RaGaPa Inc. (“RaGaPa”) is committed to safeguarding your privacy online. We have implemented numerous technical and administrative measures to ensure that your personal information and data remain protected and secure.
- Visitors to our website, www.CaptiveXS.com (the “Site”);
- RaGaPa customers (“Clients”), which use RaGaPa products and solutions (collectively “RaGaPa Service”) to provide wifi-related services to their end-users (“Users”); and
- Users whose Information is processed by the RaGaPa Service.
By using the Site or the RaGaPa Service, you are agreeing to the collection and use of your Information, including Personal Data, in the manner described in this Policy. “Personal Data” is data that identifies or could be used to identify, locate, track, or contact an individual, e.g. name, postal address, e-mail address and phone number.
RaGaPa complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and Switzerland to the United States. Please see our Privacy Shield Commitments page for more information.
Information Provided to Us and How We Use It
Contact Information. If you use the Site to ask that we contact you or provide you information, then we collect demographic and contact information, such as your name, company name and email address.
- We use this information to send you the information or materials you requested or to otherwise respond to your inquiry
- We also use this information to notify you of new product offerings by RaGaPa and developments related to the RaGaPa Service, including by sending you our monthly newsletter.
- If you no longer wish to receive these communications, you can follow the unsubscribe mechanism described in the Marketing Choices section of this Policy.
Client Information. If you sign-up with RaGaPa to use the RaGaPa Service as a Client, then in order for us to enable and administer such service, we need you to provide company name, address, emails, phone numbers, and billing information.
- We use this Client data to administer the Client’s account, provide support, improve the RaGaPa Service and to keep a record of our dealings with the applicable Client.
- We use Information related to a Client’s financial qualifications and billing information to perform credit analysis, to process purchases, for accounting, and to detect and prevent fraud. We do not use this financial information for marketing or promotional purposes.
- RaGaPa may use Personal Data a Client provides to us to notify the Client of new product offerings by RaGaPa and to ask the Client about their experience using the RaGaPa Service. Clients can elect to not receive these mailings as described below in the Marketing Choices section of this Policy.
- We also may use the Personal Data Clients provide us to send Clients important notices about changes, updates and availability of the RaGaPa Service or changes to our policies. Because this information is important to interaction with RaGaPa, Clients may not opt out of receiving these communications.
User Data. RaGaPa receives data (“User Data”) from Users through their use of the RaGaPa Service provided to them by a particular Client. User Data may include name, email address, job title, device mac/IP address, demographic information (such as gender, age range, education level, hometown, zip code, preferences and interests) and information from customer surveys and/or offers. RaGaPa follows the instructions of the applicable Client with respect to the processing of User Data for such Client’s Users.
- RaGaPa processes User Data in order to provide the RaGaPa Service and perform its contractual obligations for Clients.
- RaGaPa also may view and access User Data to resolve a problem or support issue, to update or enhance the RaGaPa Service, to investigate a suspected violation of the related user agreement, to provide professional services or as may be required by law.
Log Data. As is true of most web sites, we gather certain information automatically and store it in log files. This information includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. Such information does not include Personal Data. We may combine this automatically collected log information with other information we collect about you, but we do not associate it with any Personal Data. We use this information to improve the RaGaPa Service and other services we offer you, as well as for analytics and Site and services operations purposes.
Cookies. The Site and RaGaPa Service send your browser cookies– a small piece of data stored on your computer’s hard drive. The purposes of the cookies are to improve your reading of and your search possibilities on the Site. If you are a registered Client, the cookies will also manage and control your login and session on those parts of the Site and RaGaPa Service that are only available to registered Clients.
In addition, we use Google Analytics for the Site and the RaGaPa Service. This tool helps us understand how often users visit the Site and the RaGaPa Service and what pages they visit. This page further explains how Google uses your data www.google.com/policies/privacy/partners/.
If you do not want to accept that your computer receives and stores cookies, you can alter your security settings on your web browser. However, note that certain parts of our Site and the RaGaPa Service may only be used fully if your browser allows cookies. Thus, your use of the Site and our services may be affected negatively by removing and not allowing cookies.
Sharing of Information
RaGaPa may share Information in the following situations:
Service Providers. RaGaPa may contract with other companies to provide services or functionality on our behalf. If we do so, we may share your Information, including Personal Data, with such providers to the extent necessary for their engagement. In all such cases, the service providers’ use of your Information will be contractually limited to uses consistent with this Policy. Examples of such service providers are:
- Payment processors and other third parties which are provided billing information to complete our transactions with you and to detect and prevent fraud or for collections.
- Data storage providers where we may store copies of our database backups. These third parties do not have the right to access such data.
Legal Requirements. We reserve the right to disclose your Personal Data and other Information as required by law such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. Unless we are prohibited by law, we will attempt to notify you of any request to disclose your Personal Data to the authorities or any other party and, where appropriate, refer such requests directly to you.
Successors. If RaGaPa is involved in a merger, acquisition, or sale of all or a portion of its assets, your Information, including Personal Data, may be disclosed and transferred in connection with that transaction. Such transfer would enable due diligence and/or allow the transferee to operate the business. You will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your Personal Data, as well as any choices you may have regarding your Information.
Access to Personal Data (Other than User Data)
The following terms describe how RaGaPa will respond (unless such response is not required by applicable local law) to the indicated requests regarding your Personal Data, other than User Data (“Covered Data”):
Access and Deletion. Upon request we will provide you with information about whether we hold any of your Covered Data.
- If you wish to receive a copy of your Covered Data or to correct, update or request the deletion (assuming that this does not impact services we are providing to you) of your Covered Data, you may contact us using the information below in the Contact Us section of this Policy.
- You may request that we restrict or cease the processing of your Covered Data while we make any corrections which you request.
- If we no longer need your Covered Data to provide services or for other legitimate purposes, you may request that we retain but not otherwise process such Personal Data to the extent needed in order for you to establish, exercise or defend legal claims.
- We will respond to your request to access, update or delete your Personal Data within 30 days. We may reject requests which risk the privacy of others or are unreasonable or repetitive or would require disproportionate effort.
Transfer of Information. You may receive a copy of your Covered Data in a structured and commonly used machine-readable format and you may transfer that information to another data controller. If it is technically feasible, you may request that we transfer such data directly to another controller. We will comply with your request subject to verifying your identity and provided that it is technically feasible.
Access to Personal Data Which is User Data
We are a data processor of User Data, which is controlled by our Clients. To the extent the User Data received from a particular Client includes Personal Data, such Client is responsible for complying with all privacy laws and regulations applicable to such User as a user of the RaGaPa Service and controller of such User Data. RaGaPa shall, to the extent legally permitted, promptly notify such Client if RaGaPa receives a request from an individual to exercise data subject rights for such User Data. RaGaPa agrees to use reasonable efforts to assist such Client for the fulfilment of such a request. To the extent legally permitted, the applicable Client shall be responsible for any costs arising from RaGaPa’s provision of such assistance.
Destruction of Personal Data
Any of your Personal Data that we possess is only stored as long as it is required for us to keep it in order to fulfill the purposes for which it was collected. Personal Data may however be necessary to store for a longer period due to legal requirements, e.g. for accounting purposes.
The RaGaPa Service provides you access to wifi networks which enable you to access the Internet. RaGaPa has no control over the websites which you access, including their privacy and security practices.
Whenever you submit requests for more information or services from us, you may opt out of entering certain fields. However, such decision may affect our ability to provide what you have requested. You can opt out from our marketing messages by clicking on the “unsubscribe” link included in them or by contacting RaGaPa as indicated below under Contact Us. Such opt out will not extend to transactional or relationship messages.
RaGaPa is dedicated to maintain the security of Personal Data and preventing unauthorized access through the implementation of appropriate technical and organizational measures, as far as is reasonably possible. Such security measures also include that Personal Data may be accessed only by a limited number of persons within RaGaPa.
Our employees are made aware of and must comply with RaGaPa’s security standards. When we occasionally use third-party contractors to perform tasks involving Personal Data that might otherwise be performed by our employees, these contractors are contractually bound to adhere to this Policy and they are subject to similar restrictions as our employees.
Do Not Track Signals
Some browsers contain features that signal that the user does not want to be tracked, known as “Do Not Track” or DNT. The Site currently does not respond to such signals.
Changes to this Policy
We may change this Policy from time to time. If RaGaPa is going to use your Personal Data in a manner different from that stated at the time of collection, we will advise you of the choices you may have as a result of those changes. We will also post a notice that this Policy has changed, so we encourage you to periodically review this page for the latest information on our privacy practices.
You may direct questions regarding this Policy to firstname.lastname@example.org or via postal mail at 19925 Stevens Creek Blvd Suite 100, Cupertino, California 95014.