Privacy Policy

NEXA Data Protection and Privacy Policy

Captivate ApS

Dampfærgevej 2 2100 København Ø

2100 København DK

Company registration number: 43767879 (the ”Organization”)

This is version 1 last updated the 07.07.2025 13:39.

Table of contents

Introduction
Collecting personal data with cookies
Types of personal data processed
Purposes of processing the personal data
Legal basis for processing personal data
Disclosure and transfer of personal data
Erasure and retention of personal data
Data subject rights
Changes to this Policy
Contact

1. Introduction

1.1 This Data Protection and Privacy Policy (the “Policy”) describes how Captivate ApS (“us”, ”we” or ”our”) when acting in the role of a controller, collects and processes your personal data relating to the purchase of services, membership, products, or your use of our website,

1.2 The Policy is prepared and made available to comply with the General Data Protection Regulation (2016/679 of 27 April 2016) (the ”GDPR”) and the rules included herein on information to be provided to you.

2. Collecting personal data with cookies

2.1 By visiting and using our website(s), cookies are collected and used based on your consent. Information in these cookies include ("Cookiedata"):

a) browser type

2.2 We use sessions cookie to log your usage of the Nexa Platform. Only general log-in information is being tracked.

Session Cookie Name: sessionid

Purpose: Maintains your login session after you sign in. It allows the website to recognize you across different pages so you don’t have to log in repeatedly.

Type: Session cookie (expires when you close your browser) Essential: Yes

Data Stored: A unique, anonymized session identifier (no personal data directly stored)

CSRF Token Cookie Name: csrftoken

Purpose: Protects against Cross-Site Request Forgery (CSRF) attacks by verifying that form submissions come from your browser.

Type: Persistent cookie (typically expires after 1 year) Essential: Yes

Data Stored: A random token associated with your session to validate requests

2.3 Cookiedata is used for: prevention of fraud, scams and illegal use of our website or services, improvement of the website(s) and user experience, to deliver our products, services or goods .

2.4 Our use of cookies for the purpose of collecting personal data is carried out in accordance with section 3 of the Executive Order (No. 1148 of 9 December 2011).

2.5 If you wish to limit or decline the cookies placed on your computer when visiting our website you can do so at any time by changing your browser settings. However, you should be aware that if you decline or reject cookies it will impact the functionality of the website which means that there are features on the website that you will not be able to see. Any browser allows you to delete cookies collectively or individually. How this is done depends on the browser you use. Remember to delete the cookies in all browsers, if you use several different browsers.

2.6 Below you will see an overview of the duration of the cookies we use: Up to 1 year - please see per cookie

3. Types of personal data processed

3.1 We process personal data about you when this is necessary and in accordance with the applicable legislation. Depending on the specific circumstances, the processed personal data include the following types of personal data:

account status (customer points, payments etc.)
address
Customer number
email
invoicing and bookkeeping data and documentation
IP addresses
name
password
purchasing history
telephone number
username
payment card details

3.2 If we need to collect more personal data than specified above, we will inform you by updating this Policy.

4. Purposes of processing the personal data

4.1 We will only process your personal data if we have a legitimate purpose and in that case in accordance with the rules of the GDPR. The personal data we collect about you is processed for the following purposes:

To administrate a customer or membership club
To communicate and exchange data with public authorities when required by law.
To deliver products or services.
To facilitate a sales process.
To improve our products, services, or website.
To prevent fraudulent behavior or misuse of our products, services and website, including the processing of personal data for the purpose of legal actions.
To provide service messages and information.
To provide support and service messages, including responding to questions and complaints and sending updates about our products and services.
To store personal data to comply with applicable legislation requirements such as bookkeeping acts.

5. Legal basis for processing personal data

5.1 We only process your personal data when we have a legal basis to do so in accordance with the GDPR. Depending on the specific circumstances, the processing of personal data is done on the following legal basis:

The legal basis for the processing of such personal data is consent, in accordance with GDPR, Article 6(1)(a). You can withdraw your consent at any time by contacting us via the contact details provided at the end of this Policy. If you withdraw your consent, the personal data processed will be deleted, unless it can or must be processed in order to comply with legal obligations.
The processing is necessary for the performance of a contract to which the data subject is a party in accordance with GDPR, Article 6(1)(b), the first indent.
The processing is necessary to comply with applicable legislation in accordance with GDPR, Article 6(1)(c).
The processing is necessary in order to take steps at the request of the data subject prior to entering into a contract in accordance with GDPR, Article 6(1)(b), last indent.
The processing is necessary in order to protect the vital interests of the data subject or of another natural person in accordance with GDPR, Article 6(1)(d).

5.2 In addition to the above, in some instances we analyze individual customers' or users' personal preferences and/or behavior with the purpose of using such analyses for marketing, sales or similar commercial activities. Before we perform such processing, we will collect a consent hereto. We perform this processing activity for the following purposes: We might use the customers preferences or behavior in order to optimize, or develop new features we see relevant - to improve the services to the clients.

6. Disclosure and transfer of personal data

6.1 We only transfer personal data to other entities when it is legally permitted or required.

7. Erasure and retention of personal data

7.1 We ensure that the personal data is deleted when it is no longer necessary for the processing purposes described above. However, we retain your personal data to the extent that we are legally obligated, as is the case with for example accounting and bookkeeping materials and records. If you have any questions about our retention of your personal data, you may contact us by using the email mentioned in the last section of this Policy."

8. Data subject rights

8.1 As a data subject under GDPR, you have a number of rights.

8.1.1 You have the right to request access to the personal data we process about you, the purposes we process the personal data, and whether we disclose or transfer your personal data to others.

8.1.2 You have the right to have incorrect information rectified.

8.1.3 You have the right to have certain personal data deleted.

8.1.4 You may have the right to restriction of our processing of your personal data.

8.1.5 You may have the right to object to our processing of your personal data based on reasons and circumstances that pertain to your particular situation.

8.1.6 You have the right not to be subject to a decision based solely on automated means, without human interference unless the decision (1) is necessary for entering into, or performance of a contract between you and the Organization, (2) is authorised by law, or (3) is based on your explicit consent.

8.1.7 If the processing of your personal data is based on your consent, you are entitled to withdraw such consent at any time. Withdrawal of your consent will not affect the lawfulness of the processing carried out prior to your withdrawal.

8.1.8 You are entitled to receive personal data which you have provided to us in a structured, commonly used, and machine-readable format (data portability).

8.1.9 You can always lodge a complaint with the data protection authority.

8.2 Your rights may be subject to conditions or restrictions. Accordingly, there is no certainty that you will be entitled to for example data portability in the specific situation; it will depend on the circumstances of the processing.

8.3 More information about data subject rights can be found in the guidelines of the national data protection authorities.

8.4 Please use the contact details below if you want to use your rights.

8.5 We try to meet your wishes about our processing of personal data, but you can always file a complaint to the data protection authorities.

9. Changes to this Policy

9.1 We reserve the right to update and amend this Policy. If we do, we correct the date and the version at the top of this Policy. If we make significant changes, we will provide notification by way of a visible notice, for example on our website or by direct message.

10. Contact

10.1 You may contact us at the below specified email if you:

a) disagree with our processing or consider our processing of your personal data infringes on the law,

b) have questions or comments to this Policy, or

c) want to invoke one or more of your rights as a data subject described in this Policy.

If you have questions or comments to this Policy or if you would like to invoke one or more data subject rights, please contact us at compliance@captivateint.com or +45 44 45 46 47.