Last updated 04/17/20
CAI International, Inc. Privacy & Cookies Policy
1. Introduction
CAI International is committed to the protection and security of your personal data. This Privacy & Cookies Policy (“Privacy Policy”) explains how we will collect, process, use or share any personal data we collect from you, or that you provide to us when you use this website www.capps.com (the “Website”).
CAI International is the controller of your personal data.
By “personal data”, we mean any information which either on its own or in combination with data enables us to identify an individual and includes any unique identifier such as IP address, device ID or other online identifier.
Please read this Policy to understand how we may process your personal data.
By visiting the Website, you are acknowledging the terms of this Privacy Policy. Any external links to other websites are clearly identifiable as such, and we are not responsible for the content or the privacy policies of these other websites.
2. Types of Information Collected
Communications via our Website: We collect personal data when you provide it to us through communications via our Website. This includes where you have contacted us through the channels listed on the Website and situations in which you have chosen to provide the information to us, including, for example, for recruitment purposes.
Services you request: Where you request a service from us, we will collect your personal data in order to process your request and otherwise contact you following such a request.
The type of personal data we may collect includes identity data (including name), contact data (including email address and telephone number), country, location, language preference, employment data (including job description), transaction data (details of services you have purchased or are interested in purchasing from us) and any other personal data you provide to use via the “Contact” and related functions of the Website.
3. Purposes for Processing your Personal Data
We process any personal data you provide to us to enable us to perform a contract we are about to enter into or have entered into with you, to ensure compliance with local legal and regulatory requirements and for the purposes of our legitimate business interests, including:
• to provide you with the information, products and services that you request from us;
• to enable us to respond to an enquiry or other request you make when you contact us via our Website;
• to comply with our legal obligations, standards, policies and procedures;
• to notify you about changes to our service;
• to enable us to issue a notice or corrective action to you in relation to any of our services, if required;
• to better understand how you interact with our Website, including its functionality and features, and ensure that content is presented in the most effective; and
• to provide you with information about other services we offer that are similar to those that you have already purchased or enquired about and we feel may interest you, as described in the “Marketing” section below.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending party direct marketing communications to you via email. We will seek your express opt-in consent before we send you any marketing communications.
4. Marketing
We may use your personal data to send you promotional or marketing-related information (such as newsletters) from CAI International where it is linked to the product or service we are providing to you. You may at any time unsubscribe by clicking on the “unsubscribe” link at the bottom of each such communication.
Alternatively, you may also send requests about your contact preferences and changes to your information by emailing websupport@capps.com. If you opt out of receiving marketing or promotional materials, we may still send you non-promotional emails, such as service announcements, information notices about our services and administrative messages
5. Sharing Of Personal Information
We may share your personal data with:
• our group companies;
• Government bodies and agencies in the USA and overseas to comply with our legal and regulatory obligations;
• a prospective seller or buyer in the event of a sale or purchase of any CAI International business or asset so that the buyer can continue to provide you with information and services;
• our service providers that we engage to provide services for us. Where we provide your personal data to third party service providers, they are required to keep your personal data confidential and secure, and must only use your personal data as instructed by us; and
• our distributors, business partners, or other service providers, including for marketing purposes or where you have chosen to share your personal data through various features and functionality provided via our Website.
We may also disclose your personal data where it is necessary to enforce or apply this Privacy Policy or other agreements, to investigate or protect the rights, property or safety of CAI International and our group companies, our products and services and our customers, distributors or business partners or to prevent or take action regarding illegal activities or fraud, situations involving potential threats to the safety of any person or as evidence in litigation.
6. Cookies
We use cookies and other similar technologies to distinguish you from other users of the Website.
A cookie is a small data file that is placed on your computer or mobile device by your web browser when you visit a website. It is a tool that stores information about website visits, recognizes you and your preferences each time you visit our Website, and ensures website functionality and generally improving your experience of a website.
A cookie file can contain information such as a user ID that the site uses to track the pages you have visited, but the only personal data a cookie can contain is information you supply yourself. Some parts of our Website use cookies to track user traffic patterns. We do this in order to determine the usefulness of Website information to our users and to see how effective our navigational structure is in helping users reach that information. We do not connect this information with data about individual users.
The cookies we use are categorized into four groups:
• Strictly Necessary cookies - these cookies are used for technical reasons and are necessary to enable the Website to operate efficiently so that you can navigate the Website with ease and use specific features. These include, for example, cookies that help us to debug any errors. If these cookies are blocked or disabled, some of the Website may not operate effectively.
• Performance cookies - these cookies are used to obtain statistics about the number of users of the Website and how such users interact with the Website. These cookies collect data that is aggregated and therefore cannot be used to ascertain an individual's identity. Such cookies allow us to continuously improve the Services and to provide users with a better, more user-friendly, online experience.
• Functionality cookies - these cookies are used to improve the functionality of the Services and make it easier to use. They help us to identify you as a repeat user of the services and help us remember your preferences (for example, your choice of language or region), improving your user experience.
• Analytical - These cookies record your visit to the Website, the pages you have visited and the links you have followed and are used to generate usage statistics and help us to understand user preferences and how improve delivery of the Website and our Services.
We use other tracking technologies, such as third party tags. Cookies can be persistent by remaining on your computer until you delete them or be based on your browsing session where they delete once you close your browser. First party cookies are used and controlled by us to provide services on the Website.
Please note that third parties (including, for example, providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
You have the right to decide whether to accept or reject cookies. If you don’t want to receive cookies, you can modify your browser so that it notifies you when cookies are sent to it or you can refuse cookies altogether. You can also delete cookies that have already been set. If you wish to restrict or block web browser cookies which are set on your device then you can do this through your browser settings; please visit your browser's help menu for further details. Please note that if you choose to reject cookies, doing so may impair some of the Website’s functionality.
Google Analytics
We use Google Analytics to collect information about how users use the Website. The information generated by the cookie about your use of the Website will be transmitted to and stored by Google on servers in the USA.
Google will use this information on our behalf for the purpose of analyzing your use of the Website, compiling reports on Website activity and providing other services relating to Website activity and internet usage. The IP address that your browser conveys within the scope of Google Analytics will not be associated with any other data held by Google. You can also opt-out from being tracked by Google Analytics in the future by downloading and installing ‘Google Analytics Opt-out Browser Add-on’ for your current web browser: http://tools.google.com/dlpage/gaoptout?hl=en .
7. Security and Storage Of Your Personal Information
We will take reasonable steps (including appropriate technical and organisational measures) to ensure your personal data is processed securely to protect the confidentiality, integrity and availability of your personal data and in accordance with this Privacy Policy. However, the nature of the internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the internet and any transmission is at your own risk.
Your personal data collected via the Website will be stored on servers located in the United States of America. It may also be processed by CAI International staff or by one of our service providers operation in other locations.
We have implemented appropriate safeguards, to protect your personal data when it is transferred outside the European Economic Area (“EEA”), including the execution of data transfer agreements with recipients of the information. For access to copies of these agreements please contact us by email at datareq@capps.com or by mail to "ATTN: Legal - PII requests", CAI International, Steuart Tower, 1 Market Plaza Suite 2400, San Francisco CA 94105 USA. We will process any request in line with any local laws and our policies and procedures.
8. Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
9. Your Rights
You may inform us of any changes in your personal data. We will process your request in accordance with applicable data protection laws. We may ask you for additional information to confirm your identity and for security purposes, before processing your request.
If you are located in the EEA, you may have the right to: (a) request access to personal data we hold about you; (b) request we correct any inaccurate personal data we hold about you; (c) request we delete any personal data we hold about you; (d) restrict the processing of personal data we hold about you; (e) object to the processing of personal data we hold about you; and/or (f) where we process your personal data to fulfil a contract between us, receive any personal data we hold about you in a structured and commonly used machine-readable format or have such personal information transmitted to another company.
To exercise any of your rights in connection with your personal data, please contact us by email at datareq@capps.com or by mail to "ATTN: Legal - PII requests", CAI International, Steuart Tower, 1 Market Plaza Suite 2400, San Francisco CA 94105 USA. We will process any request in line with any local laws and our policies and procedures. If you are located in the EEA, you have the right to lodge a complaint about how we process your personal data with the supervisory authority in your country.
10. Changes To This Policy
Any changes to this Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this Privacy Policy.
11. Contact Us
If you have any questions about the processing of personal data via this Website, please contact us at the following address websupport@capps.com. If you contact us, we will do our utmost best to address any concerns you may have about our processing of your personal data.