to create and manage classes, personalize and differentiate instruction, and monitor and assess student progress;
• allow subscribers to monitor and safeguard student welfare; and
• allow subscribers to set creation and sharing permissions and privacies schoolwide.
   

To Communicate with You

We process personal information in order to communicate with you in relation to your accounts, our services, our marketing, and your requests to:

• inform subscribers about feature updates, site maintenance, and programs/initiatives (does not include subaccounts);
• communicate with you about orders, purchases, returns, Services, accounts, programs, contests, and sweepstakes;
• respond to your customer service inquiries and requests for information;
• post your comments or statements on our websites;
• send you promotions, content, special offers, and other marketing communications;
• communicate with you about our brands, Products, events, or other promotional purposes;
• implement your communications preferences, such as sharing information with our business partners so that they may email you about their promotions, products and initiatives;
• provide important Product safety information and notice of product recalls; and
• notify you about changes to our website, Services, products, or material changes to this Policy.
   

For Research, Development, and Improvement of Our Products and Services

We want to ensure that our Products and Services are continually improving and expanding so that we meet and exceed your needs and expectations. To do so, we may process certain personal information to:

• maintain, improve, and analyze the Products we offer; and
• detect, prevent, or investigate suspicious activity or fraud.
   

To Enforce our Terms, Agreements, or Policies

To maintain a safe, secure, and trusted environment for you when you use our Products and Services, we use your personal information to ensure our terms, policies, and agreements with you and any third parties are enforced.
 

To Comply with Applicable Laws

We may be required to process certain personal information under certain laws and regulations, such as tax laws, as well as to:

• maintain appropriate records for internal administrative purposes; and
• comply with applicable legal and regulatory obligations, and respond to lawful subpoenas or governmental requests, as needed.
   

With Your Consent

We may process certain personal information in order to fulfill any other business or commercial purposes described to you at the time we collect personal information from you, at your direction, or with your consent.
 

Use of Cookies

We use cookies and other tracking technologies to personalize your experience, analyze user trends, and improve the Products and Services. These tracking technologies allow us to collect information such as your Device type, browser type, interactions with our Products or Services, geographic location, your web request, the date and time of your web request, your Internet Protocol address, the domain name of your Internet service provider and other data. If you can be identified from this information, for example by combination with other pieces of information, then we will treat this information as Personal Information.

You can alter the configuration of your browser or Device to refuse to accept cookies, but it is possible that doing so may cause limited functionality of the Products. For example, we use cookies to track user sessions across multiple application components. These cookies are required for the application to function correctly. Without these cookies a user would be asked to login again each time they moved from one part of the application to another.

We or our service providers and vendors may use “cookies” (a small text file sent by your computer each time you visit use our Products or Services) or similar technologies to record log data. Many browsers default to accepting cookies. You may be able to change this setting in your browser and you can also clear your cookies. If you do, you may lose some functionality of our site. Check your browser’s help function to learn more about your cookie setting options.

We may use the following types of cookies in connection with our Products and Services.  Other than “strictly necessary” cookies, we will only place these cookies on your Device where you have consented to us doing so (except where otherwise permitted by law).  Note some of the cookies described below are temporary and deleted as soon as you close your browser.  These are known as “session cookies.”  Other cookies are stored on your Device until they expire or you remove them.  These are known as “persistent cookies.”

• Strictly necessary cookies. These cookies are essential for you to browse the website and use its features, such as accessing secure areas of the site. Cookies that allow web shops to hold your items in your cart while you are shopping online are an example of strictly necessary cookies. These cookies cannot be turned off are usually only set in response to specific actions you take on the site.
• Functionality cookies. Also known as “preference cookies,” these cookies allow a website to remember choices you have made in the past, like what language you prefer, what region you would like weather reports for, or what your username and password are so you can automatically log in.  These cookies may be set by us or third-party providers whose services we have added to our Products or Services.  Disabling these cookies may result in some aspects of the Products or Services not displaying of functioning properly.
• Analytics cookies. Also known as “performance cookies,” these cookies collect information about how you use our Sites, like which pages you visited and which links you clicked on. None of this information can be used to identify you. It is all aggregated and, therefore, anonymized. Their sole purpose is to improve website functions. This includes cookies from third-party analytics services as long as the cookies are for the exclusive use of the owner of the website visited.  Disabling these cookies will not allow us to recognize you when you visit our Products or Services. We use Google Analytics, Kibana, and Pendo to help us understand how our customers use the Sites. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
• Advertising cookies. These cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an ad. These cookies can share that information with other organizations or advertisers. These are persistent cookies and typically set by third-party providers.  These cookies are able to identify your browser and Device.  Disabling these cookies may result in less targeted advertising.

We might also use a pixel tag which is a small graphic file that allows us and third parties to monitor the use of the site and provide us with information based on your interaction with the site. These tags may collect the IP address from the Device which you loaded the page, the browser type. Pixel tags are also used by our third parties to collect information when you visit our site, the links and other actions you take on our site, and we may use this information in combination with cookies to display targeted advertisements.

Other data technologies may be used that collect comparable information for security and fraud detection purposes.

For more information about your choices with regards to Cookies, please review the “Your Choices About the Collection and Use of Personal Information” section below.
 

How We Share Your Information

Services Providers

We share your Personal Information with our third-party service providers who provide services that are necessary for our Products and Services, such as website hosting, payment processing, online chat functionality, data analysis, information technology, fulfillment houses, customer service, email delivery, online advertising, auditing and other services.
 

Marketing and Advertising Partners

We share information about your use of our Products and Services, your purchases, and your interaction with our ads on other websites with our marketing and advertising partners that may assist with lead generation, hosting information relating to clients and potential clients, marketing automation, marketing campaigns, or providing you with targeted advertisements or marketing communications. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).
 

Authorized Representatives

We use a network of independent sales representatives and resellers for marketing and sales purposes (“Representative”). We may share your information with these Representatives for the purposes of marketing our products and services, engaging in sales, and otherwise communicating information about our products and services to customers or potential customers.  
 

Other

Aside from the instances described above, we will only share your personal information:

• to comply with the law;
• to respond to claims or comply with legal process served on Capstone (e.g., a lawful subpoena, warrant, or court order);
• to enforce or apply our policies or agreements;
• to protect and defend our rights or property or that of our customers, employees, visitors, or the public;
• in connection with an acquisition, liquidation, divestiture, restructuring, reorganization, dissolution, or merger, or sale or transfer of some or all of our assets (including the negotiation of the same), whether as a going concern or as a part of bankruptcy, liquidation, or a similar proceeding, where the information is among the items being transferred;;
• if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure; and
• to any other parties for any purpose we disclose to you at the time you provide the information or to which you otherwise consent.
   

Third Party Links

The Products may contain links to other websites such as social media platforms, other websites and partner websites. These websites are not covered by this Privacy Notice. Please review the Privacy Notices or Policies of those websites to understand the privacy practices of these third parties. We cannot and do not take responsibility for the content of any linked websites or those companies’ data-handling practices.
 

International Transfers of Personal Information

For customers located outside of the United States, Capstone is headquartered in the United States and the Products are operated from the United States. If you are located in another jurisdiction, please know that your information will be transferred to, stored, and processed in the United States. By using the Products and providing us with information, you consent to the transfer, processing and storage of your information in the United States. It is important to note that the privacy laws in the United States may not be as comprehensive as those in other countries such as those in the European Union (“EU”). When we transfer your personal information from other countries, we will use appropriate safeguards to protect such transfers as may be required by applicable data protection laws.
 

Your Choices About the Collection and Use of Personal Information

We strive to provide you with choices regarding your personal information.  Some choices you have regarding the collection and use of your personal information include the following:

• Marketing Emails: If we ever send you promotional emails, you can stop receiving those emails by clicking the “unsubscribe” link in the email.  We endeavor to promptly process any unsubscribe requests. 
• Communication Preferences: You may change previously expressed preferences regarding how we use your information to communicate with you by accessing your “Account Settings” on our Sites or mobile apps. You can also contact us at privacy@capstonepub.com.
• Do Not Track Signals: Capstone does monitor or take any action with respect to “Do Not Track” signals.
• Cookies: Depending on your browser or device, you may have the option to set the browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies.  Each browser and device are different, so we recommend you evaluate the tools and settings available in your browser or device, as well as any available instructions for the same.  Please note that if you disable or delete cookies, you may not be able to access or use certain features of the Services.
• Analytics: As discussed above, we use Google Analytics and other analytics services, such as Kibana and Pendo, in connection with the Services. You can opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en.
• Personalized or Interest-Based Advertising: To opt-out of personalized or interest-based advertisements, you may be able to adjust the settings on your device.  Please go to your device settings and opt-out through the controls provided through Google/Android or iOS, as applicable. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

            You can opt out of targeted advertising by visiting the following:

• • Facebook - https://www.facebook.com/settings/?tab=ads
  • Google - https://adssettings.google.com
  • Bing - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
• Jurisdiction-specific choices: Choices relating to Data Transfers from the EU, UK, and Switzerland are described in the “Your Rights Under the GDPR” section below. Choices relating to the rights afforded consumers under the California Consumer Privacy Act (CCPA) are described in the “Your California Privacy Rights” section below.

To protect your privacy and security, we may also take reasonable steps to verify your identity before making any changes. Finally, you can also choose not to provide us with information we may request through the Services, but that may result in you being unable to use certain features of our Services.
 

Data Transfers from the EU, UK, and Switzerland

If we transfer personal information from the EU, UK, or Switzerland to the United States or any other country, we will implement appropriate legal mechanisms to ensure an adequate level of personal data protection consistent with the GDPR’s requirements.  For example, if the recipient country has not received an Adequacy Decision from the EU (such as the United States), we will rely on European Commission’s Standard Contractual Clauses (SCCs) as the lawful mechanisms for such transfers.  Further, we will enter into appropriate data processing agreements with all non-EU (sub)processors which contain SCCs and define security standards to be employed by each (sub)processors.
 

Security

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information. Such measures may include, without limitation, taking reasonable steps to ensure the reliability of employees or service providers having access to your data; limited access rights and access controls; security and privacy training for employees; appropriate data backup, recovery, and incident management procedures; and software protection of Devices on which personal data are stored.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. Where we have given you (or where you have chosen) a password so that you can access certain areas of our site, you are responsible for keeping this password confidential. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us at privacy@capstonepub.com.
 

Your Rights Under the General Data Protection Regulation

This section of our Privacy Notice applies if you are a data subject in the European Economic Area (“EEA”), UK, or Switzerland. We adopted this Policy to comply the General Data Protection Regulation (“GDPR”), as adopted and applied in the EEA, UK, and Switzerland. Any terms defined in the GDPR have the same meaning when used in this Section. Capstone is the data controller for processing Personal Information provided to us through the Products.

We hope to ensure that the Personal Information we possess are always accurate and therefore we encourage you to update your information in your own account in case any changes have occurred. We have listed below the rights that you may be able to exercise in respect of the processing of your Personal Information, subject to applicable law. We take every reasonable step to ensure that the Personal Information that we process are limited to the Personal Information that are reasonably required in connection with the purposes set out in this Privacy Notice.

If you are a resident of or located within the EEAUK, or Switzerland, you have the following rights under the GDPR:

• 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 Information by contacting us at the contact information below.
• The right of rectification. You have the right to correct any inaccuracies in the personal information we process about you.
• The right to object. You have the right to object to our processing of your Personal Information.
• The right of restriction. You have the right to request that we restrict the processing of your Personal Information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your Personal Information.
   

Legal Basis for Processing Personal Information

We rely on the following legal bases for processing your Personal Information:

• Processing of your Personal Information that you provide to us when you interact with our Services, such commenting in our community blog, watching our videos or making a purchase, is necessary to respond to or implement your request prior to entering into a contract with us.
• We use account-related data to set up accounts for users in our platform and to administer and support those accounts (such as usernames, email address and billing information), provide you with access to the Products and Services, contact you regarding your use of the Products or Services or to notify you of important changes to the Products or Services. Such use is necessary for the performance of the contract between you and us.
• We will send you information by email on our new services or other promotions only with your consent or if you otherwise opt-in to receiving those communications. If you do not provide us with your consent to the processing of your Personal Information for this purpose, we will not send you this information. You have the right to withdraw your consent at any time as described below. In addition, we use information received for our legitimate interest in monitoring the efficacy of our marketing efforts, respond to inquiries about our business and services, and promote our service offerings. 
• Our use of data relating to your use of the Products and Services, described above, is necessary for the following legitimate interests:
  • Understanding how the Products and Services are being used by you
  • Improving your experience on our Products and Services offerings
  • For Buncee, confirming the identity of students and educators/administrators.
  • To detect and prevent potential security issues in connection with our Products.
  • Aggregating and/or anonymizing the information that we collect through our Products or Services and using this information for our business purposes, as described above.
• When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Information for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests, as further described below.
   

Retention of Personal Information

Capstone will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Notice. The criteria used to determine our retention periods include (i) the length of our ongoing relationship with a particular customer or visitor to the Sites, (ii) the period of time necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), and (iii) the length necessary to resolve disputes and enforce our legal agreements and policies.
 

Exercising Your Rights Under GDPR

If applicable and subject to exceptions, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by using the contact details below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the EEA in order to obtain the information. Once we have received your request, we will review it and contact you within 30 days of our receipt of your request, but we will notify you of any delay and, in any event, will reply within three (3) months.  Please note that we may ask you for information necessary to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request. You will not typically need to pay a fee to exercise any of your rights under the GDPR.  But we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.  Alternatively, we may refuse to comply with your request in these circumstances.

Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us as follows:

Data Privacy Administrator
Capstone
1710 Roe Crest Drive
North Mankato, MN 56003
Email:  privacy@capstonepub.com

 

If in the United Kingdom:

Raintree
264 Banbury Road
Oxford, OX2 7DY
United Kingdom
Email: feedback@raintree.co.uk

 

Data Protection Officer:

Ametros Group Ltd
Lakeside Offices, Thorn Business Park
Rotherwas Industrial Estate
Hereford
Herefordshire
England
HR2 6JT
0330 223 2246
Email: dpo@ametrosgroup.com
Website: www.ametrosgroup.com

 

 EU Representative:

Ametros Ltd
Unit 3D
North Point House
North Point Business Park
New Mallow Road
Cork
Ireland
Email: gdpr@ametrosgroup.com
Website: www.ametrosgroup.com
 

Your California Privacy Rights

This section of our Privacy Notice applies to “consumers” who reside in California, as defined by the California Consumer Privacy Act (“CCPA”). We adopt this section to comply with the CCPA, including as amended by the California Privacy Reform Act (“CPRA”).  This Section applies to our processing activity when we are acting as a “business” under the CCPA—meaning that we control the purposes and means of processing your personal information.  Some of the personal information we collect may be subject to other data protection laws (such as the Fair Credit Reporting Act) and may be exempt from some or all of the requirements under the CCPA. 

If you are a California resident, you may be able to exercise the following rights. We will honor requests received to the extent required by applicable law and within the time provided by law.
 

Right to Access and Information Regarding Personal Information

You have the right to request that we disclose to you the categories and specific pieces of Personal Information we have collected about you. Specifically, you have the right to request that we disclose the following to you, in each case, for the twelve-month period preceding your request:

• The categories of Personal Information we have collected about you;
• The categories of sources from which the Personal Information is collected;
• Our business or commercial purpose for collecting or selling Personal Information;
• The categories of third parties with whom we share Personal Information;
• The specific pieces of Personal Information we have collected about you;
• The categories of Personal Information about you, if any, that we have disclosed for monetary or other valuable consideration and the categories of third parties to which we have disclosed the information, by category or categories of Personal Information for each third party to which we disclosed the Personal Information; and
• The categories of Personal Information about you that we disclosed for a business purpose.
   

Right to Deletion of Personal Information

You have the right to request that we delete Personal Information that we have collected about you. There may be certain exceptions to our obligation to delete your information such as if you have an existing account or transaction with us or if we have a legitimate business reason to keep your information. 
 

Right to Opt-Out

You have the right to opt out of the sale of Personal Information. We do not sell personal information, but we recognize that some privacy laws define “personal information” in such a way that making available identifiers linked to you for a benefit may be considered a “sale.” To opt-out of this, please contact us at privacy.capstonepub.com.  Please note: Capstone does not have actual knowledge of any “sales” of personal information relating to consumers under 16 years of age.
 

Right to Non-Discrimination

We may not discriminate against you because you have exercised any of the aforementioned rights, including by:

• Denying you goods or services;
• Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• Providing you a different level or quality of goods or services; or
• Suggesting that you will receive different price or rate for goods or service or at a different level or quality of goods or services.
   

Notice of Financial Incentives

As permitted by the CCPA, we may offer you certain financial incentives and benefits by joining our Capstone Rewards loyalty program. The information that we collect for enrollment in the program (listed above) allows us to tailor our communications and products and services suggestions for you. This, in turn, helps us establish a stronger relationship with you – something we at Capstone value.

If you participate in the Capstone Rewards program, there are two types of financial incentives:

• Points. You can earn points when you purchase products from our online store that can be used to discount the price of future purchases with us. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value. We estimate the value of personal information we request from our Capstone Rewards program customers by comparing the amount spent by Capstone Rewards program customers to similarly-situated customers who do not participate in the Capstone Rewards program over a 12-month period.

• Discounts. We may also send you promotions to discounted products and services. The value of these discounts vary and depend on the type of product you are buying.

Participation in the Capstone Rewards program is voluntary and requires your prior opt-in consent, which you may revoke at any time. If you wish to leave the Capstone Rewards program, please reach out to us using the information in the Contact Us section below.

For full program details, please visit https://www.capstonepub.com/rewards/rewards-faq/terms-and-conditions.
 

Personal Information We Collect about California Consumers

We collect certain types of Personal Information about you during your relationship with us, as stated above. In particular, we collected the following categories of Personal Information from California consumers within the last twelve (12) months:
 

Category of Personal Information Collected (and examples)	Sources of Personal Information Collected	Third Parties to Whom Disclosed
Identifiers such as name, address, email address, phone number, unique id, and other identifiers listed in the Personal Information Collected section above.	You Automatically Third Parties	IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers, and IT consultants Online analytics and marketing/advertising service providers Financial institutions and payment processors Order processing and fulfillment providers Professional advisors (accountants, lawyers, and auditors) Other users of the Products, including any users you authorize us to share the information with
Personal information described in California Civil Code §1798.80(e): (1) the personal information listed in the preceding bullet point as “identifiers,” and (2) the other information that identifies, relates to, describes, or is capable of being associated with a particular individual that we describe in “Information We Collect” above.	You Automatically Third Parties	IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers, and IT consultants Online analytics and marketing/advertising service providers Financial institutions and payment processors Order processing and fulfillment providers Professional advisors (accountants, lawyers, and auditors)
Commercial information, including information about orders or purchases of any of our products or services; registration information, specials, and information you provide or submit to us when you participate in any event, program, contest, survey or other promotion that we may offer from time to time.	You Automatically Third Parties	IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers, and IT consultants Online analytics and marketing/advertising service providers Financial institutions and payment processors Order processing and fulfillment providers Professional advisors (accountants, lawyers, and auditors)
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our websites, mobile apps, or our products pages or accounts on any third-party social media platforms.	Automatically	IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers, and IT consultants Online analytics and marketing/advertising service providers
Audio information from calls placed with customer service and accounting centers which may be reported, and electronic information in the form of Internet or other electronic network activity information described above.	Automatically
Education information specific to student users.	You	IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers, and IT consultants
Inferences drawn from (1) the information we collect when you visit our websites, tools, widgets and plug-ins, (2) information we collect, including through third-party suppliers, regarding content and other data posted on the Internet (such as public locations on the Internet), and (3) information about consumers preference and behavior that we collect on our websites and mobile apps or purchase from third parties in order to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.	Third Parties	Online analytics and marketing/advertising service providers
Sensitive Personal Information such mail, email and text message content, account login, financial account, debit card, or credit card number	You	IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers, and IT consultants Online analytics and marketing/advertising service providers Financial institutions and payment processors Order processing and fulfillment providers Professional advisors (accountants, lawyers, and auditors)

Requests to Exercise Your Rights

You or your authorized agent may make a request to access, correct, delete or opt-out of the disclosure of your Personal Information for business purposes. You may also make a verifiable consumer request on behalf of your minor child if you believe we have received their information inadvertently. You may request to exercise the aforementioned rights by:

• Submitting a request to privacy@capstonepub.com
• Calling us at 888-262-0705

 Your request must include your name, e-mail address, mailing address, phone number, the nature of your inquiry and the context in which we may have received your information.  Please note that we take additional steps, and request additional information, to verify your identity and residency before granting you access to information or acting on your request to exercise your rights, as required or permitted by law. In order to protect the privacy and security of consumers, a verifiable request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of such consumer; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

If you use an authorized agent, we may require proof of written authorization you have given to make the request. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We may limit our response to your exercise of the above rights as permitted by law. You may only make a verifiable consumer request for access or data portability twice within a twelve (12)-month period.  We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you or the consumer on whose behalf you are making the request. 

We will confirm receipt of the request within 10 business days describing our verification process. We will respond to your request within 45 days or let you know if we need additional time, in which case we may extend our response period by an additional 45 days and will explain the reasons for any such extension.   For data portability requests, we will select the format of our response; the format will be readily useable and should allow you to transmit the information from one entity to another.  We will not charge a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing the request.
 

Data Sharing for Direct Marketing Purposes

California Civil Code § 1798.83 further permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your personal information with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us at privacy@capstonepub.com.
 

Notice for Nevada Residents

Under Nevada law, Nevada “consumers” may request that “operators” of internet sites and online services refrain from the “sale” of their “covered information” to third parties (as such terms are defined under Nevada law).  “Covered information” includes first and last name, address, email address, and phone number, or an identifier that allows a specific person to be contacted either physically or online.  As discussed above, we share your information with certain third parties that we believe can provide you with offers and promotions for products and service of interest to you and in the other ways described above.  We do not believe that our sharing in this regard would qualify as a sale under Nevada law. 
 

Changes to This Privacy Notice

We may change this Privacy Notice at any time. We will post all changes to this Privacy Notice on this page and will indicate at the top of the page the modified notice's effective date. We therefore encourage you to refer to this page on an ongoing basis so that you are aware of our current privacy notice. If required by the applicable law, we will notify you of the changes. By continuing to use the Products or the Services or providing us with information following such a replacement Notice being uploaded, you agree that you will be deemed to have agreed to be bound by the Privacy Notice as changed.
 

Contact Us

If you have any questions or suggestions regarding this Privacy Notice, please contact us at:

Data Privacy Administrator
Coughlan Companies, LLC dba Capstone
1710 Roe Crest Drive
North Mankato, MN 56003
Email: privacy@capstonepub.com
Contact number:  888-262-0705

 

If in the United Kingdom:

Raintree
264 Banbury Road
Oxford, OX2 7DY
United Kingdom
Email: feedback@raintree.co.uk