Privacy Policy
Last Updated: October 8, 2024
We’re a privacy-first carrier, which means that we hold in the highest importance decisions around how we collect, use, and protect the data you share with us while using our services. It’s with that approach in mind that we’ve created this Privacy Policy as a central pillar of promises to you, rather than as an afterthought. If you have concerns about our Privacy Policy, or you otherwise have comments, please, let us know.
This Privacy Policy applies to the processing of personal information by Private Tech Inc. dba Cape (“Cape,” “we,” “us,” or “our”) on our website available at cape.co (the “Website”) and on our private and secure mobile carrier service (the “Cape Mobile Carrier Service”), as well as any of our other online or offline offerings which link to, or are otherwise subject to, this Privacy Policy (together, the Website and the Cape Mobile Carrier Services are referred to as the “Cape Services”).
1. PERSONAL INFORMATION WE COLLECT
2. HOW WE USE PERSONAL INFORMATION
3. HOW WE DISCLOSE PERSONAL INFORMATION
4. YOUR PRIVACY CHOICES AND RIGHTS
5. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
6. CHILDREN’S PERSONAL INFORMATION
7. THIRD-PARTY WEBSITES/APPLICATIONS
8. RETENTION OF PERSONAL INFORMATION
9. UPDATES TO THIS PRIVACY POLICY
1. Personal Information We Collect
We collect personal information that you provide to us, personal information we collect automatically when you use the Website, and personal information from third-party sources, as described below.
A. Personal Information You Provide to Us Directly
We may collect personal information that you provide to us.
- Subscription Information. When you sign up for Cape Mobile Carrier Service, you will be prompted to provide to Cape certain personal information. We try to keep the personal information collected from you to the minimum possible—as such, we do not collect your name, only your phone number and zip code.
- Payment Information. We do not directly collect or store full credit card numbers entered through our Cape Services. Instead, our third party payment processor, Stripe, processes all payments and generates a token, stripped of sensitive information, that is stored on our systems to confirm payment. We may collect some personal information and details associated with your payment for the Cape Services. In particular, we collect and keep your zip code as long as necessary to comply with state, municipal, and other local tax payment and reporting obligations.
- Your Communications with Us. We, and our service providers (including Mailchimp), may collect the information you communicate to us, such as through email, when you request customer support or use our web chat tool. However, your email will never be associated with your Cape Mobile Carrier Service account, meaning we cannot link your email to your phone number or other personal details. If you contact us through the chat features we may offer on our Website or in our app, we may monitor and retain those chat communications and store them with our service providers for up to two months in order to improve our service. We will retain that information for as little time as possible to provide you with support and service, and our default is to delete data when possible.
- To Sign Up for Our Mailing List. If you sign up for our mailing list via the Website, we will collect your email. We will use your email to send you news about Cape and its products. If you become a Cape customer, we will not associate your email with your Cape account, so we would not be able to link your email with your phone number or other personal details.
- Surveys. We may contact you to participate in surveys. If you decide to participate, we may ask for personal information from you in connection with the survey.
- Interactive Features. We and other platforms integrated with our Website may collect personal information that you submit or make available through our interactive features (e.g., messaging features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Website will be considered “public.”
- To Provide You with our Service Coverage Map. We and our third-party service provider will collect your address if you choose to enter it on the Website to determine whether Cape will offer cell phone coverage in your area. Like all other data collected on the Website, this will not be associated with your Cape account, should you choose to become a customer. As a principle, we do not track and link customer data captured across the Website with customer data captured from the Cape Mobile Carrier Service.
- Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
- Job Applications. If you apply for a job with us, we and our service providers hosting our recruiting platform will collect any personal information you provide in connection with your application, such as your contact information and CV.
B. Personal Information Collected Automatically
We may collect personal information automatically when you use the Services. We are always looking for ways to minimize the collection of personal information while providing you with the best experience. As of the date of this privacy policy, we are not using Google Analytics on our Website, and instead are using a more privacy-protective analytics service called Simple Analytics. This service does not set any cookies on our Website and does not collect IP addresses. Cape also does not use cookies to track you on our Website. To see more of what Simple Analytics collects and doesn’t collect see here.
- Device Information.
- Collected through the Website: We may collect personal information about your device, such as your Internet protocol (IP) address, user settings, browser or device type, and location information (including, as applicable, approximate location derived from IP address and approximate locations via time zones).
- Collected through the Cape Mobile Carrier Service: Cape and its partner networking providers will collect your phone number. If you make an emergency 911 call, wireless communication systems will approximately know where the device is physically located by tracking your GPS information. In providing you with the Cape Mobile Carrier Service, Cape will also collect your Cell ID, call logs, subscriber number (IMSI), your device number (IMEI) and your MAC address. Cell ID and call logs are stored for two months for billing, compliance, and financial reconciliation. Cape will not store your IMEI or MAC address.
- Usage Information. We may collect non-identifying information about your use of the Website, such as the pages that you visit and when, information about the links you click, the frequency and duration of your activities, and other information about how you use the Website. This usage information does not allow us to personally identify you.
- Web Beacons. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
2. How We Use Personal Information
We use personal information for a variety of business purposes, including to provide the Cape Services, for administrative purposes and with your consent as described below.
A. Provide the Website
We use personal information to provide the Cape Services, such as:
- Managing your plan and information;
- Providing access to certain areas, functionalities, and features of the Cape Services;
- Answering requests for support;
- Communicating with you;
- Sharing personal information with third parties as needed to provide the Cape Services;
- Processing applications if you apply for a job we post on our Website;
- Allowing you to register for events; and
- Allowing you to sign up to receive news about Cape by providing your email address to us.
B. Administrative Purposes
We use personal information for various administrative purposes, such as:
- Carrying out analytics;
- Measuring interest and engagement in the Cape Services;
- Improving, upgrading, or enhancing the Cape Services;t activity;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
- Processing your financial information and other payment methods for products and the Cape Services purchased;
- Developing new products and services;
- Ensuring internal quality control and safety;
- Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;
- Debugging to identify and repair errors with the Cape Services;
- Auditing relating to interactions, transactions, and other compliance activities;
- Enforcing our agreements and policies; and
- Carrying out activities that are required to comply with our legal obligations.
C. Marketing
We will not share your personal information with third parties to send marketing communications.
If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.
D. With Your Consent or Direction
We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information, with your consent, or as otherwise directed by you.
E. To Provide You Spam Filtering Functionality
By using the Cape Mobile Carrier Service to send SMS messages, you agree that if you have or the sender has sent a large volume of SMS messages during a short time period and we or our network partners suspect it is an unauthorized spam or scam campaign, we or our network partner may need to review the content of your sent or received SMS messages. We may also review content of your SMS messages if someone has reported to us that any of the them are unauthorized spam or a scam. If SMS content is validated as spam, it will be saved in a spam history database to prevent future Cape customers from receiving the spam campaign.
If you are the recipient of the SMS message, your phone number and other personal information is hashed (converted to a fixed-length string of letters and numbers) and not viewed by Cape or its network partners. Any account numbers, credit card information, URLs, and first and last names within the flagged SMS messages are also masked. The relevant SMS messages are not linked to specific individuals, and are disassociated from the personal information of any customers.
F. On an Aggregated or De-Identified Basis
We may use your network diagnostic information to create de-identified and/or aggregated information to monitor, maintain, and improve the quality of our network. If we create or receive de-identified information, we will not attempt to reidentify such information, unless required to comply with, applicable laws.
3. How We Disclose Personal Information
We disclose personal information to third parties for a variety of business purposes, including to provide the Cape Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
We do not sell your personal information.
A. Disclosures to Provide the Cape Services
We always seek to minimize the amount of information we collect. What personal information we do collect, we may disclose to the categories of third parties described below. We share the minimum amount of information with third parties necessary to provide you with the Cape Services.
- Service Providers. We may disclose personal information to third-party service providers that assist us with the provision of the Cape Services. This may include, but is not limited to, service providers that provide us with wireless communication services, hosting, mapping coverage services, customer service, email campaign services, network and other analytics, marketing Website, IT support, and related services. In addition, personal information and chat communications may be disclosed to service providers that help provide our chat features.
- Network Service Providers. We may share your personal information with network service providers and partners like UScellular to provide you with the Cape Mobile Carrier Service. Once your personal information is shared with our network service provider, it will also be subject to our network service provider’s privacy policy.
- Third-Party Services You Share or Interact With. The Website may link to or allow you to interface, interact, share information with, direct us to share information with, access and/or use third-party websites, applications, services, products, and technology (each a “Third-Party Service”).
Any personal information shared with a Third-Party Service will be subject to the Third-Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services; however, we have a rigorous vetting process to select secure and privacy protective Third-Party Services. - Subsidiaries. We do not currently have any subsidiaries, but we might in the future. If we do, we may share your personal information with our corporate affiliates.
B. Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect the rights, property, or safety of our company or of any third party; prevent or stop any illegal, unethical or legally actionable activity; enforce our policies or contracts; collect amounts owed to us; comply with our legal obligations such as assisting with an investigation or prosecution of suspected or actual illegal activity.
C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction. The acquirer would be required by law not to treat your personal information in a manner that is materially inconsistent with the promises made in this Privacy Policy without providing you notice or obtaining your consent.
D. Disclosures for Location-Based Services
We use location information to route wireless communications and to provide 911 service, which allows emergency services to locate your general location. In case of an e911 call, we may disclose, without your consent, the approximate location of a wireless device to a governmental entity or law enforcement authority when we are served with lawful process or reasonably believe there is an emergency involving risk of death or serious physical harm. Depending on your device, you may also be able to obtain a wide array of services based on the location of your device (for example, driving directions, enhanced 411 Directory Assistance or search results, etc.). These data services, known as Location-Based Services (“LBS”) are made available by us and other entities, usually via applications. These services use various location technologies and acquire location data from various sources. These applications and services use various location technologies (including Global Positioning Satellite (“GPS”), Assisted GPS (“AGPS”), cell ID and enhanced cell ID technologies) to identify the approximate location of a device, which is then used in conjunction with the application to enhance the user’s experience (for example, to provide driving directions, to provide enhanced 411 Directory Assistance or search results, etc.). LBS may, or may not, involve any interaction with or dependency on our supplier’s network, and location-based services may or may not look to our network to obtain location data. Where our network supplier allows third parties the capability of accessing data about your location that is derived from our supplier’s network, our network supplier requires those third parties to observe specific privacy and security protections consistent with this policy. It is important that you understand the location capabilities and settings of your device, and that you carefully read and understand the terms under which these services are provided – whether by us or another entity. You should carefully review the privacy policies and other terms of third parties with whom you have authorized the sharing of your location information, and you should consider the risks involved in disclosing your location information to other people. Where we provide a location-based service, you will receive notice of the location features of the service and collection of location data is with your consent. You will be provided options for managing when and how such information should be shared.
4. Your Privacy Choices And Rights
Your Privacy Choices. The privacy choices you may have about your personal information are described below.
- Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. We may also send you certain non-promotional communications regarding us and the Website, and you will not be able to opt out of those communications (e.g., communications regarding the Website or updates to this Privacy Policy).
- Text Messages. If you authorize us, we may send you text messages to inform you about important updates regarding your account and the Cape Mobile Carrier Service. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in “Contact Us” below
- “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Our Website responds to or honors DNT signals or similar mechanisms transmitted by web browsers.
5. International Transfers Of Personal Information
All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live.
6. Children's Personal Information
The Cape Services are not directed to children under 13 (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children.
If you are a parent or guardian and believe your child has uploaded personal information to the Website in violation of applicable law, you may contact us as described in “Contact Us” below.
7. Third-Party Websites And Applications
The Cape Services may contain links to other websites or applications and other websites or applications may reference or link to the Cape Services. These third-party websites or applications are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
For more details on retention periods for specific types of sensitive data, see here [Link to table from privacy policy summary here]
8. Retention of Personal Information
We will keep it only as long as it is useful to provide you with cell phone service, or if you provided your email via our website, to send you updates until you unsubscribe. We prefer to delete data, not store it.
We want you to know how long we keep especially sensitive information about you, and we are always working to collect and store less information, for less time.
9. Updates To This Privacy Policy
We may update this Privacy Policy from time to time. If we do, we’ll always let you know by posting the updated Privacy Policy on our Website, and we may also send other communications.
10. Contact Us
If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at: info@cape.co.