Privacy Statement
INTRODUCTION
PLEASE READ THIS PRIVACY STATEMENT CAREFULLY.
This Privacy Statement tells you how we use information that we collect about you through this Kapetan website operated by Left Turns LP based in Greece as well as any mobile sites, applications ( "apps"), widgets, conferences, events, electronic newsletters, communications or other services (collectively the "Services") that link to this Privacy Statement. This Privacy Statement does not apply to situations where we have notified you that an alternative privacy statement applies, nor does it apply to other Left Turns LP websites.
You should review the privacy statement posted on other Kapetan websites when you visit them. This website and this Privacy Statement are intended for global audiences.
We intend to deal with your information in a manner that is fair and in line with your expectations and encourage you to read and consider the information provided in this Privacy Statement to confirm that this is the case.
WHAT INFORMATION DO WE COLLECT ABOUT YOU?
The information we receive, and how we use it, depends on what you do when visiting our website or using our Services. We collect and use non-personal information (information that does not identify you personally) differently from your personal information.
YOUR PERSONAL INFORMATION
Personal information is information that can specifically identify you, such as your:
first and last name
address, telephone number, e-mail address, or other contact information
date of birth or age
social media username or profile
interests and qualifications
IP (Internet Protocol) address when such address is associated with a specific user
We collect personal information about our users in two ways:
1. when you directly provide information to us, e.g. by entering personal information on certain pages of the website. For example, you may fill out a registration form for a particular service, participate in a survey, or complete a contact form.
2. using automated means, specifically through cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website. For more information about the cookie policy, please read below:
COOKIES AND OTHER TOOLS
Left Turns LP and its Providers collect information about you by using cookies, tracking pixels, and other technologies (collectively, “Tools”). We use this information to better understand, customize and improve user experience with our websites, services, and offerings as well as to manage our advertising. For example, we use web analytics services that leverage these Tools to help us to understand how visitors engage with and navigate our Site, e.g., how and when pages in a site are visited and by how many visitors. We are also able to offer our visitors a more customized, relevant experience on our sites using these Tools by delivering content and functionality based on your preferences and interests. If we have collected your personal data, e.g., through a registration or a request for certain materials, we may associate this personal data with information gathered through the Tools. This allows us to offer increased personalization and functionality on the Site.
Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting cookies. To find out more about cookies, visit www.aboutcookies.org. Certain information is collected by most browsers or automatically through your devices, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, and Internet browser type and version. We use this information to ensure that the services function properly.
Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Site, along with the time of the visit and the pages visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications, and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems, and administering the Site. We may also derive your approximate location from your IP address.
We may use Google Analytics, which uses cookies and similar technologies to collect and analyze information about the use of the Site and report on activities and trends. This service may also collect information regarding the use of other websites, apps, and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
We may use Flash Local Shared Objects (“Flash LSOs”) and other technologies to, among other things, collect and store information about your use of the Site. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs (referred to as “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including those used in connection with the Site.
HOW DOES LEFT TURNS LP USE PERSONAL INFORMATION?
We may use the information that you have shared with us through this website and relevant Services (other than sensitive information, which is discussed separately below) for the following purposes:
to respond to your requests
to provide the services or information you request
to allow you to register certain products or services, or enhance their functionality
to resolve and track the status of any consumer and/or product or service issues
to manage our relationship with you and facilitate any necessary follow-up (e.g. by storing relevant information and preferences for a reasonable amount of time)
to enter into, or perform a contract with you (e.g. in case you wish to order products or services from us)
to enable you to participate in our online communities, including social media and blogs
to enable you to participate in and join online meetings in this website
to contact you with information that might be of interest to you – see further the Marketing and Education section below
In other ways to which you consent
Left Turns LP may also use your personal information to the extent necessary to achieve the following legitimate interests, so long as compatible with your rights and expectations of privacy:
for analytical purposes in order to research, develop and improve programs, products, services, and content
to anonymize your information by removing any personal identifiers (your name, e-mail address, etc.) so that it may be used for other purposes. In this case, the anonymized information would no longer identify you and may be treated like other non-personal information. For more details please see the relevant section below.
to enforce this Privacy Statement and other rules about your use of this website
to protect our rights or property
Left Turns LP also has legal grounds to use your personal information:
as necessary to protect someone's health, safety, or welfare; and
in order to comply with a law or regulation, court order, or other legal processes
Where required by law, we will ask you to "opt in" or affirmatively consent to the processing of your personal data for a particular purpose. For example, where the law so requires, we will only send you newsletters if you have subscribed to them.
MORE INFORMATION ON OUR PROCESSING ACTIVITIES
Below we outline each website-related processing activity in greater detail and provide information on the categories of information collected for each activity as well as the legal basis of processing for each of these activities, if and to the extent the data processing is subject to GDPR.
Responding to requests or inquiries
We may use the information that you provide to us to take the steps necessary to respond to your request, for instance, inquire about a product, or subscribe to one of our mailing lists. Depending on your request, we may collect your contact information (such as your name, mailing address, telephone number, job title=, your interests and preferences (such as products or areas of interest), and any other information you provide to us.
We collect and process your personal data for these purposes based on our legitimate interest to respond to your request. If you submit sensitive Personal Data as part of your inquiry, we will also base such processing on your explicit consent. If reporting is required, we may process your data to comply with our legal obligations.
Article 6(1)(f) GDPR Articles 6(1)(a) and 9(2)(a) of the GDPR Article 6(1)(c) and Article 9(2)(i) GDPR
Completing transactions
Some parts of our website may collect your Personal Data to fulfill services that you have requested and to understand your interests and preferences. In these instances, we may collect your contact information as well as a history of your previous transactions with us. (such as order history, Customer account information).
We use this information to perform an agreement with you.
Article 6(1)(b)
Personalizing Your Experience
We may collect certain information about you, your preferences, and how you have interacted with us in the past in order to understand your interest in our products and services so that we can best serve you. This may include information about your contact and product preferences, languages, marketing preferences, and demographic data.
In cases where we collect this information automatically, we collect and process his information for our legitimate business interests. In other cases, we will collect and process this information pursuant to your consent.
Article 6(1)(f) GDPR Articles 6(1)(a) of the GDPR
Website Analytics and Tracking
Where permitted by law, we may combine Personal Data you provide with other information you’ve provided to Left Turns LP through our websites. Where permitted by law, we may combine Personal Data collected through our websites and online resources with Left Turns LP offline records and information provided to us by third parties. More information about this can be found in the section below and in our Cookie Policy.
In cases where we collect this information automatically, we collect and process his information for our legitimate business interests. In other cases, we will collect and process this information pursuant to your consent.
Article 6(1)(f) GDPR Articles 6(1)(a) of the GDPR
To Run and Maintain our Website
We use this information to secure our websites, network systems, and other assets. This may include information concerning your IP Address, geographic location, resources you have accessed, and similar information.
We collect this information automatically, for our legitimate business interests to run, maintain, and secure our websites.
Article 6(1)(f)
WHAT IS SENSITIVE INFORMATION?
Some types of personal information are sensitive information. Sensitive information is personal information revealing or relating to your health (such as your device serial number, or the date of surgery, implantation, injection), genetic or biometric data, your racial or ethnic origin, religious or philosophical beliefs, sex life or sexual orientation, political opinions or trade union membership.
WILL LEFT TURNS LP TREAT SENSITIVE INFORMATION DIFFERENTLY THAN OTHER PERSONAL INFORMATION?
Left Turns LP will only collect and process your sensitive information:
in ways for which you have given your explicit consent
to protect the vital interests of you or another person, in cases where your explicit consent cannot be given or reasonably requested
according to applicable laws which include suitable and specific measures to safeguard your fundamental rights and interests
to establish, exercise, or defend a legal claim
For example:
We may collect sensitive information directly from you, when you voluntarily provide it to us for a particular purpose (e.g. when you contact us with a question or suggestion about our products and services);
We may collect sensitive information about participants who have explicitly consented to participate in clinical trials, studies, and other research initiatives.
NON-PERSONAL INFORMATION
Non-personal information is information that cannot identify you or be tied to you in any way. Therefore the non-personal information that we collect through this website does not identify you as an individual person, and will not be linked to you. It may include information such as the following:
the type of web browser software you use (for example, Safari or Internet Explorer)
the name of the domain from which you access the Internet
the Internet address of the website from which you linked directly to our website
the date and time you access our website
which pages you have visited on our website
the search terms you use
the links on which you click
If you visit our website to read or download information, such as information about one of our products, we may collect certain non-personal information from your computer. This information is collected from your computer's web browser. If you only read or simply click to download information on our website, we do not collect or learn your name, e-mail address, home address, or any other personal information about you.
WHAT DOES LEFT TURNS LP DO WITH NON-PERSONAL INFORMATION?
We are always looking for ways to better serve you and improve our products, services, and website experience. We will use non-personal information from you to make this website more useful to visitors. We may also use non-personal information for other business purposes. For example, we may use non-personal information or aggregate non-personal information to:
create reports for internal use to develop programs, products, services, or content
adapt or improve the information or services provided
share or sell information to third parties
provide information on how our site is used, such as "traffic statistics" and "response rates" to third parties
DIRECT MARKETING AND EDUCATIONAL MATERIALS
Left Turns LP may wish to provide you with educational materials or other information about our products and services, that might be of interest to you, based on the information you have shared with us and that we have collected through cookies or similar techniques regarding your use of Left Turns LP websites, social media, and blogs. We will ask you to "opt-in" or affirmatively consent to the use of your personal information for the purposes of such communications, in accordance with applicable laws.
If at any time you decide not to receive any educational, commercial, or promotional information related to our products and services or regarding the products or services of our affiliates or service providers, please email us at the contact details listed below and mention “OPT-OUT” in the subject of your email. Alternatively, you may use the opt-out procedure provided in any relevant message you receive from us.
Please note that if you opt not to receive promotional messages from us, we may still continue to send you relevant information for other lawful purposes, such as to administer any account you may have with us, to respond to your requests, to execute agreements with you, or to provide you with information that Left Turns is required by law to provide, e.g. regarding product recalls.
SURVEYS
From time to time, we may invite you to participate in a survey to determine customer satisfaction levels, identify areas of potential improvement, or carry out market research. We may send you a specific invite to participate in such a survey on the basis of our legitimate interests in conducting the survey, or on the basis of your prior “opt-in” consent to receive such communications, in accordance with applicable laws. You may opt out of receiving any such future communications in the manner detailed in the section above. The personal data that is collected for the purpose of the survey may include your email address, phone number, survey results, and any free-text message you may have written in the survey.
We process your personal information as part of the survey for carefully considered and specific business purposes which are in our legitimate interests and which we believe also often benefit you, based on our assessment that our legitimate interests do not override your freedom and data protection rights.
The business purpose of collecting your data is to reply to survey feedback you may have provided, specifically:
Should you have indicated an issue that we need to take action to resolve
In order to gain further insight into the experience you have described
To inform you of any action we might take internally to resolve your issue or enhance your experience
DOES LEFT TURNS EVER SHARE PERSONAL INFORMATION WITH THIRD PARTIES?
Left Turns will not share your personal information with a third party except as described in this Privacy Statement.
In the ordinary course of business, we may share some personal information with Left Turns LP affiliates or third-party companies that we hire to perform services or functions on our behalf. For example, we may:
use a service provider to administer certain newsletters or informational mailings that you have signed up for, and provide access to your email address for this purpose.
use a third-party application or platform to allow us to manage and keep track of our communications with you.
use a third-party application or platform like Zoom or Microsoft Teams or any custom live streaming platform to conduct live video training events (webcast) to manage and keep track of our communications with you.
use our company affiliates to provide services relating to your personal information e.g. we may store your information on a secure server based at our affiliate’s site in Europe or the United States. For more information on the circumstances in which we may transfer your information to other countries, please see the relevant section below.
use a third-party application or platform to conduct surveys, which can include storage of the survey feedback.
In all cases, we will not share more information than is necessary, and we will not authorize any third parties to keep, disclose or use your information except to provide the requested services in line with the purposes set out above.
Please note that subject to applicable laws, we may disclose your personal information if we believe we are required to do so to comply with any law, regulation, court order, legal or government request. In the unlikely event that all or part of our business is acquired by a third party, your information may be transferred to the new corporate owner insofar as relevant to the business in question and subject to appropriate safeguards being in place.
In addition, we may use and disclose your personal information to third parties if necessary to:
enforce this Privacy Statement and the other rules about your use of this website
protect our rights or property
protect someone's health, safety, or welfare
comply with a law or regulation, court order, or other legal processes
investigate or take action in cases of suspected fraud or illegal activities
In addition, please keep in mind that certain areas of our website may be interactive in nature, and allow you to post information that other users can see. If you do not wish to have information viewed publicly, please do not use those sections of the website.
DO WE TRANSFER PERSONAL INFORMATION TO OTHER COUNTRIES?
In certain cases, Left Turns may transmit personal information collected on this website to our affiliates or third-party service providers in other countries, but only in furtherance of the purposes set out in this Privacy Statement. In cases where personal information is transmitted from Europe to other countries, we will ensure that safeguards equivalent to those provided by European data protection laws are in place. For more information please contact hello@kapetan.gr .
HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION FOR?
We will only keep your personal information for as long as necessary to fulfill the purposes for which we are allowed to use them, as set out in this Privacy Statement. For example, if you tell us that you no longer wish to receive a newsletter from us, we will immediately delete your email address from our mailing list. In case you participate in a program via our website we will delete the personal information provided as part of that program within a reasonable time after its completion (e.g. six months after completion will normally be considered reasonable unless we have lawful grounds to retain some of the information for longer (e.g. if necessary for validation or to comply with recordkeeping obligations)).
WHAT HAPPENS IF THE PRIVACY STATEMENT CHANGES?
This Privacy Statement was created in November 2022. We may change this Privacy Statement at any time and for any reason. If we decide to make a significant change to our Privacy Statement, we will post a notice on the homepage of our website for a period of time after the change is made. We encourage you to review this Privacy Statement each time you visit the website.
WHAT ABOUT PRIVACY ON OTHER WEBSITES?
This website may contain links to other websites. Some of those websites may be operated by Left Turns LP and its affiliates, and some may be operated by third parties. This Privacy Statement does not apply to other websites, even other Left Turns LP websites. Therefore whenever you leave this website we recommend that you review the privacy practices that apply to the information you provide on other websites. We provide the links for your convenience, but we do not review, control, or monitor the privacy practices of websites operated by others. Neither are we responsible for websites operated by third parties or your business dealings with them.
ARE THERE SPECIAL RULES ABOUT CHILDREN'S PRIVACY?
We care about protecting the online privacy of children. We will not intentionally collect any personal information (such as a child's name or e-mail address) from children under the age of 16 without the consent of someone holding parental responsibility. If you think that we have otherwise collected personal information from someone under the age of 16, please contact us.
WHAT ABOUT WEBSITE SECURITY?
Security is very important to us. We also understand that security is important to you. We use industry-standard measures to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However no website or email transmission is 100% secure and we encourage you to therefore take special care in deciding what information you send or request via email, and take appropriate precautions such as keeping any usernames and passwords you use confidential.
YOUR RIGHTS
At any time, you may exercise your right to access, rectify and, as the case may be, erase, any personal information relating to you, or restrict the processing of your personal information, in compliance with applicable laws. You also have the right at any time to object, based on your particular situation, to any use or processing of your personal information which we have based on our legitimate interests.
In case we are processing your personal information in an automated manner as part of a service to you or based on your consent then you also have the right to request a copy of your information in a structured, commonly used, and machine-readable format (known as the right to “data portability”).
Such requests can be sent to hello@kapetan.gr .
Please note that we may ask you to provide proof of identity (such as a copy of your ID card or passport) before we can comply with your request.
If we have based our collection or use of your personal information on your consent then you also have the right to withdraw your consent at any time in the same way as it was given, or by sending a request in the above manner.
You may also at any time, free of charge and without having to provide any justification, opt-out of any direct marketing campaigns and request to no longer receive any promotional material as described above.
In case you are not satisfied with our handling of your request you may contact the applicable Data Protection Authority. See further: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm