Privacy policy.

Last Updated: February 10, 2023

Protecting your privacy is important to CAPE Inclusion, Inc. (“CAPE,” “We,” or “Us”). This Privacy Policy explains our policies and practices regarding the collection, use, storage and disclosure of information used by CAPE’s website (the “Site”), CAPE’s applications (each an “App”), and CAPE’s Platform (collectively the “Service”), from you (a “user” or “you”).

We collect, use and store the information we need to provide, administer, manage, support, promote, and improve CAPE’s Apps and Platform, and to promote and provide additional services to our users. We collect information relating to identified or identifiable natural persons as set forth below (any one or more items of such information, “PII”). We disclose the information we collect only as this Privacy Policy states.

CAPE does not solicit or otherwise attempt to obtain PII from or about persons under 18 in connection with its Services. Please do not submit any personal information of persons under 18 to CAPE. If you submit or believe CAPE is in possession of a such a person’s PII (defined below), please delete such information from your Account or contact us at contact@capeinclusion.com. 

  1. THE INFORMATION WE COLLECT

    Account Information. Depending on which of our Services you use and your permission level, CAPE may create an account for you (an “Account”). As part of that process, we request information from users that can be used to identify them, such as a user’s name, email address, billing information, phone number, or social media identifiers. At your option, we may also collect information that is not ordinarily used to identify users, such as race, gender, and preferences for how users use and control access to CAPE’s products and services (any one or more items of such information, including PII, “Account Information”). 

    Log Information. CAPE collects information about each use of its products or services (any one or more items of such information, “Log Information”). Log Information may include information such as a user’s device type, IP address, browser type, operating system, the web page that a user visited before accessing CAPE’s products and services, or features a user accesses and the time spent on those pages or features, search terms, links associated with CAPE’s Products or Services that a user clicks on, and additional statistical information. 

    DEI Information. We will collect the information you submit about your experiences, organization, or work environment via the App or on our Platform (“DEI Information”). 

    Support Information. In addition, we collect the information we need to provide users with support services for CAPE products and services (any one or more items of such information, “Support Information”).

    Payment Information. When you pay for a Service, we will collect the information necessary to complete the transaction, like credit card information and billing address (“Payment Information”).


2. HOW WE USE THE INFORMATION WE COLLECT

CAPE uses: (a) Account Information to provide, manage, and administer access to CAPE’s Apps and Platform and to maintain compliance with our End User License Agreement that you agree to when you sign up for an Account (“EULA”). In addition, CAPE uses Account Information to provide support and additional services to users as they request, such as marketing emails if you sign up for our email list or updates to your account or our Services; (b) Log Information to administer, secure, improve and enhance CAPE’s products and services. Our analysis may involve using IP address to determine a user’s general location; (c) DEI Information to provide you the Services and helpful suggestions for increasing DEI in your organization; (d) Support Information, to provide users with support for CAPE’s Apps or Platform and to enhance and upgrade CAPE’s products and services, and (e) Payment Information to process your subscription or payments.

We may create data or analytics derived from PII or any other information we collect (“De-Identified Information”) So long as we do not enable the re-identification of such information, we reserve the right to use De-Identified Information for any lawful purpose and in perpetuity, internal or external, commercial or otherwise.

We use all information we collect, including PII, to provide, secure, market, and improve our Service and our business. 

3. DISCLOSURE OF INFORMATION COLLECTED

Service Providers. We share Account Information, Log Information, and DEI Information to enable one or more CAPE agents, vendors, or service providers to perform under their respective agreements, including agreements to provide CAPE with email marketing and promotional services, which third parties are contractually bound to keep your information secure and confidential. For example, we share all information collected and created with our third-party hosting provider’s servers. We use cloud service providers to manage information collected, but those service providers do not process your PII. We will share your email address with our email service provider if you sign up for updates or to send updates on our behalf. We use a third-party payment processor to facilitate payments and we share your Payment Information with them. We do not sell PII to third parties. We may use Account Information you provide to us to send you updates about your Account, new products and services, and similar topics, but we will not provide your Account Information to third parties outside of the manager of your account, if any.

Your Account Manager, Employer, or Organization. If your Account is paid for by your employer or organization, and if you use the Service as a non-manager of an Account, we will share your Account Information and DEI Information with the Account’s manager. We disclaim any and all responsibility for the content of your DEI Information or the consequences of sharing any information with your Account manager or employer.

We may also share PII with third parties as follows:

A user requests or authorizes the disclosure of its Account Information; 

The disclosure is required, in the judgment of CAPE’s management:To comply with a search warrant, subpoena, discovery request, court order or other legal requirement; or a request made by a law enforcement or other government agency acting within its authority;

To prevent the unlawful or illegal use of CAPE’s services or facilities;

To enforce the EULA or other agreements between CAPE and one or more users, or as otherwise appropriate to protect the rights, interests, and property of CAPE;

To protect personal safety, including the safety of CAPE’s employees; 

To respond to emergencies; and

To respond to disputes, claims, and to users’ successors in interest.

CAPE’s Site may link to social media sites such as Facebook, LinkedIn, Twitter and others. If users “like” or share information from CAPE’s Site using any one or more of these services, the information disclosed or shared will be governed by terms and conditions and the privacy policy of that service. The interfaces for certain social media services may allow those services to access PII users disclose in connection with CAPE. Please contact us at contact@capeinclusion.com with questions or complaints about this process.

4. INFORMATION RETENTION

CAPE stores: (a) Account Information and DEI Information, including PII, for each user while its account exists and retains it in accordance with applicable law, the instructions of CAPE’s management, and this Privacy Policy; (b) Log Information, for long enough to analyze and use it as this policy contemplates; (c) Support information for as long as necessary to provide the support you request; (d) Payment Information to complete the transactions you request, and (e) De-Identified Information for as long as we deem fit.

5. CROSS-BORDER INFORMATION COLLECTION AND RELATED TRANSFERS

Users who reside outside the United States may use the CAPE Apps or Platform to transfer information, including Account Information, to CAPE’s systems, which may be based in the United States or other countries where the privacy laws may not be as protective as those of the jurisdictions where users reside. Except where prohibited by applicable law, CAPE may transfer information obtained from such users within and beyond the United States in accordance with this policy. 

6. SECURITY FOR INFORMATION COLLECTED

We implement a variety of security measures to maintain the safety of your PII. For example, we encrypt PII at rest. We offer the use of a secure server. All Payment Information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway provider’s database only to be accessible by those authorized with special access rights to such systems and are required to keep the information confidential.

After a transaction, your Payment Information will not be stored on our servers. 

While we use industry-standard precautions to safeguard your PII, we cannot guarantee complete security. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us is compromised), please immediately notify us of the problem.

7. COOKIES 

Cookies are small pieces of information that our Site stores on your computer while you are viewing it. We may use both session cookies (which expire once you close your web browser) and persistent cookies (most of which have an expiration date, based on the purpose of the cookie, at which point they self-delete) to provide you with a more personal and interactive experience on our Site. Currently, we place the following cookies:

Cookie

Google Tag Manager

(Essential)

What it does

Provides measurement codes and related code fragments collectively known as tags on the Site or mobile app.

When it’s set

Page Load

Persistent/Session

Persistent

Cookie

Google Analytics

(Performance)

What it does

Collects data on a user’s device, browser, location and ad campaign information. It also records behavior on the web, leading up to visiting the site and on the Site.

When it’s set

Page Load

Persistent/Session

Persistent or Session

Cookie

Hubspot

(Analytics)

What it does

Tracks inbound traffic for analytics

When it’s set

Page Load

Persistent/Session

Persistent


We use generally use cookies and similar technologies as follows: 

  • for “essential” or “functional” purposes, such as to enable various features of the Site like remembering passwords or staying logged in during your session;

  • for social media integration e.g. via third-party social media cookies, when you share information using a social media sharing button or “like” button on our Site, or when you engage with our content on or through a social networking website such as Facebook;

  • for analytics purposes, consistent with our legitimate interests in how our Site is used or performs, how users engage with and navigate through the Site, what sites users visit before visiting our Site, how often they visit our Site, whether an email was received or opened, and other similar information; 

  • subject to any consent required by law, for the purpose of displaying advertisements via retargeting to those users who have visited our Site, or for targeting advertising to visitors to our Site; and

  • subject to any consent required by law, for the purpose of analyzing your feedback on our products on other platforms.

If you’d like to remove or disable cookies via your browser, refer to your browser’s settings. 

Most advertising networks offer you a way to opt out of interest-based advertising. If you wish to limit third parties’ collection of information about your use of our Site, you can opt-out of such at the Digital Advertising Alliance in the US, the Digital Advertising Alliance of Canada in Canada, or the European Digital Advertising Alliance in Europe.  

8. HOW WE RESPOND TO DO NOT TRACK INSTRUCTIONS

While you may disable the usage of cookies through your browser settings, the Site currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted.

9. LINKS TO OTHER SITES

This CAPE Privacy Policy applies only with respect to CAPE’s products and services that link to it. The treatment of information that users provide on or to any other site or service will be governed by the terms of service and privacy policy applicable to that site or service, if any.

10. MODIFYING YOUR INFORMATION

If you are an Account manager, you may modify your PII in a Service by contacting your account representative or by using in-account controls. If you use our App, you may modify certain PII in your Account or by contacting contact@capeinclusion.com.

11. DELETING INFORMATION

Unless you and CAPE agree otherwise, managers may delete PII and close their organization’s account by either using in-account controls (if available) or by contacting CAPE at contact@capeinclusion.com

12. CHANGES TO THIS PRIVACY POLICY

CAPE may modify and revise this Privacy Policy at any time. We will notify you by changing the “Last Updated” date above. Please check this policy regularly for updates. Your continued use of the CAPE Apps or Platform constitutes your acknowledgement that you understand and will adhere to this Privacy Policy.

13. QUESTIONS?

Please contact us at contact@capeinclusion.com if you have any questions about the CAPE Privacy Policy.