Capsule - Privacy Policy

Last Revised: July 08th , 2021

We, NewCo and our affiliates (collectively, “Company” “we” or “us”) respect the privacy of the users of our online marketing website, available at https://capsule.im/ including its sub-domains (collectively, the “Site”), our social calendar mobile application (the “App”) and our landing-pages (the “Landing Page(s)”, and respectively, “you” or the “User(s)”). For the purpose of this Privacy Policy, the Site, the Landing Pages and the App shall be referred to collectively as the “Platform”.

We believe that you have a right to know our practices regarding the information we may collect and use when you visit and/or use our Platform, and we are committed to protecting the personal information that you share with us.

Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use at https://capsule.im/capsule/tos/ (“Terms of Use”), into which this Privacy Policy is incorporated by reference.

1.Your Consent (PLEASE READ CAREFULLY!)

This Privacy Policy details how your Personal Information (as defined below) is used and processed by the Company, or on its behalf, in the context of your use of the Platform.

BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE AND/OR LANDING PAGES AND/OR BY DOWNLOADING AND/OR INSTALLING ON YOUR MOBILE DEVICE AND/OR ACCESSING AND/OR USING THE APP, YOU ACKNOWLEDGE THAT YOU ARE OR HAVE HAD THE OPPORTUNITY TO BECOME AWARE OF AND AGREE (IN JURISDICTION WHERE SUCH CONSENT IS REQUIRED) TO THIS PRIVACY POLICY AND COMPANYS’ PRACTICES DESCRIBED HEREIN, INCLUDING THE PROCESSING (INCLUDING COLLECTING, USING, DISCLOSING, RETAINING OR DISPOSING) OF YOUR PEROSNAL INFORMATION UNDER THE TERMS OF THIS PRIVACY POLICY.

2.Which information we may collect on our Users?

We may collect two types of data and information from our Users:

a.Non-personal Information. The first type is non-identifiable and anonymous information. Non-personal information, which is being gathered, consists of technical information and behavioral information that does not pertain to a specific individual (“Non-Personal Information”).

Like most online services, when you access and use the Platform we passively collect certain Non-Personal Information from your devices (depending on whether you access our Site, Landing Pages or App), including: (i) technical information such as the type and version of your device and its operating system, the type of browser, screen resolution, device browser and keyboard language, Wi-Fi connectivity and the type and name of your device and/or browser, etc.; and (ii) behavioral information which may include the User’s click-stream on the Platform, the activities of the User on the Platform and additional information of a similar nature (collectively, “Technical and Behavioral Information”). We may use third-party service providers to obtain detailed analytics on the device and the User's behavior on the Platform. Please note that we or our third-party service providers will collect such Technical and Behavioral Information by using certain tracking technologies, such as cookies, as further detailed below.

b.Personal Information. The second type of information is individually identifiable information (“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature.

Personal Information which is provided voluntarily:

  • Communications with the Company: Personal Information you provide us as part of any communications with the Company, by any means, including by contacting us via the Site and/or Landing Pages and/or App or any other communications method such as by email or through our social network pages (such information may include marketing and communication data that includes your preferences in receiving marketing from us and your communication preferences). Please note that we may record phone calls for quality assurance purposes and in order to improve our services. 

  • Registration to the App: Personal Information is collected from the details the Users provide in the registration form available on the App (which enables the Users to open an Account), which includes, inter alia, name (including username), country, telephone number and profile photo. Please note that as part of the registration and/or log-in process, we may send you a text massage in order to verify your mobile number and connect you to your Account. Additional information may be requested in the future.

  • User Content: Personal Information includes any data and/or content, including User Content, that you may upload or generate through use of the App, including by way of integrating the App with Third Party Services (such as, Outlook calendar). Such information may include, for example, information related to meetings, your schedule, contact details, photos, data, links, texts, contact information of the Contact Person to whom you may send an invitation to an appointment, etc.  Please note that in order to facilitate the sending of appointment invitations to Contact Persons, we may be required to access the contact lists on the device on which the App has been installed and that we do not retrieve or otherwise copy such lists, but only information relating to the specific Contact Person(s) concerned.

Please note: if you upload personal information which relates to third parties, including without limitation personal information of Contact Persons to whom you wish to send an appointment invitation through the App, you represent and warrant that you have received all required consents and provided all required notices to the affected data subject, in order to facilitate the disclosure of such information to the Company, all to the extent required under applicable law. In this respect, please note that when sending appointment invitations to Contact Persons, such Contact Persons may receive text and email messages from the Company relating to such invitation.

  • Third Party Services: Users may integrate their existing third-party calendar accounts (Third Party Services) with the App. When you integrate the App through such existing Third-Party Services’ accounts, then such third-party accounts provide us with access to certain information, which is detailed and displayed to you in the notice which appears during the integration process, which may include your name, email address and calendar appointments. Please carefully read such notice in order to understand what information is made available to us via your Third-Party Services’ accounts. We may collect your login information and other relevant information necessary to enable us to access your Third-Party Services’ accounts in order to collect the abovementioned information. Please note that such information is stored locally on your device. If you do not agree to these practices, please do not use Third-Party Services’ accounts in order to use our App.

  • Landing Pages: to the extent that a User accesses our Landing Pages, the User may voluntarily provide his/her email address for the purposes of sending appointment invitations directly to his/her email box, rather than through the Landing Pages. Please note that we may also offer Users that visit the Landing Pages to voluntarily join our mailing list.

  • Mailing List: we may collect your personal information, including your name, email address and other communication methods, when you join our mailing list.

Personal Information collected from other Users:

  • Contact Persons: we may collect, with respect to Contact Persons (including those who have not opened an Account to use the App), any information concerning them which was uploaded to the App by the App’s Users. For example, Users of the App may invite Contact Persons to certain meetings, and in doing so they may provide us with such Contact Persons’ telephone number, e-mail addresses and other information relating to the meetings; as such, we will process the information provided to us as well as certain information derived from such details, for example the relevant Contact Persons’ location, schedule, photos and so forth.

Personal Information collected via technology:

  • IP/MAC Address: users of the Platform may automatically provide their IP address (or Mac Address, as applicable) and/or advertiser identifier (when available on a device) mainly for enhancing the User’s experience and for geo-location and security purposes as further detailed below.

  • Geolocation data: while using the Platform we will access, collect, process, monitor and/or remotely store "geolocation data", including through the collection of GPS coordinates and IP analysis, to determine your location, in order to provide you our services, and for analytics and security purposes.

  • Technical and Behavioral Information: to the extent that the Technical and Behavioral Information detailed above under Section 2(a) will be linked to or associated with a specific individual then such information will be considered as Personal Information.

  • Identifiers: while using the Platform we may collect certain unique identifiers, such as Internet Protocol (IP) address, your Unique Device Identifier (UDID), or other unique identifiers for security purposes and analytics and in order to provide you with our services via the Platform.

For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.

We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your active acceptance to the Terms of Use and the Privacy Policy.

3.How Do We Collect Information on Our Users?

There are three main methods we use:

a.We collect information through your entry, connection, installation, access and/or use of Platform. In other words, when you are using the Site, App or Landing Page we are aware of it and may gather, collect and store the information relating to such usage.

b.We collect information which you provide us voluntarily. For example, we collect Personal Information when you register and open an Account (as defined in the Terms of Use), interact with other Users and upload User Content.

c.We collect information relating to Contact Persons from Users of the App. App Users may provide us with certain information relating to Contact Persons, such as their telephone numbers.

We may gather, collect and store such information either independently or through the help of our authorized third-party service providers as detailed below.

4.What are the Purposes of the Collection of Information?

We collect Non-personal Information and Personal Information in order to operate the Platform and provide the Services.

Non-personal Information is collected in order to:  

  • Use it for statistical and research purposes and for customization and improvement of our Services.

  • Provide and improve the Services for our commercial purposes.

  • Improve the quality of the Services by formulating, customizing and enhancing the User's experience.

Personal Information is collected in order to:  

  • Enable the overall operation of the Platform.

  • Personalize your experience on the Platform.

  • Improve the quality of the Platform and the Services by formulating, customizing and enhancing the User's experience.

  • Allow us to contact Users with proposals and tailored information regarding new products, events, offers, services, features, enhancements, special offers, upgrade opportunities, and events of interest etc.

  • Send text messages and emails to Contact Persons. Contact Persons may choose to opt out of receiving such messages by using relevant functionality on the applicable Landing-Page. or by sending us an email to: unsubscribe@capsule.im

  • Send push notifications to Users of the App. Users of the App can deactivate push notification by changing their settings within our App or by using their device’s settings.

  • Verify the User's identity when he/she signs in to the App, as well as verifying User's identity for the purpose of dealing with inappropriate interactions of User and/or fraudulent use of our App.

  • Be able to contact Users for the purpose of providing them with technical assistance and support.

  • Keep the Platform safe and secured and for prevention of fraud and crime;

  • Maintain our data processing records and general administrative purposes;

  • Determine general geo-location information (i.e., country) from which the User's computer is connected to the Internet in order for us to know the general location of our Platform's Users as well as in order to safeguard our Platform. 

5.Sharing Information with Third Parties

The Company respects your privacy and will not disclose, share, rent, or sell your Personal Information to any third party, other than as permitted under this Privacy Policy.

Notwithstanding, the Company may share Personal Information in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy and/or the Terms of Use, including investigation of potential violations thereof; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to User's support requests; (e) to respond to claims that any content available on the Platform violates the rights of third-parties; (f) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; (g) to protect the rights, property, or personal safety of the Company, its Users, or the general public; (h) when the Company is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets; (i) to collect, hold and/or manage your Personal Information through Company’s authorized third parties service providers (including, as applicable, their affiliates as necessary to provide us with the requested services), as reasonable for business purposes, which may be located in a country that does not have the same data protection laws as your jurisdiction; (j) to store or process your Personal Information through Company’s affiliated companies, which may be located in a country that does not have the same data protection laws as your jurisdiction. The Company requires its affiliated entities to agree to processing your Personal Information in compliance herewith; (k) cooperate with third parties for legitimate business purposes, including without limitation, enhancing the User's experience; and/or (l) pursuant to your explicit approval prior to the disclosure.

For avoidance of doubt, the Company has the unrestricted right to use Non-personal Information for any purpose and to transfer and disclose Non-personal Information to third parties at its own discretion.

6.Social Features

Our Platform may include social media features (“Social Features”). The Social Features are operated or allow for social integration with certain third-party social networks or third party platforms (“Social Network”). These Social Networks are created and maintained by third parties who are not affiliated with and/or controlled by the Company. If you enable this integration with such Social Networks, your use of the Social Features is subject to the applicable third-party Social Network’s terms of use and privacy policies. You should ensure that you read their terms of use and privacy policies to understand how they treat your information and in order to understand the methods for changing the privacy or sharing settings on such services. If you do not agree to the practices described in such terms you should not allow the Platform to interact with such Social Networks, however you may find that you are not able to enjoy all the features that may be made available via the Platform. You understand that where you allow interaction with any third-party Social Network, we may share data about you with your contacts (and vice versa) in order that you may enjoy social elements. This data may include, without limitation, your name and your social media profile picture. By using the Social Features you hereby agree and understand that the applicable Social Networks or Platforms may collect certain Personal Information, such as your IP address, Non-personal Information and may set cookies and/or other web tracking technologies to enable the functionality of the Social Features. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the third party that provides the Social Features. You hereby understand and agree that when you share content via Social Networks that your content may become public and others may re-post-it.

7.Deletion or Modification of Personal Information

The Company acknowledges you may have the right under applicable law to access, change and delete the Personal Information we collect and process. If you wish to access or to correct, amend, or delete Personal Information, please send us an email to: support@capsule.im and we will respond within a reasonable timeframe, but in any event no later than permitted by applicable law.

8.Minors

The Platform are intended for Users over the age of sixteen (16). Therefore, the Company does not intend and does not knowingly collect Personal Information from minors under the age of sixteen (16) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Platform. If we learn that we collected Personal Information from minors under the age of sixteen (16) we will delete that information as quickly as possible. Please contact us at report@capsule.im if you have reasons to suspect that the Company collected Personal Information from minors under the age of sixteen (16) and we will delete that information as quickly as possible.

9.Security

We take reasonable measures to maintain the security and integrity of our Platform and your information and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use of your Personal Information will never occur.

10.Third Party Service Providers

While using the Platform we may be using third party service providers, who may collect, store and/or process your Personal Information, as detailed in this Privacy Policy. Note, that we collect, hold and/or manage your Personal Information through our authorized third party vendors of certain products or services (such as hosting cloud services, including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes.

Such third parties service providers include the following service providers:

  • Cloud application platforms and infrastructure, including Firebase, Heroku, AWS and Google;

  • Application monitoring services, including Sentry;

  • Message management services, including CloudMailIn; and

  • Log management services, including Papertrail.

11.International Data Transfer

The information collected from you, as detailed in this Privacy Policy, may be transferred to, processed and stored by the Company and/or its service providers on servers and by staff which may be located in countries outside of your jurisdiction, namely in the European Union, in Israel and in the United States.

The Company is committed to protecting your Personal Information and will take appropriate steps to ensure that your Personal Information is processed and stored securely and in accordance with applicable privacy laws, as detailed in this Privacy Policy. Such steps include putting in place data transfer agreements or ensuring our third-party service providers comply with our data transfer protection measures.

BY SUBMITTING YOUR PERSONAL INFORMATION THROUGH THE PLATFROM, YOU ACKNOWLEDGE, AND CONSENT, TO SUCH TRANSFER, STORING AND/OR PROCESSING OF PERSONAL INFORMATION.

12.Data Retention

The Company will retain the Personal Information for as long as your Account to use Platform is active and for a period of 7 years thereafter, for archiving purposes, to defend against potential legal claims and to comply with our legal obligations. Personal Information which is no longer required for the purpose for which is was initially collected will be deleted unless we have a valid justification to retain it which is permitted under applicable law, such as to resolve disputes or comply with our legal obligations.

13.Links to Third Party Websites

Certain links provided herein permit our Users to leave the Platform and enter non-Company sites or services. Those linked sites and services are provided solely as a convenience to you. These linked sites and services are not under the control of the Company and it is not responsible for the availability of such external sites or services, and does not endorse and is not responsible or liable for any content including but not limited to content advertising, products or other information on or available from such linked sites and services or any link contained in linked sites or service. In addition, the Company is not responsible or liable for such linked sites and services' privacy practices and/or any other practices. Your access to, use of and reliance upon any such sites, services and content and your dealings with such third parties are at your sole risk and expense. The Company reserves the right to terminate any link at any time. You further acknowledge and agree that the Company shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused, by or in connection with use of or reliance on any services, content, products or other materials available on or through such linked sites or resource. Most of such linked sites and services provide legal documents, including terms of use and privacy policy, governing the use thereof. It is always advisable to read such documents carefully before using those sites and services, inter alia, in order to know what kind of information they are collecting.

14.Cookies and Other Tracking Technologies

When you access or use the Platform, we and/or our third party service providers may use industry-wide technologies such as cookies, web beacons, pixels, clear gifs and other similar tools (or other similar technologies) (collectively, "Cookies") which may enable us, amongst others, to recognize your device from those of other Users of the Platform, to improve the Platform's performance, to deliver a better and more personalized service according to our Users' individual interests and the device or browser used, to track Users' use of the Platform, to gather information about the Users' approximate geographic location (e.g. city), to prevent fraud and/or abuse, to estimate our audience size and usage pattern and perform other analytics, to develop our Platform and to serve targeted advertisements. 

Cookies may locally store certain Technical and Behavioral information and other Personal Information on your device and we and/or our authorized third party service providers may access such information for the purposes detailed under this Privacy Policy. We and/or our authorized third party service providers may use both session Cookies (which expire once you close the web-browser) and persistent Cookies (which stay on the User’s device until he/she deletes them).

Most devices and browsers will allow you to erase Cookies from your device’s hard drive, block acceptance of Cookies, or receive a warning before a Cookie is stored on your device. However, if you block or erase Cookies, your experience of the Platform may be limited.

For detailed instructions regarding the blocking of Cookies, please refer to your browser's 'help', 'tool' or 'edit' sections or see http://www.allaboutcookies.org/manage-cookies/. Below are links to instructions regarding the blocking of Cookies on commonly used web-browsers: Chrome, Internet Explorer and Microsoft Edge, Mozilla Firefox and Safari.

It is possible to opt-out of having your browsing activity within the Platform recorded by performance cookies. Please note that we use Google Analytics as our service provider in order to track Users' activities on the Site and/or Platform, including by use such services' persistent cookies. Google provides a browser-add on which allows users to opt-out of Google Analytics across all websites, which can be downloaded here: https://tools.google.com/dlpage/gaoptout.

You can opt out of receiving interest-based advertising on your device by visiting the following sites: www.aboutads.info/choices/, www.networkadvertising.org/choices/, choices.ghosteryenterprise.com/global-opt-out.html, and preferences-mgr.truste.com/. If you wish to opt out of receiving interest-based advertising on your mobile device, please see the advertising preferences information on support.apple.com for iOS devices or support.google.com  for Android devices.

15.Direct Marketing

You hereby agree that we may use your contact details for the purpose of informing you of products, services and other updates and new features which may be of interest to you, as well as for sending you other materials to the e-mail address provided in the registration process. You may withdraw your consent via sending a written notice to the Company by e-mail to the following e-mail address: unsubscribe@capsule.im or alternatively following the instructions for removing yourself from the mailing list which are available in the e-mail transmitted to you.

16.Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the Platform and/or Services and any information collected with respect thereto. The Company reserves the right to change this policy at any time, so please re-visit this page frequently. In case of any material change, we will make reasonable efforts to post a clear notice on the Platform and/or we will send you an e-mail (to the extent that you provided us with such e-mail address) regarding such change. Such substantial changes will take effect seven (7) days after such notice was provided on our Platform or sent by e-mail, whichever is the earlier. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the Platform after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the Terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by the law and without any prior notice.

17.Got any Questions?

If you have any questions (or comments) concerning this Privacy Policy, you are most welcome to send us an email to the following address: privacy@capsule.im and we will make an effort to reply within a reasonable timeframe.