Privacy Policy

LAST UPDATED: JUNE 26, 2023

RECAPPED PRIVACY POLICY

1. ABOUT RECAPPED

We are Recapped, Inc. a Delaware corporation (“Recapped”, “we”, “our” or “us”). We respect your privacy and are committed to protecting it through our compliance with this policy.

2. ABOUT THIS PRIVACY POLICY

This privacy policy (the “Privacy Policy”) applies to the personal information and other information we may collect on behalf of our clients (“Clients”) from our users (“you”) or that you may provide when you visit our website at https://www.recapped.io (the “Site”), our software-as-a-service platform (the “Software”), and all other related sites, platforms, applications, and services provided by us (together with the Site and Software, the “Services”). It explains, among other things, how and why we collect data about you when you use our Services, what data we collect, what we do with that data, how we look after it, and what your rights are in relation to it.

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, THEN YOU DO NOT HAVE PERMISSION TO USE OUR SERVICES. By accessing or using our Services, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Section 13 - Changes to This Privacy Policy). Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

3. DATA WE COLLECT ABOUT YOU

The personal information we collect via or in relation to the Services can be split into three broad categories:

· information you provide to us;

· information collected automatically; and

· information we obtain from third parties.

3.1 Information you provide to us

We may ask for and collect the following information when you use the Services:

Identity and profile information: We require you to provide certain personal information to create an account on the Services. The personal information we require may include your name, company name, job title, telephone number, email address, and profile picture.

Information from social networks: If you connect your social network profile to the Services, we collect your social network user information, which may include your name, company name, job title, telephone number, and email address, social network username, location, gender, birth date, profile picture, and public data for contacts.

Payment information: We may request your credit card or other payment information to collect payment for purchases made through the Services. We use Stripe, a third-party provider to process the credit card information and do not store your payment information. The use and storage of your payment information is governed by https://stripe.com/privacy.

Communications: When you communicate with us by email, mail, telephone, or through/via the Services, we collect information about your communication and any information you choose to provide.

3.2 Information we collect automatically

We may use automatic data collection technologies and collect certain information automatically when you use the Services. This information includes:

Usage data, interaction information, and history: Information about your interactions and history with the Services, including the pages that you visit and links you click on, search history, logs and location data, the time, frequency and duration of your Site visits and Software uses, and what features you used. The foregoing information includes traffic and usage trends on the Services. We also collect information about your computer/device and internet connection, including your IP address, operating system, and browser.

Cookies: Like many websites on the Internet, when you visit the Site, Recapped may assign your computer one or more cookies to facilitate access to the Site and to personalize your online experience. Through the use of a cookie, Recapped also may automatically collect information about your online activity on the Services, such as the web pages you visit, the time and date of your visits, the links you click, and the searches you conduct on the Services. Recapped may use this data to better understand how you interact with the Services, to monitor aggregate usage by our users and web traffic routing on the Services, and to improve the Site and our Services. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies, please note that you may not be able use some of the interactive features offered on the Services. In addition, please be aware that other parties may also place their own cookies on or through the Site and/or Services and may collect or solicit personal information from you. Other cookies may reflect de-identified demographic or other data linked to the registration data you have submitted to Recapped in hashed, non-human readable form. No personally identifiable information is contained in these cookies.

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 the Company, 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).

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the preferences or settings page of your web browser. For further details, visit donottrack.us.

The information we collect automatically may include personal information. It helps us to improve our Services and to deliver a better and more personalized service, including by enabling us to: estimate our audience size and usage patterns; store information about your preferences, allowing us to customize our Services according to your individual interests; speed up your searches; and recognize you when you return to our Services.

3.3 Information we receive from other sources

Service providers and business partners: We may also receive information about you from our service providers and business partners, including companies that assist with payment processing, analytics, data processing and management, account management, customer and technical support, hosting, and other services which we use to personalize your Recapped experience. We explain in more detail why and how we use this information below.

When we receive information from other sources, we rely on them having the appropriate provisions in place telling you how they collect data and who they may share it with.

4. HOW YOUR PERSONAL DATA IS USED

We will use the information we collect to:

Carry out our obligations arising from any contracts entered into between you and us and to provide you with the Services;
Better understand our users;
Respond to your enquiries or to process your requests in relation to your information;
Notify you about your account and important changes or developments to our Services;
To provide you with information, products, or services that you request from us;
Process payments for services, and complete other Services-related purchases and payments;
Ensure that the Services are being presented in the most effective manner for you, making the Services easier for you to use and to provide you with a smooth, efficient, safe and tailored experience;
Detect and protect us against error, fraud and other criminal activity, and enforce our agreements;
Enable us to display advertisements to our advertisers' target audiences;
Administer the Services and for internal operations, including troubleshooting, data analysis, testing, research, and statistical purposes;
Improve the Services and user experience to ensure that content is presented in the most effective manner for you;
Allow you to participate in interactive features of our Services, when you choose to do so;
Be used as part of our efforts to keep the Services safe and secure;
Identify additional customer opportunities and ensure that we are meeting the demands of our customers and users;
In any other way we may describe when you provide the information; and
For any other purpose for which you provide it, or with your consent.

We may also use your information to contact you about our products and services that may be of interest to you. To do so we may process your personal information to:

Send you promotional messages, marketing, advertising, and other information based on your preferences;
Personalize, measure, tailor, and improve our advertising;
Analyze characteristics and preferences to send you promotional messages, marketing, advertising, and other information that we think might be of interest to you,

We may combine information received from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the information we receive).

5. SHARING YOUR PERSONAL DATA

The following describes the ways we may share your personal information in the normal course of business and in order to provide our Services.

With your consent: We will disclose your personal information when and if you have agreed that we may do so. We will make this clear to you at the point at which we collect your personal information, including the purpose(s) for which we will use the personal information.

Intended purpose: We will use your personal information to fulfill the purpose for which you provide it, or for any other purpose disclosed by us when you provide the information.

Sub-processors: We use contractors, service providers, and other third parties (“Sub-processors”) to facilitate or outsource some aspects of our Services and some of these Sub-processors will process your personal information. The purposes for which we use such Sub-processors include: (i) cloud infrastructure hosting and database management; (ii) scheduling, (iii) application monitoring, error tracking, and telemetry; (iv) hosted search; (v) marketing; (vi) open authorization; (vii) conversion and analytics; (viii) CRM and optional integration; (ix) support; (x) link and video processing; and (xi) email notifications. We use reasonable efforts to ensure that our Sub-processors have appropriate technical, operational, and organizational safeguards to handle personal information and are commissioned to process personal information. For additional information for these Sub-processors, we recommend that you read their privacy policies so that you can understand the manner in which your personal information will be handled by them.

Our Sub-processors include but are not limited to: Amazon Web Services; ChilliPiper; DataDog; ElasticSearch; Facebook pixel; Filestack; Google; Google Analytics; Heap; HubSpot; HubSpot; Intercom; LinkedIn; Lucky Orange; MicroLink; Microsoft; Okta; Pendo; Twitter pixel; SalesLoft; Salesforce; Sentry; and Vero. We may change or add to our Sub-processors from time to time without notice to you.

Aggregated data: We may disclose or publish information in an aggregated and anonymized format, without restriction. This data does not personally identify you and helps us to measure the success of the Services and its features and to improve your experience. We reserve the right to make use of any such aggregated data as we see fit.

If required by law: We may be required to disclose your personal information by law, in response to a valid order of a court or other authority, or to respond to regulatory requests or requests relating to criminal investigations.

Change of control: We may transfer your personal information 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 Recapped's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Recapped about our Services users is among the assets transferred. If this happens, you will be informed of this transfer.

Enforcing our terms of use: We may disclose your personal information to enforce or apply our terms of use (https://www.recapped.io/terms) and other agreements, including for billing and collection purposes.

Protecting our rights: We may disclose your personal information if we feel this is necessary in order to protect or defend our legitimate rights and interests and/or to ensure the safety and security of the Services.

Subsidiaries and affiliates: We may disclose your personal information to our subsidiaries and affiliates, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures.

6. DATA SECURITY

Recapped (either itself or through third party service providers) maintains a variety of commercially reasonable electronic and procedural safeguards, tools, and techniques designed to protect your personal information from unauthorized access, use, alteration, and disclosure.

You should be aware that Recapped has no control over the security of other sites on the Internet that you might visit or with which you might interact even when a link may appear to another site from one of the Services. You must play your part in the safety and security of your information. 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 and therefore must not share your password with anyone. Recapped wants you to feel confident using the Services, but no system can be completely secure. Therefore, although Recapped takes steps to secure your information, Recapped does not promise, and you should not expect, that your personal information or communications will always remain secure. In the event of a breach of the confidentiality or security of your information, including your personal information, Recapped will notify you as necessary and if possible so you can take appropriate protective steps. Recapped may notify you under such circumstances using the e-mail address(es) that Recapped has on record for you. You also should carefully handle and disclose your personal information.

7. UPDATING AND RETENTION OF YOUR DATA

If we have no direct relationship with you, you should direct any query to access, correct, amend, or delete inaccurate data to our Client, which is the data controller for your information. If you are such an individual and you wish to identify the specific Client that is acting as the data controller of your information, please contact help@recapped.io and we will provide the relevant contact information, provided that we receive approval of release of that information from the data controller.

If we have a direct relationship with you, please contact us in by email at help@recapped.io for instructions on accessing or correcting your information, or to request a copy of the information we hold about you. Please note that 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.

We retain personal information as long as we are providing the Services to our Clients. In addition to providing the Services to our Clients, we retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreement, We retain and use personal information after we cease providing Services to you and/or our Client, even if you delete your account, to the extent necessary: to fulfill your request (for example, keeping your email address to make sure it’s not on our mailing list); to comply with our legal and regulatory obligations; for the purpose of fraud monitoring, detection and prevention; to comply with our tax, accounting, and financial reporting obligations; where we are required to retain the data by our contractual commitments to our partners; or where we have a legitimate business purpose. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law. Even if you delete your account and we delete your information from our systems, keep in mind that: copies of your information may remain viewable elsewhere to the extent you have publicly published them or otherwise shared them with others; and the deletion by our third-party providers may not be immediate and that the deleted information may persist in backup copies for a reasonable period of time.

8. YOUR RIGHT TO OPT OUT

You may unsubscribe from future promotional e-mail communications from us by clicking on the unsubscribe link provided in our e-mail communications. Regardless of your decision to opt-out of promotional e-mail communications, we may still contact you to respond to an inquiry, regarding your account, your use of the Services, or for security purposes.

9. CHILDREN

The Services are not intended for use by children. Individuals under the age of 18 are not permitted to use the Services and must not attempt to register an account or submit any personal information to us. We do not knowingly collect any personal information from any person who is under the age of 18, allow them to register an account. If it comes to our attention that we have collected personal information from a person under the age of 18, we will delete this information as quickly as possible.

If you are a parent or guardian and you learn that your child (under the age of 18) has provided us with personal information, please notify us immediately at help@recapped.io.

10. CALIFORNIA RESIDENTS

The California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act, requires specific disclosures for consumers who are California residents. This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under California law.

For more details about the personal information we collect, including the categories of sources, please see Section 3 “Data We Collect About You” of this Privacy Policy. We collect this information for the business and commercial purposes described in Section 4 “How Your Personal Information is Used”. We share this information with the categories of third parties described in Section 5 “Sharing Your Personal Data section”.

10.1 Your rights under the CCPA

10.1.1 Right to Know and Data Portability. Under the CCPA, you may request, up to two (2) times within a 12-month period, certain information about our collection and use of your personal information over the past 12 months. Once we have received and authenticated your request, we will disclose to you:

(a) the categories and specific pieces of data the that Recapped has collected about you;

(b) the categories of sources from which your data was collected;

(d) the purposes for which the information was disclosed or sold; and

(e) if we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

(i) sales, identifying the personal information categories that each category of recipient purchased; and

(ii) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

10.1.2 Right to Correct and Delete. You may ask us to correct inaccurate information that we have about you. Subject to certain exceptions, as a California consumer, you have the right to request that we delete any of your personal information that we collected from you and retained. Once we have received and authenticated your request, we will review it to determine whether there is an applicable exception allowing us to retain the information. We will delete or deidentify personal information not subject to one of the exceptions permitted under the CCPA from our records and will direct our service providers to take similar action.

10.1.3 Freedom from Discrimination. You have the right not to be discriminated against for exercising your CCPA rights. Unless permitted by the CCPA, we will not: (a) deny you goods or services; (b) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (c) provide you a different level or quality of goods or services; or (d) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

10.1.4 Right to Opt-Out of Personal Information Sales or Sharing. We do not consider the ways we share your information as a “sale” for purposes of California law, and we will not sell it without providing a right to opt out.

You may request to opt-out of the sharing of your personal information for cross-context behavioral advertising. Once we have received and authenticated your request, we will review it to determine whether there is an applicable exception allowing us to continue sharing the information. We will respond to your as soon as feasibly possible to your request, up to a maximum of 15 business days from the date we received your request to opt-out.

10.1.5 Exercising Your Rights. If you would like to exercise your rights to know, correct, delete, or opt-out described above, please submit your request by emailing us at help@recapped.io. Your request must:

(a) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and

(b) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with your personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

You do not need to create an account with us to submit a request. We will only use personal information provided in the request to verify the requestor's identity or authority to make it.

10.1.6 Responses to Verifiable Consumer Requests. We will confirm receipt of your request within 10 business days. Except as otherwise set forth in this Privacy Policy, we make every effort to substantively respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. If applicable, our response will also explain the reasons we cannot comply with a request. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

10.2 Rights Related to Direct Marketing

California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. Recapped does not currently disclose any information to third parties for direct marketing purposes.

11. RESIDENTS OF NEVADA

Recapped does not currently sell your “personally identifiable information” as defined under applicable Nevada law and will not sell it without providing a right to opt out. If you are a Nevada resident and user of our Services, you may submit via email a request to opt out of any potential future sales under Nevada law to: help@recapped.io. Once verified, we will maintain your request should our practices change.

12. VISITING THE SITE AND SERVICES FROM OUTSIDE THE UNITED STATES

This Privacy Policy is intended to cover collection of information on the Services from residents of the United States and is not directed to the residents of any other country. If you are visiting the Site or using the Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where Recapped’s servers are located and Recapped’s central database is operated. By using the Services, you understand that your information may be transferred to Recapped’s facilities and those third parties with whom Recapped shares it as described in this Privacy Policy. You are responsible for ensuring that information you share conforms to all local data protection laws.

13. MORE INFORMATION

It is our goal to make our privacy practices easy to understand. If you have questions or concerns about this privacy policy or if you would like more detailed information about our privacy practices, please contact us at:

Recapped, Inc.
244 Waverly Place, #1B,
New York NY 10014
help@recapped.io

14. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may change from time to time and, if it does, the up-to-date version will always be available on our Services. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Services and update the “Last updated” date at the top of this page. Please be sure to periodically check this page to ensure that you are aware of any changes to this Privacy Policy. Any material changes to this Privacy Policy will be communicated to registered users by a notification to their account and/or by posting a notice of the change on the Services. Please understand that your continued use of our Services following the posting of changes constitutes your acceptance of such changes.