Please review this policy carefully to understand our policies and practices regarding your personal data. If you do not agree with the practices described in this policy, please do not access or use our Websites or Services (defined below).
This Policy is applicable to data collected through CapeStart.com and other CapeStart websites ( collectively, “the Websites”), through our applications (“the Services”) and through any other interactions you might have with CapeStart, such as through email newsletters, our Community boards, and other interactive features and communications.
This Policy does not apply to any third-party websites, applications or businesses to which we link or who may link to us. You should review the privacy policies of those third parties to better understand how they may collect and use your personal data.
Additionally, CapeStart’s Master Subscription Agreement governs delivery and use of the Services, including any data submitted through customer accounts via the Services.
We may update the terms of this Policy at our discretion. We encourage visitors to frequently check this page for any changes.
3. How We Collect
We may collect your personal data through various ways, when you:
- Visit our Websites, through automated cookies
- Use our Services
- Interact with us by providing your contact information through the Websites, by email, by social media, or by telephone
- Participate in our online communities, blogs or other forums
- Register for or attend an online or in person event sponsored by us
- Submit an application to work for us
4. What We Collect
The types of information we collect from you may differ depending on how you interact with us.
Personal data you may provide to us:
- Your name, username, email address, postal address, phone number, and other contact information
- Your credit card number and billing information
- Your employer, job title and other job application information
- Records of your correspondence with us or on our forums
- Information you provide through other types of interactions, such as surveys, events, social media, or other types of communication with us
Personal data we may automatically collect from you:
- Device and connection information, including IP address, unique device identifiers, browser type, browser language, and other transactional information
- Geolocation information, if enabled on our Careers webpage
- Cookies and tracking technologies that analyze your use of the Websites, show traffic data, and log files such as time of access, date of access, software crash reports, session identification number, access times, and referring website addresses (see our Cookies Policy for more information)
Personal data we may receive from third parties:
- Business contact information from third party providers or your employer, if our Services are provided to you via your employer
- Publicly available data from third party sources, like social media
5. How We Use Your Data
How we use your personal data depends in part on how you interact with CapeStart. The specific purposes for which we use the data we collect about you are listed below. Where required by law, we obtain your consent to use and process your personal data for these purposes. Otherwise, we rely on either our legitimate interests or contractual necessity as our lawful basis for processing your data.
- To provide the Services. We use your personal data to provide, support, understand and improve the Services. As part of providing the Services we may send you service announcements, technical notices, updates, security alerts, billing and support-related messages related to your account or transactions with us, through the Services or by email. You may not opt out of these messages, as they are considered part of the Services.
- To personalize the Services, Websites and business. We use the information we collect to personalize content and experiences on our Websites and Services, to better understand your interests, make personalized recommendations based on your interests or information and otherwise personalize your experience with CapeStart.
- To communicate with you. We will send you emails or otherwise communicate with you in response to your questions, feedback or comments. For example, we will respond to comments on our Community boards, and answer questions sent to us through the Websites. Additionally, we sometimes send emails about new product features, promotional communications or other CapeStart news. You can always opt-out of these communications by following the opt-out instructions in the message or by contacting us through the contact information listed below.
- To create anonymous data. We may create aggregated data from our users’ personal data. We make personal data into aggregated data by removing information that makes the data personally identifiable to you. We may use this aggregated data and share it with third parties to operate, understand and improve our Services, to develop new services, and for other lawful business purposes.
- For security, compliance, fraud prevention and safety. We may use your personal data as we believe appropriate to investigate or prevent violation of the law or our Terms of Service; to secure the Services; to protect our, your or others’ rights, privacy, safety or property; and to protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity. For example, we may use tools to scan your content in the Services or on our Websites for content that violates our Terms of Service or the law. We may also use the information we collect about your device to detect users violating our Terms of Service and prevent further violations.
- For compliance with law or to investigate legal claims. We may use your personal data to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities. We may also use your personal data where permitted by law in connection with any legal investigation and to prosecute or defend legal claims.
- With your consent. In some cases, we may ask for your consent to collect, use or share your personal data. We may use the information gathered from one location on the Websites and use it in another location, either on the Websites or elsewhere in our network of Services and features, or in reports and analysis, all of which are owned and operated by CapeStart. We may also combine information gathered from multiple locations on the Website into a single customer record or analysis or report. We also use and/or combine information that we collect off-line or we collect or receive from third party sources to enhance, expand, and check the accuracy of your customer records.
6. How We Share Your Data
Aside from the instances listed below, we do not disclose information about your personal data to any companies not part of CapeStart or its parent, subsidiaries or related entities. We will not sell or rent your personal data as part of a customer list or similar transaction.
We may share your personal data as follows:
- With Business Partners. We may share your personal data with our business partners from time to time, for example, businesses who help us host our events. You may opt out of sharing your personal data with business partners at the time of collection, or afterwards by contacting us as provided in the Contact Us section.
- With Third-Party Agents and Service Providers. We have third party agents, service providers, subsidiaries and partners that perform functions on our behalf, such as hosting, billing, push notifications, storage, bandwidth, content management tools, analytics, customer service, fraud protection, etc. These entities have access to the personal data needed to perform their functions and are contractually obligated to maintain the confidentiality and security of that data. They are restricted from using, selling, distributing or altering this data in any way other than to provide the requested services to the Services and Website.
- For Compliance with Law; Legal Claims; Security, Compliance, Fraud Prevention and Safety. We may also use or disclose personal data if required to do so by law or in the good-faith belief that such action is necessary to conform to applicable law or comply with legal process served on us; protect and defend our rights or property, the Website and Services or our users, and act under emergency circumstances to protect the personal safety of us, our affiliates, agents, or the users of the Website, Services or the public. This includes exchanging information with other companies and organizations for fraud protection.
- Through Business Transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal data, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization, sale of assets or in the event of bankruptcy.
7. Data Retention
CapeStart may retain your information for as long as your account is active, or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.
Following termination or deactivation of your account, CapeStart may retain information (including your profile information) and user content for a commercially reasonable time for backup, archival, and/or audit purposes.
After the applicable retention period has expired, CapeStart will securely delete or anonymize your personal data.
8. Data Security
CapeStart takes security very seriously. We take appropriate measures, including organizational, technical, and physical precautions to help protect against unauthorized access to, alteration of, or destruction of your personal data.
While we follow industry standards and best practices to protect your data, no transmission of data over the Internet or any public network can be guaranteed to be 100% secure.
9. Payment Information
10. Children’s Data
The Services and Websites are not directed to anyone under the age of 16. A parent or guardian who becomes aware that his or her child under the age of 16 has provided us with personal data may contact us at firstname.lastname@example.org and we will attempt to delete the child’s data as soon as possible.
11. Your Data Rights
CapeStart respects your control over your personal data and, upon request, we will confirm whether we hold or are processing data that we have collected from you. You also have the right to amend or update inaccurate or incomplete personal data, request deletion of your personal data, or request that we no longer use it. Under certain circumstances we will not be able to fulfill your request, such as if it interferes with our regulatory obligations, affects legal matters, we cannot verify your identity, or fulfillment involves disproportionate cost or effort, but in any event we will respond to your request within a reasonable timeframe and provide you an explanation.
You can always contact us as provided in the Contact Us section to exercise these rights. You may also be able to take action yourself through the methods listed below.
- View, correct and delete your account information. If you use the Services or have an account through our Websites, you can view, update and delete certain information directly through your account.
- Opt-out of communications. You can opt out of receiving future promotional communications from us by clicking the unsubscribe link within an email, or by updating your profile settings. Please note that you generally can’t opt out of service-related communications.
- Deactivate your account. If you would like to stop using our Services, you or your administrator may be able to deactivate your account. Please be aware that depending on how you use our Services and Websites, this may not delete all of your information.
12. International Transfers of Data
CapeStart participates in and has certified its compliance with the SOC2 Framework for the collection, use and retention of personal data transferred from the European Union, Switzerland, and the United Kingdom to the United States. These frameworks were developed to enable companies to comply with data protection requirements when transferring personal data from the EU, Switzerland and the UK to the US.
In compliance with the SOC2 principles, we are committed to resolving your questions and complaints related to our collection and use of your personal data. Individuals located in the EU, Switzerland or the UK should contact email@example.com with any questions or concerns regarding your personal data.
CapeStart has further committed to refer unresolved complaints to our EU based GDPR Article 27 Representative. If you have a complaint or issue that we have not resolved satisfactorily, please contact our GDPR Rep Maetzler Rechtsanwalts GmbH & Co KG c/o CapeStart, Inc, Schellinggasse 3/10, 1010 Vienna, Austria. Website: https://www.gdpr-rep.eu GDPR-REP ID: 11713613 visit https://gdpr-rep.eu/q/11713613 for more information or to file a complaint.
Under certain conditions, and when all other dispute resolution procedures have been exhausted, subject individuals may invoke binding arbitration.
CapeStart is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
13. California Residents
This Policy contains a list of the categories of personal data we collect, and have collected for the past twelve months. If you are a California resident, you may have additional rights under the California Consumer Privacy Act (“CCPA”) that include the right to ask us to disclose the personal data we collect, and the right to ask us to delete certain personal data that we collect or maintain about you. Please note that we do not sell the personal data that we collect. To exercise your rights, please contact us as provided in the Contact Us section. You will not be discriminated against for exercising your privacy rights under the CCPA. In order to protect your data from unauthorized access or deletion, we may require you to provide additional information for verification. If we can’t verify your identity, we will not provide or delete your data.
14. Contact Us
If you have any questions about this Policy, or to exercise any of your statutory rights, please email us at firstname.lastname@example.org. You can also contact us at our mailing address below:
60 Thoreau Street, Suite 294
Concord, MA 01742 USA
Last Updated: March 20, 2020
We also have a presence in the form of branded social media pages on social media networks, like Facebook, LinkedIn, and Twitter. Please visit their websites to learn their privacy policies and the privacy and marketing controls available for their community members since we have no control over how these social media platforms operate.
You can control the cookies used on this site either via our Cookie Consent Portal or by adjusting your browser settings. Click the heading “How can you control cookies?” below for more information.
- What are cookies?
- How can you control cookies?
- How long do cookies last?
- How to contact us?
1. What are cookies?
Cookies are text files embedded in a web page that contain small amounts of information which are downloaded to your device when you visit a site or embedded in a web page. Cookies may then be sent back to the originating site on each subsequent visit, or to another site that recognizes that cookie. Cookies are useful because they allow a site to recognize a user’s device and to remember your actions and preferences (such as login details, language, font size, and other display preferences) over a while.
Where possible, security measures are put in place to prevent unauthorized access to our cookies and similar technologies. A unique identifier ensures that only we and/or our authorized service providers have access to cookie data.
B. Web beacons
Web beacons (also known as internet tags, pixel tags, and clear GIFs) are typically transparent graphic images placed on a site or email. Web beacons are used in combination with cookies to learn about our visitors` interactions, capture visitor’s journey on our site, to create segment categories and behavior patterns, or to serve targeted advertisements. We (or the third parties we use) use beacons to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, and the type of browser used to view the page.
C. IP addresses and URLs
An IP address is a unique identifier that certain electronic devices used to identify and communicate with each other on the internet. When you visit our site, we (or the third parties we use) may view the IP address of the device that you use to connect to the internet using a web beacon.
We (or the third parties we use) use only the redacted part of the IP address to determine the broader physical location of the device so that we can`t identify your precise location. This helps us to understand from what geographic regions (e.g. city, province, country, like Massachusetts, United States) our site visitors come to change the way we present our site to you, to enhance your visit, or to customize our marketing content. If we want to collect your precise location data for our advertising purposes, we obtain your consent to this.
A URL (uniform resource locator) is a unique identifier or address for each resource on the internet, in effect it is the address for the web page that you are visiting. We use this information to see which sites and pages are visited and the way that you navigate through our site.
D. Device IDs
E. Device fingerprinting
We use different types of cookies on our site for various purposes set out below.
Some of these cookies are placed by us and others by third parties (e.g. social media platform, advertising, and analytics providers, etc.).
You can find more information about the individual cookies used and the third parties which set the cookies on this site in your browser, as well as in the Cookie Consent Portal.
A. Required cookies – These cookies are required for the operation of our site, to enable core site functions, to ensure the site is secure and to enable us to manage the network. They are sometimes referred to as “strictly necessary” or “essential” cookies. Without these cookies, the site cannot function properly. They include, for example, cookies that allow us to remember your cookie consent preferences and balance network load, enable you to log into secure areas of our site and to access user accounts or online forms, use a shopping cart, make use of e-billing services, and download voucher coupons.
B. Functional and analytical cookies – These cookies are either functional or analytical. They are used to improve functionality, improve and personalize browsing experience, and to analyze site traffic and usage.
Analytics cookies allow us to recognize and count the number of visitors and to see how visitors move around our site. They help us understand and measure how you interact with our site, allow us to gather statistics about our site visitors to better understand them, and to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily. Analytics cookies also allow us to test new site content, features, or interactions so we can improve the site experience and appearance for all.
Functional cookies are used to enhance what you can do on our site. Examples include to help us to give you better and customized user experience to test and provide the best site design, layout, and content, and to remember choices you have made between sessions This enables us to enhance and personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Besides, certain third-party cookies are necessary to allow some site-embedded functionalities to work. These cookies are dropped by third parties only if you interact with certain functionality on the site. Provided that consent is required in your country, at each place on our site where this applies, you will be told that cookies will be placed on your device by the relevant third-party and that by clicking on the given functionality, you are indicating that you consent to the setting of cookies by that third party. If you do not allow these cookies, you may not be able to use the functionality. These cookies cannot be managed through our Cookie Consent Portal but can be disabled and deleted via your browser settings, as explained below.
Examples of how cookies are used in this way include our use of YouTube on the site for showing videos, where YouTube sets cookies on your device once you click on the YouTube video to play. Please note that in terms of playing YouTube videos on our site, we promote using the “privacy-enhanced mode” to prevent the setting of cookies that track viewing behavior to the storage of personally-identifiable cookie information by YouTube.
C. Advertising cookies – These cookies are used for advertising our products, brands, or services, for example, to show you advertisements that are more relevant to your interests based on your online activity (also known as personalized or interest-based advertising), or to prevent the same ads from continuously re-appearing.
Cookies in this category enable us to collect information across the sites you visit, to record your visit to our site, the pages you have visited and the links you have followed, our brand emails you view and links you click in the emails, to track your online activities across your computer, mobile phone or other devices you use, including the mobile apps you use.
We use this information to try to predict what advertisements for our products or brands might be the most interesting to you and to make our site and the advertising displayed on it or other sites more relevant to you.
We also use the cookies in this category to place you into a group of consumers who show the same interests (e.g. age, gender, interest category) (also known as an “audience”). Generally, this process does not require us to know you as an identifiable individual, only that someone using your browser showed interest in a product. We may add other information to this, such as information about the products you buy in an online shop or information that you provide directly to us when creating an account on our sites, or information about your browsing history.
By using advertising cookies, we can:
- learn about trends, habits, or characteristics from a group of consumers who all act similarly;
- show you personalized advertisements on our site or other sites you visit;
- find others who appear to be similar in interests, characteristics, or behaviors to those already in the interest group, so we can reach more potential customers by showing relevant advertising to them.
If you turn off these cookies you will see less targeted, interest-based advertising; however, it does not mean you will not see any advertisements. Even if you opt-out receiving interest-based advertisements, you will still be shown advertisements about our products or brands based on the context of the sites you visit (these are called “contextual ads”).
If you want to learn more about interest-based advertising and cross-device linking, you may find it useful to visit the Network Advertising Initiative website.
In general, when we share information about your use of our site with our third parties, we do not pass to them any personally identifiable information obtained through cookies used on our site.
You can find information about how we process personal data in our Privacy Notice.
3. How can you control cookies?
v Opt-in model: In the European Economic Area and the United Kingdom: except where allowed by applicable law, we place cookies after having received your consent through the cookie banner which you will see when you first use our site, or via our Cookie Consent Portal which is continually available on the site, or through your browser settings (see below for more details). Please note that certain functionalities embedded in the site require the setting of cookies by third parties to work. These cookies are set only when you interact with the functionality. At each place on our site where this applies, you will be told that cookies will be placed on your device by the relevant third-party and that by clicking on the given functionality, you are indicating that you consent to the setting of cookies by that third party.
v Opt-out model: In countries outside of the European Economic Area, or the United Kingdom: except where prohibited by applicable law in your country, we place cookies when you visit our site, however, you can opt-out from cookies any time via either the Cookie Consent Portal or your browser settings (see below for more details).
B. Your browser: You can change your cookie preferences by changing your browser settings. The majority of web browsers accept cookies, but you can usually change the web browser’s settings to refuse new cookies, disable existing ones or simply let you know when new ones are sent to your device. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools”, “Settings” or “Edit” facility). Also, certain third parties have additional opt-out browser add-ons that you can enable on your browser, for example, see the browser add-on by Google regarding Google Analytics.
C. Your mobile phone: You can change settings to opt-in or opt-out from receiving personalized interest-based advertising within your mobile phone or similar device usually in the “Setting” menu. (For example, in iOS: visit Settings – Privacy – Advertising – Limit Ad Tracking. Similarly, in Android: visit Settings – Google – Ads – Opt-out of interest-based ads.)
Please note that the opt-outs described above will apply only to the specific browser or device from which you opt-out, and therefore you will need to opt-out separately on all of your browsers and devices.
Also, disabling a cookie or category of cookie does not delete the cookie from your device; you will need to do this yourself within your browser. Please note if you decide to delete all cookies, your “opt-out cookie” will be also deleted, and you will need to opt-out again if you still do not want to receive certain categories of cookies.
You can visit http://www.attacat.co.uk/resources/cookies/how-to-ban or the NAI’s website for more information on how to manage cookies.
4. How long do cookies last?
The cookies used on our site last for a maximum of 13 months. Session cookies expire immediately after you finish your browsing session on our site.
6. How to contact us?