PRIVACY POLICY

Effective Date: October 1,2023

Website: https://developer.capstone.cn.com

Company: Capstone Limited ("Capstone", "we", "us", or "our")

1. INTRODUCTION

Capstone Limited is committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, store, disclose, and safeguard your information when you visit our website https://developer.capstone.cn.com (the "Website") or interact with our services.

By using our Website or services, you agree to the terms outlined in this Privacy Policy.

2. INFORMATION WE COLLECT

We collect information that you voluntarily provide and data that is automatically collected during your interaction with our Website.

2.1 Personal Information Provided by You

Full Name

Email Address

Phone Number

Company Name

Billing and Wire Transfer Details

Identification Documents (if applicable for compliance)

Any other information voluntarily provided through contact forms, registration, or project submission.

2.2 Automatically Collected Information

IP Address

Browser Type and Version

Operating System

Usage Data (e.g., pages viewed, time spent, referring URLs)

2.3 Information Collected During Transactions

For clients and developers, we collect transaction-related details, including wire references, invoice data, project deliverables, and signed agreements. This data is used for audit, legal, and financial recordkeeping purposes.

3. HOW WE USE YOUR INFORMATION

We use your information for the following purposes:

To manage and deliver development services and proprietary code solutions

To process wire transfer payments to developers and contractors

To issue, monitor, and validate reference codes used in financial disbursements

To communicate updates, confirmations, and service-related notices

To comply with legal, regulatory, and financial institution requirements

To improve site functionality, user experience, and service delivery

To prevent fraud, conduct KYC/AML verification, and support risk assessments

4. LEGAL BASIS FOR PROCESSING

We process your data under the following legal bases:

Your consent (where applicable)

The performance of a contract (e.g., developer agreements or service delivery)

Legal obligations (e.g., AML, tax, or financial regulations)

Legitimate interests, such as improving and securing our services

5. SHARING YOUR INFORMATION

We do not sell or rent your personal data. We may share your data with:

Financial institutions involved in processing payments

Compliance vendors (e.g., KYC/AML verification providers)

Contracted developers or project managers under strict NDAs

Service providers who assist in hosting, analytics, and operations

Government or regulatory authorities, when legally required

All third-party processors are contractually obligated to handle your data securely and lawfully.

6. DATA RETENTION

We retain your information only as long as necessary to:

Fulfill contractual and legal obligations

Comply with financial audit and reporting requirements

Resolve disputes and enforce agreements

Data related to financial transactions and identity verification may be retained for 5 to 7 years, depending on jurisdictional laws.

7. DATA SECURITY

Capstone uses industry-standard security measures, including:

End-to-end encryption for financial and personal data

SHA-256 encryption on sensitive fields

Multi-Factor Authentication (2FA) for system access

Audit trails and access logs for internal accountability

8. YOUR PRIVACY RIGHTS

Depending on your jurisdiction, you may have the right to:

Access, correct, or delete your personal data

Withdraw consent (where applicable)

Object to processing

Request data portability

File a complaint with a data protection authority

To exercise any of these rights, contact us at: support@capstone.cn.com

9. INTERNATIONAL DATA TRANSFERS

Data collected may be transferred to and processed in countries where Capstone or its service providers operate, including the United States, European Union, and Asia-Pacific regions. We ensure adequate protection through contractual safeguards and lawful frameworks.

10. THIRD-PARTY LINKS

Our Website may contain links to third-party sites. We are not responsible for the privacy practices of such sites and encourage users to read their privacy policies.

11. POLICY UPDATES

We may update this Privacy Policy from time to time. Updates will be posted on this page with a revised effective date. We recommend reviewing it periodically.

12. CONTACT US

If you have questions about this Privacy Policy or wish to exercise your rights, contact:

Capstone Limited - Data Protection Office

support@capstone.cn.com