‍Introduction

CapeZero, Inc. ("CapeZero" or "We") respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit our website www.capezero.com (our "Website") and/or access our products, services, features or tools through our Website, application programming interfaces and software (together with our Website, the “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Privacy Policy is governed by our Terms of Service. Defined terms used herein and not otherwise defined have the meanings set forth in the Terms of Service.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR PERSONAL INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE WEBSITE OR USE OUR SERVICES.  

By accessing or using the Website or the Services, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy below). Your continued use of the Website or the Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.  

Personal Information We Collect

Information You Provide to Us  

The information we collect on or through our Website may include:

• Basic Account Information: We ask for basic information from you in order to set up your account. For example, we require individuals who sign up for the Services (“Users”) to provide a name and valid email address. If your single sign-on service provider provides a picture, we may collect that information as well.
• Transaction and Billing Information: If you buy a subscription to the Services from us, you will provide additional personal and payment information that is required to process the transaction and your payment, such as your contact information.
• Communications With Us: You may also provide us information when you communicate with us, including when you contact us about a support question, provide feedback about the Services, or engage in sales discussions with us, each of which may include personal information.
• Marketing Data: You may provide information regarding your preferences for receiving our marketing communications and details about your engagement with them.

Information We Collect Through Our Services

We also receive information from you that you input and include when you use the Services. For example, any material that you share in your deal spaces on our Website (“Deals”) will be collected. This user-generated content may also include data, photos, images, music, videos, comments, questions, messages, and other content or information that you generate, transmit, or otherwise make available on the Services, as well as associated metadata.  

Information We Collect Through Automatic Data Collection Technologies  

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, unique device identifiers, referring site, date and time of access, mobile network information and browser type.
• The approximate location of your device determined from your IP address.  
• Information about your usage of our Services. For example, we collect information about the actions that administrators and Users perform on our Services, as well as the number of users accessing our Website.  

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.  
• Web Beacons. Our Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit CapeZero, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).  
• Flash Cookies. Certain features of our Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Services. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Share Your Information below.

Information We Collect From Third Parties

We may combine personal information we receive from you with personal information we obtain from other sources, including but not limited to:

• Public Sources: such as social media platforms or online news sources.
• Data Providers: such as information services and data licensors that provide demographic and other information.
• Marketing Partners: such as joint marketing partners and event co-sponsors.

Information You Provide During the Job Application Process

We may also receive information about you if you submit a job application, inquire about opportunities at CapeZero, provide us your information at a recruiting event, or if we receive information about you from third parties in connection with our recruiting activities. Throughout this Privacy Policy, we will refer to this information as "Recruiting Data". Recruiting Data may include:

• Name and contact information such as phone number, email address, and postal address;
• employment history such as prior employers and dates of employment;
• education history such as degrees earned and institutions attended;
• resume, CV, educational transcripts, and any information contained in or with such documentation;
• job qualifications and work eligibility information such as country of residence, visa and immigration status, and citizenship;
• reference information, such as name and contact details of your references;
• compensation information that you voluntarily provide, and which may depend on your region and applicable laws and regulations;
• background check information, subject to applicable law; and
• sensitive personal information that you provide voluntarily or which we request on a non-mandatory basis in order to comply with applicable law

You are responsible for the Recruiting Data you provide or make available to us and all Recruiting Data you provide must be truthful, accurate, and not misleading in any way. You may not provide Recruiting Data that is obscene, defamatory, infringing, malicious, or that violates any law. To the extent you voluntarily provide any sensitive or special categories of information, as may be defined in applicable laws, you explicitly consent to our processing of such information as described in this Privacy Policy. Depending on your region or the region where an opportunity is located, we may be required to process certain sensitive personal information to comply with applicable local law. You are responsible for providing any notices and obtaining any consents necessary for us to collect and use personal information of your references as described in this Privacy Policy.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and provide our Services to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To charge you for any of our paid Services.
• To provide you with notices about your account, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To further develop and improve our Services.
• To monitor and analyze trends and better understand how Users interact with our Services, which helps us improve our Services and make them easier to use.
• To measure, gauge, and improve the effectiveness of our advertising, and better understand User retention and attrition.
• To monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of CapeZero and others, including enforcing our Terms of Service and/or other agreements, which may result in us declining a transaction or the use of our Services.
• To provide webinars and training sessions.
• To communicate with you in response to your inquiries regarding the Services or otherwise, such as in response to sales inquiries.
• To communicate with you, for example through an email about offers and promotions offered by CapeZero and others we think will be of interest to you, solicit your feedback in writing, on conference calls, or other channels, or keep you up to date on CapeZero and our products.  

• To personalize your experience using our Services and target our marketing messages to groups of our users.
• For Recruiting Data, to review and evaluate an application you submit, communicate with you regarding your application or other interest in CapeZero opportunities; process your onboarding if you are hired; operate, improve, and maintain the security of our recruiting process; and comply with applicable laws and otherwise operate our business.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

How We Share Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.  

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To subsidiaries, employees and independent contractors that need to know the information in order to help us provide our Services or to process the information on our behalf. We require our subsidiaries, employees and independent contractors to follow this Privacy Policy for personal information that we share with them.
• To other Users with access to your Deals. For example, if you join a Deal owned by another Organization, or collaborate with other Users on our Services, we may share basic information about you such as your name, email address and profile picture with the other Users or Organizations.
• To your employer or other relevant organization (“Organization”) in certain circumstances:

• If you register a CapeZero account or associate a CapeZero account with an email address provisioned by your Organization, CapeZero may share information about you and any deals created or managed by you with your Organization. Such information could include your name, email address, and profile picture, as well as the Deal name, membership size, creation date of your Deal, and content within your Deal.  
• If (i) you create a CapeZero account or access our Services and the domain of the email address associated with your account is owned by an Organization and (ii) such Organization wants to establish an enterprise account with CapeZero or otherwise has requested that CapeZero inform it of any of its email addresses registered with CapeZero, your email address associated with such Organization may be shared with the Organization to provide you additional Services, integrate your CapeZero account with the Organization’s, or otherwise as elected by the Organization. If the Organization ultimately creates an enterprise account with CapeZero, the remainder of your personal information associated with accounts registered with the Organization’s email domain may be disclosed to the Organization as described above. We may also share your personal information with the Organization (such as their accounting department) or the credit card account holder to validate your payment if you purchase Services using a credit card.

• To third party vendors who need to know information about you in order to provide their services to us, or to provide their services to you. This group includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information or technology providers that enable certain features in our Services), those that assist us with our marketing efforts (e.g., by providing tools for identifying a specific marketing audience or improving our marketing campaigns), those that help us understand and enhance our Services (like analytics providers), and those that help us conduct our recruiting and hiring activities (such as recruiting firms or background check providers). If you connect your account to certain vendors that are third party integrations, certain information will be shared between such vendor and CapeZero to facilitate the integration.    
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of CapeZero's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by CapeZero about our Services users is among the assets transferred.
• To third parties to market their products or services to you if you have consented to these disclosures. For more information, see Choices About How We Use and Share Your Information below.
• To fulfill the purpose for which you provide it.  
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Service and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of CapeZero, our customers, or others.  

How Long We Keep Personal Information

We generally discard information about you when we no longer need the information for the purposes for which we collect and use it, which are described in How We Use Your Information above, and we are not legally required to continue to keep it. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.  

Choices About How We Use and Share Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:  

• Limit the Information that You Provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services may not be accessible.
• Choose Not to Use Certain Features: You may choose not to use certain features within our Services where the use of such features results in the processing of information you submit through the feature by a third party.  
• Tracking Technologies and Advertising. At this time, CapeZero does not respond to "do not track" signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using our Website, with the drawback that certain features of the Website may not function properly without the aid of cookies.
• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email with your request to info@capezero.com.  
• Promotional Offers from CapeZero. If you do not wish to have your contact information used by CapeZero to promote our own or third parties' products or services, you can opt-out by following the instructions in those messages or by sending us an email stating your request to info@capezero.com. This opt out does not apply to other messages, like those about your account and legal notices.
• Delete Your Account: While we’d be sad to see you go, if you no longer want to use our Services, you can delete your CapeZero account. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Personal Information above, for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.

We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

Residents of certain states may have additional personal information rights and choices. Please see Your State Privacy Rights below for more information.

Accessing and Correcting Your Information

You can review and change your personal information by logging into our Services and visiting your account profile page. You may also send us an email at info@capezero.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your User account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. If you delete your User Contributions from the Services, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Users. Proper access and use of information provided on the Services, including User Contributions, is governed by our Terms of Service.

Residents of certain states may have additional personal information rights and choices. Please see Your State Privacy Rights below for more information.

Other Sites, Mobile Applications and Services

Our Services may contain links to other websites, mobile applications, and other online services operated by third parties such as social media companies or payment processors (“Third Party Services”). These links are not an endorsement of, or representation that we are affiliated with, any third party.  In addition, our content may be included on Third Party Services. We do not control these Third Party Services, we are not responsible for their actions, and they may follow different rules regarding the collection, use and sharing of your personal information.  We encourage you to read the privacy policies of Third Party Services you use.

Children Under the Age of 18

Our Website and the Services are not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Website or through the Services. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or through the Services. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at info@capezero.com.

Your State Privacy Rights

The Website and our Services are hosted in and provided from the United States, and your use of our Website and Services is governed by United States law. If you are using the Website or Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our systems and facilities, and those of our third party providers and recipients of information, are located. Below we provide information applicable to individuals who are residents of certain US states, as required under applicable data protection laws in those states (“Relevant Laws”).

Your Consumer Rights

Certain Relevant Laws provide individuals in the applicable regions certain rights regarding their personal information. If a Relevant Law applies to you, you may submit a request to exercise your right(s) in relation to your personal information, as follows:

• Know/Access: You may request access to the specific pieces of personal information we have collected about you, which may, in accordance with Relevant Laws, be limited to the information collected in the prior 12 months.  
• Correct/Rectify: You may request that we correct or rectify the personal information we have collected about you. Please note that we may decline to correct certain information as required or permitted by applicable law, and we may deny your correction request if retaining the personal information in its current state is necessary for us or our service providers under any permitted exceptions.  
• Limit Use of Sensitive Personal Information: You may request that we limit the use of sensitive personal information, as defined in Relevant Laws, to certain purposes as set forth in the Relevant Laws. 
• Delete/Erase: You may request that we delete the personal information we have collected about you. Please note that we may retain certain information as required or permitted by applicable law, and we may deny your deletion request if retaining the personal information is necessary for us or our service providers under any permitted exceptions. If you request to delete your personal information, certain of our Services may no longer be available to you.
• Restrict or Object: You may request that we limit the way we use your personal information or object to certain forms of processing.
• Data Portability: You may request for your personal information to be transferred directly to another organization.
• Automated Decision Making and Profiling: You have the right not to be subject to automated decision-making if it produces a legal effect that significantly affects you, with certain exceptions.  
• Not to Receive Direct Marketing Communications: Under certain Relevant Laws, you may request to not receive our direct marketing messages, as more fully set forth below.

You can usually access, correct, or delete your personal information using your account settings and tools that we offer, but if you aren’t able to do that, or you don’t have an account, or you would like to contact us about one of the other rights, our contact information is set forth in Contact Information below.  

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. Under some Relevant Laws, you may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request must (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will respond to a verifiable consumer request within the time periods permitted under Relevant Laws. If we require more time, we will inform you of the reason and extension period in writing, in accordance with Relevant Laws.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Relevant Laws may require us to verify your identity. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Nevada Residents

Though we do not as a matter of course “sell” “covered information” as those terms are defined by the applicable Relevant Law, if you reside in Nevada and believe we have sold your covered information, please contact us as described in Contact Information below.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.  

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.  

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.  

Changes to Our Privacy Policy

Although most changes are likely to be minor, CapeZero may change its Privacy Policy from time to time, in CapeZero’s sole discretion. CapeZero encourages visitors to frequently check this page for any changes to its Privacy Policy. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of such change.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:  

info@capezero.com

CapeZero, Inc.

55 W Chestnut Street

Kingston, NY 12401

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