Our Privacy Principles

Here is a short summary of our privacy practices. This summary is intended to be easy to read and understand. You can find our full Privacy Policy . If you have concerns about these privacy principles, or you otherwise have comments, please, let us know. We are committed to maintaining user-first privacy principles, and that is a work in progress. This is an ongoing conversation, and we want you in it.

Our goal is to minimize the personal information we collect from you, and to minimize the extent to which that information is shared after it is collected, while still providing you with a good experience with our website, available at cape.co, and our products.

We can update this Privacy Policy at any time, and will likely update it often as we seek to provide more details and transparency. We will post these changes on our website, so you can always find the latest version. We might also send you notifications about Privacy Policy updates.

One thing that won’t change is our privacy principles, which underpin this Privacy Policy:

  1. Your data is a part of your person. You, and only you, should control it.
  2. We will collect the minimum amount of user data needed to offer our service.
  3. We will never sell your data. Period. We will comply with the law, but we can only share what we store.
  4. We believe everyone should have access to private, secure connection.


How do we collect your personal information?
We collect your personal information when you provide it to us on our website (for instance, when you enter your email address to join our mailing list), when we collect website usage information (for instance, your browser type) through your navigation of cape.co, or when you sign up for our cell phone service. Our website , which helps limit third-party access to your data.

How do we use your personal information? We use your personal information to (i) make your phone service or the website work, including to manage our newsletter and allow you to sign up via email to receive Cape-related news, (ii) for administrative purposes such as to improve the your phone service or our website’s performance or usability, (iii) to provide you with occasional updates about Cape, or (iv) otherwise only with your explicit consent. We use Mailchimp as our email manager, so they will have your email if you provide it via the website. That email is never linked to a Cape phone service user account, because by principle we avoid combining your data.

To whom do we disclose your personal information?
We do not sell your personal information, period. We may disclose your personal information in the following ways: (i) with our service providers, to help us operate the website or our cell phone service, for instance by sharing information like your IP address with web hosting companies or sharing necessary information, like your phone number, with our network partners who help us connect you to subscribers of other carriers, (ii) to protect the safety, property, or rights of our company or of any third party (for instance, law enforcement authorities if we witness harmful behavior on our website or our cell phone service, (iii) to prevent or stop any illegal, unethical or legally actionable activity (for instance, if we notice deceptive, fraudulent or illegal activity), (iv) to comply with our legal obligations, such as responding to legal or regulatory inquiries, and (v) in connection with an acquisition or sale of Cape, as permitted by law. This means if we get acquired, whatever information we have stored will become the property of our acquirer. The acquirer would be required by law to not 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.

What about Law Enforcement and other Government Requests? As a Mobile Virtual Network Operator, Cape is required to comply with lawful requests for subscriber and other information from law enforcement and other government requestors, for example under the federal Stored Communications Act. As described in this summary, we seek to minimize the amount of personal information we retain, and therefore we can only provide what we have.

In addition, before making any disclosure, Cape will notify its subscribers of receipt of any legal process seeking disclosure related to their accounts, thereby giving you the opportunity to challenge that request. In cases where we are explicitly prohibited by law or court order from notifying a subscriber about a government request, we will challenge any such request that is not narrowly tailored or otherwise lawful. To date, Cape has not received any requests for subscriber data that contained a nondisclosure obligation.

In other words, while Cape respects the role of law enforcement in an organized society, we will take all reasonable measures to keep our subscribers informed and to protect them against overreach.

How long do we keep your 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 may keep personal information longer to comply with tax or legal obligations. Specifically, we keep zip codes to comply with tax reporting requirements.

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.

Data type

When collected

Connected to
user account?

Who collects

Why is it collected
and how it is used

Retention by Cape

Name

Not collected

N/A

N/A

N/A

N/A

Street address

Not collected

N/A

N/A

N/A

N/A

Zip code

At payment

Yes

Cape, our payment processor Stripe, and tax service providers

Required for Cape to pay state and municipal taxes, and for Stripe to process your payment

For tax reasons, we must keep zip code for 3 years

Credit card number

At payment

Stripe generates a token that is stored on our systems to confirm a payment has been made. We do not store your credit card number. Cape does not associate tokens to subscribers.

Stripe. Cape does not collect full credit card numbers.

To process your payment

Cape does not keep this data.

Phone number

At sign-up

Yes

Cape and our network service providers who help us connect you to subscribers of other networks

Required for you to be able to make and receive voice calls, SMS, and MMS

If you are no longer a subscriber of Cape, we will not retain records of your phone number’s activity longer than 60 days (see Call Detail Records)

Location - Time of Arrival (TOA)

When your phone connects to a cellular base station

No

Our physical infrastructure partners. Cape does not collect this data.

Network management

Cape does not keep this data.

Location - Angle of Arrival (AOA)

When your phone connects to a cellular base station

No

Our physical infrastructure partners. Cape does not collect this data.

Network management

Cape does not keep this data.

Observed Time Difference of Arrival (OTDOA)

When your phone connects to a cellular base station

No

Our physical infrastructure partners. Cape does not collect this data.

Network management

Cape does not keep this data.

Location - GPS Coordinates

If you use e911 services or if you opt in to enhanced signaling protection.

If you use e911 services or if you opt in to enhanced signaling protection.

For e911 services, our physical infrastructure partners. For enhanced signaling protection, Cape collects this data.

For e911 services, to locate you in the event of an emergency. For enhanced signaling protection, to prevent signaling attacks

For e911 services, Cape does not keep this data. For enhanced signaling protection, Cape retains this data for 1 hour.

Location - Cell ID (which identifies a geographic area of coverage provided by a network tower)

When your phone connects to the network

Yes

Cape and, in the case of data usage, our network service providers who help us connect you to subscribers on other networks

To ensure connectivity, and for billing reconciliation

60 days. For data sessions, our partners who help us connect to subscribers on other networks keep this longer.

Location - Enhanced Cell ID (E-CID)

When your phone connects to a cellular base station

No

Our physical infrastructure partners. Cape does not collect this data.

Network management

Cape does not keep this data.

Call Detail Records (CDRs, also known as call logs)

When you send or receive a call or text, or when you use data

Yes

Cape and, in the case of data usage, our network service providers who help us connect you to subscribers on other networks

For billing, compliance, financial reconciliation, and spam call analysis and blocking

60 days. For data sessions, our partners who help us connect to subscribers on other networks keep this longer. In addition, for fraud cases, we will keep CDRs until the case is resolved, but this is the exception and not the rule.

Browser history

Not collected

N/A

N/A

N/A

Egress data, including DNS queries, is not inspected by Cape (for example, via deep packet inspection of data flows)

Email

Only if you sign up to our mailing list from cape.co

No

Cape and Mailchimp, our email marketing platform

To keep you informed about Cape news, products, and services

Until you unsubscribe

Subscriber SIM number (IMSI)

At sign-up

Yes

Cape and our network service providers who help us connect you to subscribers of other networks

Required to ensure connectivity across networks and billing reconciliation

If you are no longer a subscriber of Cape, we will not retain records of your phone number’s activity longer than 60 days (see CDRs)

Device number (IMEI)

When your phone connects to the network

Yes

Cape and our network service providers who help us connect you to subscribers of other networks.

Our partners may capture this information to screen for stolen devices and fraud.

60 days (see Call Detail Records)

MAC address (an identifier for your device)

When your phone connects to the network

Yes

Cape

Network security and management

We do not store this information

App data, including device model and OS version

When you download and use the Cape app

No. We assign random identifiers that are not tied to you or any information that can uniquely identify you.

Cape, Apple, Google

Apple and Google get app crash and performance data by default. Cape registers what app screens are viewed and how they’re interacted with, without linking that data to you, in order to improve your experience

60 days

Customer service communications

When you contact customer service with a question that requires us to troubleshoot your billing, onboarding, port-in or port-out, network issues, and other account-specific topics that you can’t resolve on your own within the app

Yes

Cape and our customer service platform provider

To allow our customer support team to address account-specific issues that you can’t resolve on your own within the app

120 days