Privacy Policy

1.       Introduction

1.1.             Your privacy is important to us. We are Global Finance & Investment Company LDA ("GFIC"), the provider of the CapSure site. 

1.2.             We strive to ensure that our use of your personal data is lawful, reasonable and relevant to our business activities, with the ultimate goal of improving our services and your experience. 

1.3.             This data privacy policy ("Privacy Policy") sets out what personal data we collect from you when you use our site (which could be our website, mobile site, an application or any other electronic platform), how we collect your personal data, why we collect it and how we use it, and related matters. 

1.4.             Please read this Privacy Policy carefully to understand our views and practices regarding your personal data and how we will treat it (even if you're a long-standing site user) and contact us if you need any clarity or assistance, using the contact details set out in the "Contact Us" section below. 

1.5.             When you provide us with your personal data, we act as a "data controller". This means that:

1.5.1.                    we "control" the personal data that you provide, including making sure that it is kept secure; and

1.5.2.                    we make certain decisions on how to use and protect your personal data, but only to the extent that we have informed you about the use or are otherwise permitted by law.

2.       Application

2.1.             This Privacy Policy does not apply to other parties' sites, products or services, such as sites linked to, from or advertised on our site, or sites which link to or advertise our site.

2.2.             This Privacy Policy applies to you if you are:

2.2.1.                    a visitor to our website or user of our application (regardless of the device which you use to access it e.g. a computer, mobile phone, tablet etc); and

2.2.2.                    a customer who has ordered the goods or services that we provide.

2.3.              Please note that our site is not targeted at children under the age of 18.  

3.       What is personal data?

3.1.             Personal data refers to private information about an identifiable person, such as your name and surname, gender, age, date of birth, contact details (e.g. your home address, postal address, e-mail address or phone number), physical location, passport number and your image (such as a private photograph on a social networking site).

3.2.             Other information which might be "personal data” may include:

3.2.1.                    "device and device event information": We may collect information such as your IP address, unique device identifier, the nature of the device which you used to access our site (e.g. a computer, tablet or smart phone, and the type thereof), the geographic location from which you accessed our site (i.e. the geographic location of your device), hardware model and settings, operating system type and version, browser type and version, browser language, system activity, crashes;

3.2.2.                    "log information":  When you use our site, we may automatically collect and store certain information in server logs (i.e. our web servers automatically record and maintain a log of your activities when users access our site), which may include your "site activity information", such as details of how, when and for how long you accessed and used our site and other site traffic and use information (e.g. the date and time of your site requests, referral web pages (i.e. which site pages directed you to our site), landing pages (i.e. the page at which you accessed our site), URLs, which pages you accessed, the number of pages viewed and the order of those pages, the amount of time spent on those pages, the number of clicks and exit pages (i.e. sites which you navigated to when leaving our site);

3.2.3.                    "location information":  We may use various technologies to determine your actual location, such as geographical data from your device (which is usually based on the GPS or IP location); and

3.2.4.                    "unique application numbers":  Certain services include a unique application number. This number and information about your installation (for example, the operating system type and application version number) may be sent to us when you install or uninstall such a service or when that service periodically contacts our servers, such as for automatic updates.

4.       How we collect your personal data

4.1.             We collect your personal data in four ways, namely:

4.1.1.                    actively from you;

4.1.2.                    passively from your device when you use our site;

4.1.3.                    passively from social networking sites (subject to your privacy settings); and

4.1.4.                    passively from third party service providers.

4.2.             Why we process your personal data and how we use it

4.2.1.                    We use the information we collect to provide, maintain and improve our services, to develop new ones, and to protect us, our services and our users. We constantly strive to improve our users' experience, and so we also use the information we collect in order to offer you information and content which is more appropriately tailored for you.

5.       Monitoring

5.1.             We monitor communications where the law requires us to do so. We will also monitor where we are required to do so to comply with our regulatory rules and practices and, where we are permitted to do so, to protect our business and the security of our systems. 

5.2.             We may also collect, use and process your personal data for the following reasons:

5.2.1.                    to compile and use statistical information about you and other users and their access to and use of our site, browsing habits, click-patterns, preferences, demographics etc. which we may use to develop, provide and improve the site and our products and services, including, recommendations to users and tailoring information and content for users; 

5.2.2.                    to compile, use, disclose and trade with non-personal statistical information about our users and their access to and use of our site, browsing habits, click-patterns, preferences, demographics etc. which we and/or our advertisers may use to develop, provide and improve the site and our products and services, including targeted advertising to user groups.

6.       Retention of your personal data

6.1.             We retain personal data which we collect from you for as long as we need it and until there is a valid technical, legal or business reason for us to delete, destroy or de-identify it ("retained information"). 

6.2.             We will delete the information that we hold about you when we no longer need to hold it in terms of the law.

6.3.             Notwithstanding the above, we may keep all retained information for as long as you:

6.3.1.                    continue to access our site;

6.3.2.                    we are required by law, a code of conduct or a contract with you to keep it;

6.3.3.                    we need it for lawful purposes related to our activities;

6.3.4.                    we reasonably need it for evidentiary purposes; or

6.3.5.                    you agree to us keeping it for a specified further period. 

6.4.             We store all retained information in a cloud.

6.5.             Security measures

6.5.1.                    We take reasonable technical and organisational measures to secure the integrity of retained information, using accepted technological standards to:                          prevent unauthorised access to or disclosure of your personal data; and                          protect your personal data from misuse, loss, alteration or destruction. 

6.5.2.                    We require your credit card details, Internet banking details or PIN numbers for purposes of providing you with our products or services. We will keep the payment records (for finance, recordkeeping and audit purposes) on secure servers.  We will not disclose your banking details to any third party except to the extent necessary to process and record payments. 

6.5.3.                    Where we allocate you or replace a password which enables you to access certain parts of our site, we will do so in an automated manner and we do not store it. You are responsible for keeping your password confidential. Please notify us immediately and change your password if you become aware that your password has or may have become compromised or accessed by an unauthorised person. 

6.5.4.                    From time to time we review our information collection, storage and processing practices, including physical security measures, to keep up to date with best practice.

7.       Disclosure of your personal data

7.1.             We will not disclose your personal data other than as set out in this Privacy Policy, without your permission or otherwise as permitted or required under applicable law.

7.2.             We may disclose your personal data to:

7.2.1.                    our affiliates, related parties and members of our group in order to provide you with content, services and manage our relationship with you;

7.2.2.                    our employees, contractors and agents if and to the extent that they need to know that information in order to process it for us and/or to provide services for or to us, such as site hosting, development and administration, technical support, financial services such as processing of payments, delivery services, marketing services (only in respect of our site, products and services) and other support services;

7.2.3.                    any third party who acquires (or proposes to acquire) ownership or control of our assets, shares or management, or that of our affiliates, and/or our site, whether by sale, merger, acquisition or otherwise, and/or to any third party who we acquire (or propose to acquire) ownership of or control of assets, shares or management, whether by purchase, merger, acquisition or otherwise;

7.2.4.                    tax authorities, where we are required to do so (who, in turn, may share your personal data with foreign tax authorities as may be required);

7.2.5.                    lawyers, auditors and other provisional advisors in order to comply with applicable legal and regulatory requirements or to deal with any customer complaints or any litigation matters that may arise;

7.2.6.                    governmental agencies, exchanges and other regulatory bodies if we are required to do so by law or if we reasonably believe that such action is necessary to:                          comply with the law or with any legal process;                          protect and defend the rights, property or safety of ours, our affiliates or our customers, employees, contractors and agents or any third party;                          detect, prevent or deal with actual or alleged fraud, security or technical issues or the abuse, misuse or unauthorised use of our site and/or contravention of this Privacy Policy;                          protect the rights, property or safety of members of the public (if you provide false or deceptive information about yourself or misrepresent yourself as being someone else, we may proactively disclose such information to the appropriate regulatory bodies and/or commercial entities).

7.3.             We may use your personal data to compile profiles for statistical purposes, provided that the profiles or statistical data cannot be linked back to you by a third party. 

8.       Accuracy of your personal data

8.1.             You need to ensure that your personal data is accurate, complete, not misleading and up to date at all times to enable us to provide you with our products or service.

9.       Direct marketing

9.1.             When you register on the site you may choose not to receive marketing communications from us.  You may also change this choice in your privacy settings on our site.

9.2.             You may refuse to accept, require us to discontinue, or pre-emptively block any approach or communications from us if that approach or communication is primarily for the purpose of direct marketing ("direct marketing communications").

9.3.             You may opt out of receiving direct marketing communications from us:

9.3.1.                    at the time of registering on the site by ticking the relevant "opt-out" box; and

9.3.2.                    at any time by requesting us to desist from initiating any direct marketing to you.

10.    International data transfers

10.1.           We may transfer the personal data we collect about you to recipients in countries other than the country in which the information originally was collected for purposes of providing you with our products and services. You expressly agree to this transfer by your continued use of our site.

11.    Linking to third party sites

11.1.           To the extent any linked websites are not owned or controlled by us, we are not responsible or liable for the privacy practices of the third party site to which there may be a link on our site or to which you may log in from our site (e.g. integrated social networking services). 

11.2.           We suggest that you to read the privacy notice of each site which you visit and to determine your privacy settings in accordance with your personal preferences.

11.3.           In certain instances we will give you the option to manage some of your privacy settings on integrated social networking sites from our sites (e.g. to enable you to determine which of your personal data you would like to share via our site). 

12.    Changes to this policy

12.1.           We may change this Privacy Policy from time to time. If we do so, we will post the revised notice on our site and take reasonably practicable steps to ensure that you are aware of the updated Privacy Policy.

12.2.           Please check back frequently to see any changes.   

13.    Contact Us

13.1.           If you have any comments, queries or complaints in relation to this Privacy Policy or our processing of your personal data you are welcome to contact us:

13.1.1.                 via email at; or

13.1.2.                 via post at Belas Business Park, Edf. Huambo, Sala 80, Talatona, Luanda, Angola.

13.2.           If you contact us we may ask you to verify your identity before we can act on your request.

13.3.           Please note that we may reject requests only to the extent that we are permitted to do so by applicable law. This may include rejecting requests that are vexatious or frivolous, unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or which would be materially disproportionate to address.