1. Data Controller
The data controller responsible for your personal data is Capsis Media LLC, 364 E Main St Ste 1008, Middletown, DE 19709, USA · Drottninggatan 97, 113 60 Stockholm, Sweden · Level 6, HSBC Building, No. 8 Century Avenue, Pudong, Shanghai 200120, China. Email: privacy@capsismedia.com. For EU/EEA matters, PerOla Hammar acts as the data protection point of contact. For Swedish law purposes, we are subject to the supervision of Integritetsskyddsmyndigheten (IMY).
2. Data We Collect
We collect the following categories of personal data:
Identity & Contact Data
Name, email address, phone number, company name — provided when you submit a contact form, request a quote, or create a client account.
Usage & Analytics Data
IP address, browser type, operating system, device type, pages visited, time on site, referral source, session ID, screen resolution, language, and timezone — collected automatically when you visit our website.
Communication Data
Messages, project notes, and any content you submit through our client portal or contact forms.
Cookie & Tracking Data
Cookie identifiers, consent preferences, and session tokens — see our Cookie Policy for full details.
Technical Data
Server logs, error reports, and performance data used to maintain website security and functionality.
3. Legal Bases for Processing (GDPR Article 6)
We process your data on the following legal grounds:
Consent (Art. 6(1)(a))
For analytics cookies, marketing communications, and optional tracking. You may withdraw consent at any time via our cookie settings.
Contract Performance (Art. 6(1)(b))
To deliver services you have requested, including website design projects and client portal access.
Legitimate Interests (Art. 6(1)(f))
For website security, fraud prevention, internal analytics, and improving our services. We have balanced these interests against your rights.
Legal Obligation (Art. 6(1)(c))
To comply with applicable laws including tax, accounting, and regulatory requirements.
4. How We Use Your Data
- To respond to your inquiries and provide requested services
- To manage and deliver client projects via our client portal
- To send service-related communications (quotes, project updates)
- To analyze website traffic and improve user experience
- To maintain website security and prevent fraudulent activity
- To comply with legal and regulatory obligations
- To send marketing communications where you have given consent
5. Data Sharing & Third Parties
We do not sell your personal data. We may share data with:
- Service providers acting as data processors (hosting, analytics, email services) — bound by data processing agreements
- Professional advisors (lawyers, accountants) under confidentiality obligations
- Law enforcement or regulatory authorities where required by law
- Business transfers — in the event of a merger, acquisition, or sale of assets, your data may be transferred with appropriate notice
For California residents: We do not sell or share personal information as defined by CCPA/CPRA, including for cross-context behavioral advertising.
6. International Data Transfers
As a company with offices in the USA and Hong Kong, your data may be transferred to and processed in countries outside the European Economic Area. Where we transfer EU/EEA data internationally, we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the European Commission, or we rely on adequacy decisions where applicable.
7. Data Retention
We retain personal data only for as long as necessary for the purposes described in this policy, or as required by law. Specifically:
- Client project data: 7 years after project completion (for accounting/legal compliance)
- Contact form submissions: 3 years from last contact
- Analytics data: 24 months from collection
- Cookie consent records: 12 months
- Website visit logs: 13 months
8. Your Rights
Depending on your location, you have the following rights:
Under GDPR (EU/EEA/Sweden):
- Right of access — obtain a copy of your personal data
- Right to rectification — correct inaccurate data
- Right to erasure ("right to be forgotten") — request deletion of your data
- Right to restriction — limit how we process your data
- Right to data portability — receive your data in a machine-readable format
- Right to object — object to processing based on legitimate interests or for direct marketing
- Right to withdraw consent — at any time, without affecting lawfulness of prior processing
- Right to lodge a complaint with Integritetsskyddsmyndigheten (IMY) at imy.se, or your local supervisory authority
Under CCPA/CPRA (California residents):
- Right to know — what personal information we collect, use, disclose, and sell
- Right to delete — request deletion of personal information
- Right to correct — correct inaccurate personal information
- Right to opt-out — of sale or sharing of personal information (we do not sell data)
- Right to limit use of sensitive personal information
- Right to non-discrimination — we will not discriminate against you for exercising your rights
To exercise any of these rights, contact us at privacy@capsismedia.com. We will respond within 30 days (GDPR) or 45 days (CCPA/CPRA).
9. Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption in transit (TLS/HTTPS), access controls, and regular security reviews. However, no method of internet transmission is 100% secure.
10. Children's Privacy
Our website and services are not directed to individuals under the age of 16. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, please contact us immediately.
11. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated by updating the "Last updated" date at the top of this page and, where appropriate, by direct notification. We encourage you to review this policy periodically.
12. Contact Us
For any privacy-related questions or to exercise your rights: Capsis Media LLC, 364 E Main St Ste 1008, Middletown, DE 19709, USA · Drottninggatan 97, 113 60 Stockholm, Sweden · Level 6, HSBC Building, No. 8 Century Avenue, Pudong, Shanghai 200120, China. Email: privacy@capsismedia.com
