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Privacy Policy

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1. Introduction

This Privacy Policy explains how we collect, use, store, share and protect personal data when you visit the Capsules.com website, apply for a trade account, use our customer portal, or otherwise deal with us.

Capsules.com is a business-to-business supplier of empty two-piece HPMC and gelatin capsules to trade customers such as manufacturers, contract packers and brand owners. We do not sell to consumers, and our website and portal are not directed at the general public.

We handle personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003 (PECR). This policy should be read together with our Cookie Policy and our Terms of Service.

Customers and visitors in the United States are supplied and served by CAPSULES DIRECT LTD from the United Kingdom. Personal data you provide through the US site is transferred to and processed in the United Kingdom under this policy.

2. Who we are

CAPSULES DIRECT LTD is the data controller for the personal data described in this policy. This means we decide how and why that data is processed.

  • Controller: CAPSULES DIRECT LTD
  • Company number: 17362490 (England and Wales)
  • VAT number: GB530725510
  • Registered office: Rowood House, 26 Murdock Road, Bicester, Oxfordshire, OX26 4PP, United Kingdom
  • Data protection contact: privacy@capsules.com
  • ICO registration: application C2059582, registration number to follow

We have not appointed a statutory Data Protection Officer, as one is not required for a business of our size and activities. Our Chief Executive Officer is responsible for data protection and can be reached at privacy@capsules.com.

3. Who this policy covers

This policy applies to personal data about people who deal with us in a business context: trade account applicants and their named contacts, authorized users of our customer portal, ordering, billing, quality and technical contacts at customer companies, contacts at suppliers and professional advisers, and visitors to our website.

Because we deal with companies rather than consumers, most of the data we hold is about individuals acting for a business, such as a buyer or a quality contact at a manufacturer. That information is still personal data where it identifies an individual, and it is protected by this policy.

4. Personal data we collect

We collect only what we need for the purposes set out in this policy. We do not intentionally collect special category data (such as health or biometric data) and we ask that you do not send it to us.

CategoryExamplesSource
Identity and contact dataFull name, job title or role, business email address, business telephone number, the company you representProvided by you when you apply for a trade account, are added as a portal contact, submit a form or contact us
Trade account application dataCompany name, trading address, company registration and VAT details, business sector, intended use, indicative volumes, references or trade information you supplyProvided by you in the application form
Country of inquiryThe country derived from your IP address at the time you submit a form, recorded against the inquiry or accountDerived automatically when you submit a form
Account and portal dataUser identifier, sign-in records, authentication tokens, roles and permissions, contacts linked to your company accountGenerated when an account is created and used
Order and transaction dataOrder requests, purchase order references, dispatch and tracking details, pricing applicable to your account, delivery contactsGenerated through your use of the portal and our order processes
Billing contact dataBilling contact name and email, invoice references, payment statusProvided by you and generated through invoicing. Card payments are made through a hosted payment page; we do not capture or store card details
Documents and correspondenceEmails, support requests, inquiries, artwork and specifications you provide, supplier qualification information, and records of access to documents such as certificates of analysis and specificationsProvided by you and generated through your dealings with us
Resource requests and newsletter choicesName, business email, role, selected answers, resource requested, signup source, and the wording and time of your consent or withdrawalProvided by you on the relevant form
Consented attributionCampaign information, first and last touch, recent document-download identifiers, and a Google Analytics browser identifier; advertising click identifiers only with separate advertising permissionBrowser storage after the relevant choice (see our Cookie Policy)
Form-security and delivery recordsCAPTCHA results, request references, technical security signals and temporary copies of submissions and attachments used for reliable delivery to our business management platformGenerated when you submit a form
Website usage and technical dataIP address, device and browser type, pages viewed, referring pages, region preference and detected country used to route UK and US visitorsCollected automatically when you use the website (see our Cookie Policy)

5. How we collect personal data

  • Directly from you, when you apply for a trade account through the customer portal, submit a form, request a resource, join our newsletter, place or request an order, contact our sales or support team, complete supplier qualification information, or correspond with us.
  • Automatically, when you use our website, through service and preference cookies, optional analytics and attribution where you have consented, and server logs. When you submit a public form without optional tracking permission, we may record the current page and campaign information already sent in that HTTP request; we do not reconstruct an earlier browsing history. Country captured from the connection is country-level only, not a US state.
  • From your colleagues, where an administrator or authorized contact at your company adds you as a portal user or as an ordering, billing, quality or technical contact.
  • From public sources, such as company registers and sanctions lists, where relevant to assessing or administering a trade account.

6. Purposes and lawful bases

UK GDPR requires a lawful basis for each use of personal data. Where we rely on legitimate interests, we have weighed those interests against your rights and freedoms.

PurposeLawful basis
Assessing and approving trade account applications, including identity, business, credit and sanctions checksSteps prior to a contract (Art 6(1)(b)); legitimate interests (Art 6(1)(f)) in dealing only with suitable trade customers
Creating and administering company accounts and portal user accessPerformance of a contract (Art 6(1)(b)); legitimate interests in secure company-level access
Authenticating users and securing the portalLegitimate interests in keeping accounts and data secure; performance of a contract
Routing inquiries to the right regional team, applying the right currency and price book, and checking that we can supply your territory (using the country derived from your IP address and the details you give us)Legitimate interests in handling inquiries efficiently and lawfully
Processing order requests and providing order, dispatch and tracking informationPerformance of a contract
Providing customer-specific pricing and documents (certificates of analysis, specifications, regulatory and batch traceability documents)Performance of a contract; legal obligation (Art 6(1)(c)) for traceability records
Invoicing and facilitating paymentPerformance of a contract; legal obligation for accounting and tax records
Responding to inquiries and providing customer supportLegitimate interests; performance of a contract where related to an existing account
Sending service and transactional communications (sign-in emails, order and account notifications)Performance of a contract; legitimate interests in administering the service
Operating, securing and improving the website and portalLegitimate interests in providing a secure, functional service; strictly necessary cookies are exempt from consent under PECR
Google Analytics, optional campaign and document attribution, and advertising click identifiersConsent (Art 6(1)(a)) and PECR; advertising attribution has a separate choice
Handling a requested article resource and recording the permission givenYour consent on the resource form; any newsletter subscription is a separate, optional choice
Sending the newsletter you requestedConsent; you can withdraw it and every marketing message includes an opt-out
Sending business-to-business marketing about our products and services to relevant business contactsLegitimate interests, subject to PECR; consent where required. Every marketing message carries an opt-out
Assessing supplier qualification information and maintaining supplier recordsLegitimate interests in selecting and managing suitable suppliers; legal obligations where applicable
Complying with legal, regulatory, tax and accounting obligationsLegal obligation
Establishing, exercising or defending legal claims, and preventing fraudLegitimate interests; legal obligation where applicable

You can object to processing based on legitimate interests and you can withdraw consent at any time. Withdrawal does not affect processing carried out before it.

7. Automated assistants and artificial intelligence

We may introduce automated assistants to help with product information, accounts and support. Where you interact with an automated assistant, we will identify it as automated and explain how information in the conversation is used before you provide it.

Before using a provider for customer conversations, we will put in place appropriate data-processing terms, including a prohibition on using your data to train the provider's own models. We may review conversations to check quality and resolve issues, and use de-identified, aggregated information to improve our systems. We do not use identifiable customer conversations to train our own models. Any new use requiring consent will start only after that consent is obtained.

We do not make decisions about you based solely on automated processing that produce legal or similarly significant effects. Decisions on trade account applications are made by a member of our team.

8. Who we share personal data with

We do not sell personal data. We share it only where necessary for the purposes in this policy, and our processors act only on our instructions under written contracts that meet the requirements of Article 28 of the UK GDPR. Recipients fall into these categories:

  • Our business management platform, which runs our customer records, orders, invoicing, payment links and transactional email.
  • Our website hosting, private submission-storage, operational-alert email and infrastructure providers, including the services that queue a request until our business management platform receives it.
  • Our form-security and rate-limiting providers, which help prevent automated abuse.
  • Our portal hosting and authentication services.
  • Our email and productivity provider.
  • Our website analytics provider (Google Analytics), where you have consented to analytics cookies.
  • AI service providers where a feature described in section 7 is introduced, subject to the safeguards explained there.
  • Logistics, courier and freight providers, to deliver orders and provide tracking.
  • Professional advisers, including lawyers, accountants, auditors and insurers, where reasonably necessary.
  • Regulators, law enforcement and other authorities, where required by law or to protect our rights.
  • Any group company that supplies or supports our customers, where relevant to providing services to you.
  • A buyer or successor in the event of a sale, merger or reorganization of our business, subject to confidentiality and data protection safeguards.

9. International transfers

We are based in the United Kingdom and personal data you provide is processed there and by our providers in the United Kingdom, the United States and other countries. The United Kingdom's data protection law gives you the rights described in section 11 regardless of where you are located. You can contact us for information about the safeguards used for a particular transfer.

10. How long we keep personal data

We determine retention from the purpose of each record: whether a request is open, whether follow-up or an ongoing business relationship needs it, whether a complaint or legal claim needs it, and whether a legal, accounting or quality obligation applies. A retention or deletion review takes account of these criteria, the relevant obligations and any hold.

RecordHow retention is determined
Enquiries, quotes, samples and trade account applications, including declined applicationsWhile needed to handle the request, carry out relevant follow-up, evidence the application decision or deal with a complaint or claim. A declined application may need to remain auditable and inform a later reapplication.
Customer account, order and portal recordsWhile needed for the account relationship, outstanding orders or balances, support, audit and applicable record-keeping obligations. Closing portal access does not erase the related business records.
Quality and traceability records, including certificates of analysis and batch recordsAccording to applicable quality, traceability and regulatory requirements, customer agreements and the need to investigate product issues.
Invoices, accounting and tax recordsAccording to applicable tax and accounting record-keeping obligations and any unresolved transaction, audit or claim.
Correspondence, support records and supplier qualification informationWhile needed for the request, relationship, qualification, quality issue, complaint or claim to which they relate.
Resource requests and newsletter recordsFor the requested resource and related permission evidence; newsletter records while subscribed, with a limited suppression and consent record where needed after withdrawal to respect that choice.
Temporary website submission and attachment copiesUsed to deliver and recover requests reliably. Copies whose delivery has not been confirmed, or which need investigation, are retained for resolution. Confirmed delivered copies are eligible for the website's guarded cleanup after 30 days; this does not delete the business record received by our business management platform.
Hosting, security and service logsAccording to the provider's configured service retention and the need to diagnose faults, detect abuse or investigate an incident; longer where a legal duty or unresolved incident requires it.
Google Analytics informationAccording to the property's configured retention settings. Aggregate reports may remain after individual event data expires. Contact us for the current setting or to request review of information associated with your browser identifier.
Cookies and browser storageThe specific lifetimes and controls in our Cookie Policy. Browser storage lifetimes are separate from the retention of submitted business records.

Contact privacy@capsules.com if you want us to review a particular record or explain the period that applies to it.

11. Your rights

Under UK GDPR you have the right to be informed; to access a copy of your personal data; to have inaccurate data corrected; to have data erased in certain circumstances; to restrict processing in certain circumstances; to data portability for certain data; to object, including to direct marketing and to processing based on legitimate interests; and rights relating to automated decision-making.

To exercise any of these rights, contact privacy@capsules.com. We may need to verify your identity. We will respond within one month, and will tell you if a complex or numerous request needs up to two further months. Exercising your rights is free of charge in almost all cases.

If you are a resident of a US state with its own privacy law, you may have additional rights under that law, including rights to know, delete and correct personal data and to opt out of its sale or sharing. We do not sell or share personal data for advertising purposes. You can exercise any applicable right by contacting privacy@capsules.com.

12. Complaints

If you have a concern about how we handle your personal data, contact us first at privacy@capsules.com and we will do our best to resolve it. You also have the right to complain to the Information Commissioner's Office, the UK supervisory authority: ico.org.uk, helpline 0303 123 1113, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

13. Security

We use appropriate technical and organizational measures to protect personal data against unauthorized or unlawful processing and against accidental loss, destruction or damage. These include access controls and role-based permissions, encryption in transit, secure authentication, and reputable hosting and infrastructure providers. Access to the customer portal is restricted to authorized users, and each user sees the data for their company that their role allows.

If we suffer a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the ICO and, where required, the affected individuals, in line with our legal obligations.

14. Children

Our website, products and portal are for business customers and the professionals who work for them. They are not directed at children and we do not knowingly collect personal data about children. If you believe a child has provided personal data to us, contact privacy@capsules.com and we will delete it.

15. Cookies

We use service cookies to keep the portal secure and remember your privacy choices and regional preferences. You can turn automatic regional suggestions off. Google Analytics and optional attribution use your consent, with a separate choice for advertising click identifiers. We honor Global Privacy Control signals, and do not use the discontinued basic page-counting service. Our Cookie Policy describes the cookies and similar browser storage in use and how to control them.

16. Changes to this policy

We may update this policy to reflect changes in our practices, technology, legal requirements or business. When we make a material change we will update the date at the top of this page and, where appropriate, notify account administrators.

17. Contact

  • CAPSULES DIRECT LTD
  • Rowood House, 26 Murdock Road, Bicester, Oxfordshire, OX26 4PP, United Kingdom
  • Company number 17362490
  • VAT number GB530725510
  • Data protection: privacy@capsules.com
  • General inquiries: sales@capsules.com
  • Telephone: (816) 445-0042

This policy and any dispute relating to it are governed by the laws of England and Wales and subject to the exclusive jurisdiction of its courts.