Captain Spices PRIVACY POLICY

Your privacy is important to us. Captain Spices is committed to protecting the rights of individuals in line with the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (“GDPR”) as well as each applicable national Personal Data protection laws and regulations.

This privacy policy (the “Privacy Policy”) will explain how Captain Spices uses the personal data we collect from you when you use our website (the “Website”). By using our services or communicating with us about them, you acknowledge that your personal information will be processed in accordance with this Privacy Policy, and in any other applicable privacy notice and any updates and amendments.

Please read this Privacy Policy carefully to understand how we will treat your information before you start using our Website or communicating with us.

• What data do we collect?

When you use this Website, Captain Spices may collect any personal data you provide us, including personal identification information (e.g. name, email address, location, phone number, etc.).

In addition to the personal data you provide to Captain Spices yourself, Captain Spices may collect, record and process additional (personal) data generated as a result of using the Website. This concerns the following personal data:

• Data from the used equipment, such as a unique device ID, version of the operating system and settings of the device you use to access a service;
• Information about the use of a service, such as the time at which you use the service and the type of service that is used;
• Location details from your device or derived from your IP address that is provided to us when you use a particular service;
• Data available from external sources. We may receive information about you from public or commercially available sources.

• How do we collect your data?

You directly provide Captain Spices with most of the data we collect when you use this Website. In particular, we collect data and process data when you:

• Fill in the “Contact Us” form;
• Send us an email;
• Share the webpages of our Website on social media platforms;
• Request to receive information;
• Download files on the Website;
• Use or view our Website via your browser’s cookies.

Captain Spices may also receive your data indirectly from the following sources: Google, Facebook, Instagram.

• How will we use your data?

By using the Website, Captain Spices will collect and process your Personal Data in accordance with this Privacy Notice. Your Personal Data may be used for the following purposes:

• Website Browsers / Administration. We use your Personal Data for administrative purposes, including to help us better understand how visitors access and use our Website and applications; to provide reports to prospective partners, service providers, regulators, and others; to implement and maintain security, anti-piracy, fraud prevention, and other services designed to protect our customers, partners and us; and to enforce our policies, directives and processes.
• To the extent permitted by law, we may use your Personal Data for marketing and promotional purposes, including communications through email or equivalent electronic means. For example, we use your Personal Data, such as your email address, to send news and newsletters, research, event updates and product data, or to otherwise contact you about services or information we think will interest you.
• We use your Personal Data to communicate with you, including responding to requests for assistance, information, newsletter, or career information. We can communicate with you in a variety of ways, including email, via your social media accounts if you have agreed, and/or text message.
• Customer service. We use your Personal Data for customer service purposes, including providing services to you, for technical support or other similar purposes and to establish and maintain customer accounts.
• Research and development. We use your Personal Data for research and development purposes, including improving our Website, applications, services, and customer experience and for other research and analytical purposes dedicated to improving our products, services, businesses, operations and processes.

• Legal compliance. We use your Personal Data to comply with applicable legal obligations, including responding to an authority or court order or discovery request.
• What is the basis for processing of your Personal Data?

We process your Personal Data in accordance with the provisions set out in the GDPR and the relevant applicable Data Protection laws and regulations. The legal basis for processing your Personal Data are:

• To comply with contractual obligations or to take steps at your request before entering into a contract. When you subscribe to a particular service through the Website, the purposes of processing your Personal Data are primarily determined by that service and we will process your information so that we can provide that service to you, assist you and answer your requests, or evaluate if we can offer you a product or service and under which conditions.
• As a result of your consent. When you have consented to the processing of your Personal Data by us for certain services through the Website, for instance if we need to carry out further processing for purposes other than those set forth in this Privacy Notice, we will inform you and, where necessary, obtain your consent. You can withdraw consent at any time. For further information on the right of withdrawal, please see below Section “What are your data protection rights?”
• Within the scope of a legitimate interest. On occasion we may not need your consent to use your data, given our legitimate interest to do so but we must inform you that we do this; examples of this are for:
• The analysis and optimisation of the Website;
• Ensuring IT security and the IT operation of Captain Spices;
• Prevention and investigation of criminal acts.
• On the basis of Captain Spices’ legal obligations or in the public interest. In some cases the processing of your Personal Data will be necessary for Captain Spices in other to fulfil these obligations.



• How do we store your data?

Your personal data will be stored by us and our service providers in accordance with applicable data protection laws to the extent necessary for the processing purposes set out in this Privacy Notice. As aglobal enterprise, our usage of the Internet almost always involves the international transmission of personal data, both within and outside the European Economic Area (EEA). In case of international transfers originating from the EEA, where the European Commission has recognised a non-EEA country as providing an adequate level of data protection, your personal data may be transferred on this basis.

For transfers to non-EEA countries whose level of protection has not been recognised by the European Commission, we will either rely on a derogation applicable to the specific situation (e.g. if the transfer is necessary to perform our contract with you such as when making an international payment) or implement the Standard Contractual Clauses adopted by the European Commission.

• Who will receive your data?

We communicate your Personal Data only to identified and duly authorized recipients. These include:

• Branches of the Captain Spices group;
• Financial or judicial authorities, state agencies or public bodies, upon request and to the extent permitted by law;
• External providers performing services on Captain Spices’s behalf.



• For how long will your Personal Data be stored?

Your data will be kept for the duration of our relationship (for example until you unsubscribe to a newsletter) and kept for a maximum of 2 years after the end of this relationship. For prospectsand personal Data sent through online forms, information is kept for 2 years.For any other data and/or purposes, your personal data are retained only for the time necessary to achieve the purpose for which such personal data were collected and for any required or permitted period under applicable laws.

Once the applicable time period has expired, we will delete your data by including it in batches of data to be flagged for deletion after two years of inactivity.

• Marketing

If you have agreed to receive marketing, you may always opt out at a later date. You have the right at any time to stop Captain Spices from contacting you for marketing purposes or giving your data to other members of the Captain Spices Group. If you no longer wish to be contacted for marketing purposes, please contact us at: contact@Captain Spices.

If you are invited to or attend one or our events, we will collect and process your contact information and any other information we may need to manage our invitation and your attendance (including for example dietary or special access requirements) in accordance with this Privacy Policy.

• What are your data protection rights?

Captain Spices would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

• The right to access– You have the right to request Captain Spices for copies of your personal data. We may charge you a small fee for this service.
• The right to rectification– You have the right to request that Captain Spices correct any information you believe is inaccurate. You also have the right to request Captain Spices to complete the information you believe is incomplete.
• The right to erasure– You have the right to request that Captain Spices erase your personal data, under certain conditions.
• The right to restrict processing– You have the right to request that Captain Spices restrict the processing of your personal data, under certain conditions.
• The right to object to processing– You have the right to object to Captain Spices’s processing of your personal data, under certain conditions.
• The right to data portability– You have the right to request that Captain Spices transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: contact@captainspices.com

Or write to us: Captain Spices – Attn. Data Protection Officer. 8 rue Marcel Sembat, 92120 Montrouge, France.

• Cookies
• What are cookies?

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our Website, we may collect information from you automatically through cookies or similar technology.

• How do we use cookies?

Captain Spices uses cookies in a range of ways to improve your experience on our Website, including:

• Keeping you signed in;
• Understanding how you use our Website;
• Personalizing content.
• What types of cookies do we use?

There are a number of different types of cookies, however, our Website uses:

• Functionality– Captain Spices uses these cookies so that we recognize you on our Website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
• Advertising– Captain Spices uses these cookies to collect information about your visit to our Website, the content you viewed, the links you followed and information about your browser, device, and your IP address.
• Statistical cookies: Captain Spices uses these cookies to analyse the Website behaviour of visitors on the Captain Spices Website. The cookies allow us to keep track of the number of visitors and see which parts of our website are popular.
• Targeting cookies: Captain Spices uses these cookies to build a profile of our Website visitors. It is based on your surfing behavior on our Website, after which we may contact you by telephone, e-mail or an ad based on the interests you have shown in order to offer you Captain Spices services or Captain Spices content (like blogs, Ebooks, whitepapers etc.).

• How to manage cookies

You can set your browser not to accept cookies, and the Website tells you how to remove cookies from your browser. However, in a few cases, some of our Website features may not function as a result.

Privacy policies of other websites

The Captain Spices Website contains links to other websites. Our privacy policy applies only to our Website, so if you click on a link to another website, you should read their privacy policy.

• Changes to our Privacy Policy

Captain Spices keeps its Privacy Policy under regular review and places any updates on this web page.

• How to contact us

If you have any questions about Captain Spices’s Privacy Policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact our Data Protection Officer:

By email at contact@captainspices.com,or At the following address: Captain Spices – Ms Emna Achour. 289, Rue Farzdak, Tunis, Tunisia.
• Contact the appropriate authority

Should you wish to report a complaint or if you feel that Captain Spices has not addressed your concern in a satisfactory manner, you may contact the competent data protection supervisory authority.