# CAPZ PRIVACY POLICY

**Effective Date:** December 5, 2025

**Last Updated:** September 19, 2026

Capz is a mobile and web platform operated by Capz HQ LLC, a Pennsylvania limited liability company ("we," "us," "our"). This Privacy Policy ("Policy") explains what information we collect when you use Capz, why we collect it, who we share it with, and the choices and rights you have.

This Policy is a disclosure about our privacy practices. Your contractual relationship with Capz HQ LLC — including terms of use, disclaimers, limitations of liability, license restrictions, and dispute resolution — is governed by our Terms of Service and End User License Agreement, which are separate documents.

We review and update this Policy at least once every twelve months.

---

## 1. SCOPE AND APPLICATION

This Policy applies to all users of the Capz mobile application and website, and to all personal data we collect through them.

Capz is intended for and directed to residents of the United States. See Section 14 regarding access from outside the United States.

Nothing in this Policy limits or waives any right you have under the privacy law of the state in which you reside. Where a state privacy law grants you rights beyond those described here, that law controls.

---

## 2. DEFINITIONS

- **Personal Data** — information that identifies, relates to, describes, or could reasonably be linked with an identifiable individual or household.

- **Processing** — any operation performed on Personal Data, including collection, use, storage, disclosure, and deletion.

- **Service Providers** — third parties that process Personal Data on our behalf and under our instructions.

- **Sensitive Personal Data** — categories treated as sensitive under applicable state law, such as precise geolocation, government identifiers, account credentials, biometric data, and data revealing racial or ethnic origin, religious beliefs, health status, sexual orientation, or immigration status.

- **Organization** — a fraternity, sorority, club, or similar student organization created on Capz, together with its members and admins.

---

## 3. DATA WE COLLECT

### 3.1 Information You Provide

| Category | Examples | Source |

|---|---|---|

| Account identifiers | Email address (used to sign you in), username, display name, and — optionally — a phone number | Directly from you |

| Profile information | Profile photo, organization affiliations you join, and your "searchable by name" preference | Directly from you |

| User content | Messages and images you send in organization group chats and channels; polls you create and the options you vote for; events, invite lists, and event details you create; RSVP responses | Directly from you |

| Organization content | Organization name, description, and organization logo you upload as an admin | Directly from you |

| Invite codes | Invite codes you generate as an admin (including the maximum number of times each may be used) and codes you redeem to join an organization or invite list | Directly from you |

| Organization verification documents | Only if you create an organization: your full name, a school email, photos of the front and back of a photo ID, and proof of your organization membership (e.g. a chapter composite, membership card, or house record) (see Section 3.5) | Directly from you |

| Support communications | Inquiries, correspondence, and attachments you send us | Directly from you |

We authenticate you with a one-time code sent to your email address; we do not ask you to create or store a password. A username is required and is your primary public identity; a phone number is optional and is only stored if you choose to provide it.

### 3.2 Information Generated by Your Use of Capz

| Category | Examples | Source |

|---|---|---|

| Messaging activity | Which messages you have read, when you last read a group chat, and delivery/read status shown to the sender ("read receipts") | Your use of the app |

| Real-time presence | Typing status, transmitted live to other members of a group chat while you are composing a message and not stored afterward | Your use of the app |

| Poll participation | Which option you selected in a poll, recorded against your account so results can be displayed | Your use of the app |

| Event participation | Event invitations you receive, your RSVP, and which invite lists you belong to | Your use of the app |

| Notification history | A record of in-app notifications sent to you (new messages, event invitations, event reminders, organization invitations, role changes) and whether you have read them | Our systems |

| Administrative audit records | Actions taken by organization admins — such as role changes, channel configuration, member removal, and invite creation — logged for accountability | Our systems |

| Legal acceptance records | Which version of this Policy, the Terms of Service, and the EULA you accepted, and when | Our systems |

| Muting and notification preferences | Group chats you have muted and the notification categories you have enabled | Directly from you |

| Blocks | The list of users you have blocked. This list is visible only to you — we never tell someone that they have been blocked, and you cannot see who has blocked you | Directly from you |

| Reports | When you report a message or a user: the reason you selected, any details you add, who you reported, and a copy of the reported content (kept so it survives deletion). Reports are visible only to Capz staff — never to other users, and never to the person reported | Directly from you |

### 3.3 Information Collected Automatically

| Category | Examples | Source |

|---|---|---|

| Device information | Device model, operating system, app version, and a push notification token (if you enable notifications) | Your device |

| Network information | IP address, coarse location inferred from IP (city/region level), connection type | Your device / our hosting provider |

| Usage and activity data | Features accessed, session duration, in-app interactions | Your device |

| Diagnostics | Crash reports and error logs | The mobile platform (Apple/Google) and our backend logs |

| Security logs | Authentication events, access attempts, abuse and fraud signals | Our systems |

Capz does not integrate any third-party analytics, advertising, attribution, or behavioral-tracking software. Diagnostic information is limited to crash and error reporting provided by the mobile operating system and to server-side logs generated by our backend provider.

### 3.4 Data Collected Only With Your Permission

The following are accessed only after you grant permission through your device's operating system. You may revoke any of these permissions at any time in your device settings, and doing so will not prevent you from using the rest of Capz.

- **Camera** — to take a photo to send in a group chat, to set as a profile or organization image, or to photograph organization verification documents

- **Photo library (read)** — to let you choose an existing image to upload. Capz reads only the image you select; it does not browse, index, or upload the rest of your library, and it does not request photo location metadata.

- **Notifications** — to deliver push notifications you have enabled

Capz does not ask for permission to **write** to your photo library, because Capz cannot save images to your device. Capz does not request access to your microphone, your contacts, your calendar, your precise (GPS) location, or your health data.

### 3.5 Sensitive Personal Data

The one situation in which we collect Sensitive Personal Data is **organization verification**. If you choose to create an organization, we ask you to use your device camera to photograph the **front and back of a photo ID** (a government identifier) and proof of your organization membership (such as a chapter composite that includes you, a membership card, or a house record), and to provide your full name and a school email, so that we can verify you are a real, authorized member of a real organization and prevent impersonation. You must confirm you are **18 or older** before you can submit these documents. These verification documents:

- are used **only** to verify your organization;

- are stored in a **private** location that is not accessible to other users;

- are reviewed only by authorized Capz personnel; and

- are **retained for up to one year, after which they are deleted**.

Providing verification documents is entirely optional — it is required only if you choose to create an organization. We do not use these documents to infer characteristics about you, and we do not collect any other category of Sensitive Personal Data for that purpose. If you otherwise include Sensitive Personal Data in content you submit, we process it only as necessary to operate the feature you used.

---

## 4. COOKIES, LOCAL STORAGE, AND SIMILAR TECHNOLOGIES

Our website uses cookies and similar technologies, and our mobile app uses on-device local storage and identifiers, for the following purposes:

- **Strictly necessary purposes** — authentication, session management, and security. Our authentication provider stores a session token on your device so you stay signed in; these cannot be disabled without breaking core functionality.

- **Functional purposes** — remembering your preferences and settings, such as your light/dark appearance choice, stored locally on your device.

We do **not** use cookies, local storage, or similar technologies for analytics, advertising, cross-context behavioral targeting, or third-party tracking. We do not load third-party analytics or advertising trackers.

You can control cookies through your browser settings and clear local app storage through your device settings. See Section 8 regarding opt-out preference signals.

---

## 5. WHY WE PROCESS PERSONAL DATA

| Purpose | What this covers |

|---|---|

| Providing Capz | Creating and authenticating your account, delivering messages, images, polls, events, and invitations, and operating the features you use |

| Group chat functionality | Showing read status to senders, showing live typing indicators, ordering and syncing messages across your devices |

| Polls | Recording your vote, calculating totals, and displaying who selected each option to other members of that group chat |

| Events and invitations | Delivering invitations, recording RSVPs, showing attendee lists to invitees, and managing invite lists |

| Organization administration | Operating admin tools (roles, channels, invite codes, member management) and maintaining audit records of admin actions |

| Organization verification | Reviewing documents you submit to verify an organization, confirm authorized membership, and prevent impersonation |

| Communication | Sending sign-in codes and service messages, responding to support requests, delivering notifications you enabled and your in-app notification history |

| Operations and improvement | Debugging, diagnosing crashes, and understanding which features are used so we can fix problems |

| Safety and security | Detecting and preventing fraud, abuse, spam, harassment, invite-code misuse, and unauthorized access; enforcing our Terms of Service |

| Legal compliance | Meeting legal obligations, recording your acceptance of our legal documents, responding to lawful requests, establishing or defending legal claims |

We do not process Personal Data for purposes that are materially different from those listed above without first notifying you.

---

## 6. HOW WE SHARE PERSONAL DATA

### 6.1 Service Providers

We share the minimum data necessary with vendors that perform functions on our behalf:

- **Cloud hosting, database, storage, and authentication** — our backend provider stores your account data, content, and images and manages sign-in.

- **Email delivery** — to send your one-time sign-in codes and service emails.

- **Push notification delivery** — the Expo push service together with Apple Push Notification service (iOS) and Google Firebase Cloud Messaging (Android) deliver notifications to your device. The visible text of a notification (for example, a sender's name and a message preview) passes through these services in order to be delivered.

Service Providers are bound by written contracts that limit them to processing data for the purposes we specify, prohibit them from retaining or using the data for their own purposes, and require appropriate security safeguards.

### 6.2 Other Users — What Is Visible on Capz

Capz is a group communication product, so much of what you do is visible to other people by design. **Please read this section before posting.** The following are visible to others:

- **Your public identity.** By default, other users see only your **username** and profile photo. Your real (display) name is hidden from other users unless you enable the "searchable by name" setting, which reveals your real name only to members of organizations you belong to.

- **Messages and images.** Anything you send in an organization group chat or channel is visible to every member of that group chat, including members who join later, and remains visible until it is deleted.

- **Poll votes are not anonymous.** When you vote in a poll, your identity is recorded and displayed. Other members of that group chat can see your avatar next to the option you selected and can open a **Results** view that lists, by name or username, everyone who voted for each option. Vote totals update live. **Do not vote in a poll if you do not want other members to know how you voted.**

- **Edits.** A message you edit is marked "(edited)" to other members; they see the current text, not your earlier version.

- **Admin moderation.** An admin of a group chat can delete any member's message or image and edit any member's poll — not only their own. These actions are taken by your organization's admins, not by Capz.

- **Read receipts.** Senders can see when their message has been read.

- **Typing indicators.** Other members of a group chat can see that you are typing, in real time, while you compose a message.

- **Events, RSVPs, and attendee lists.** Events you create are visible to the people invited to them. Your RSVP and your presence on an attendee list are visible to the event's organizers and, depending on the event, to other invitees.

- **Invite lists.** Being added to an invite list is visible to the organization's admins and to anyone permitted to manage that list.

- **Cross-organization invitations.** An admin may invite an entire other organization to an event. If you are a member of an invited organization, your public identity and RSVP become visible to that event's organizers and invitees, who may belong to a different organization from yours.

- **Organization membership and roles.** Your membership in an organization and your role within it are visible to other members of that organization.

- **Organization branding.** An organization's name and logo, uploaded by its admins, are visible to users across Capz — including in lists shown to people outside the organization, such as when another organization is choosing which organizations to invite to an event.

Verification documents, your email address, your phone number, your blocklist, and your notification and privacy settings are **never** visible to other users.

**Blocking.** You can block another user from their profile. Blocking hides that person's messages from the group chats *you* view. It is private and one-directional: the blocked person is not notified, their own view of the group chat is unchanged, and they can still see and reply to messages you send. Blocking is a personal visibility filter, not a restriction on the other person, and it is not a substitute for reporting conduct that violates our Terms of Service.

### 6.3 Content Others Save or Copy

Capz gives recipients **no way to save or share an image** you sent: images are view-only inside the app, with no download and no share action. But no app can prevent someone taking a screenshot or photographing their screen, and **we have no control over what a recipient does with content once they have received it.** Deleting content in Capz does not remove copies that others have already captured. Share only what you are comfortable having outside your control.

### 6.4 Legal and Regulatory Disclosure

We may disclose Personal Data when we believe in good faith it is required to comply with a subpoena, court order, warrant, regulatory directive, or other lawful request from a government authority. Where we are legally permitted to do so, we will make reasonable efforts to notify you before disclosing your data in response to such a request.

### 6.5 Safety and Security

We may disclose limited Personal Data where necessary to investigate or prevent fraud, illegal activity, security incidents, or threats to the safety of any person.

### 6.6 Business Transfers

If Capz HQ LLC is involved in a merger, acquisition, financing, reorganization, or sale of assets, Personal Data may be transferred as part of that transaction. We will notify you before your data becomes subject to a materially different privacy policy.

### 6.7 What We Do Not Do

We do not sell Personal Data for money, and we do not share Personal Data for cross-context behavioral advertising, as those terms are defined under California and other state privacy laws. We have not sold or shared Personal Data in the preceding twelve months, and we do not use Personal Data for targeted advertising or for profiling in furtherance of decisions that produce legal or similarly significant effects. We do not use your messages, images, or other User Content to train artificial intelligence or machine learning models, and we do not license User Content to third parties for that purpose.

---

## 7. YOUR RIGHTS

The following rights are available to **all** users of Capz, regardless of your state of residence. We extend them universally rather than limiting them to residents of states with comprehensive privacy laws.

**You may request to:**

- **Access** your Personal Data and learn how it is processed

- **Correct** inaccurate Personal Data

- **Delete** your Personal Data

- **Obtain a portable copy** of the data you provided to us, in a structured, commonly used, machine-readable format

- **Know** the categories of data collected, the sources, the business purposes, and the categories of third parties we disclose to

- **Opt out** of targeted advertising, sale of Personal Data, and profiling with legal or similarly significant effects (note: we do not engage in any of these activities)

- **Limit** our use of Sensitive Personal Data (note: we do not use it for inference)

- **Revoke** any device permission you previously granted

- **Not be discriminated against** for exercising any of these rights

### 7.1 How to Submit a Request

Email `support@capzhq.com` with the subject line "Privacy Request," or use the in-app privacy controls under Account → Settings.

**Account deletion is also available directly in Capz** under the Account screen → Delete Account.

### 7.2 What Deletion Does and Does Not Remove

When you delete your account, it immediately enters a **pending deletion** state: your profile stops being visible to other users, and where your name previously appeared you are shown as "Deleted User." After a limited recovery window of approximately **30 days**, your account and associated Personal Data are permanently removed from active systems, and from backups within 90 days.

Some information necessarily survives your deletion, and you should understand this before deleting:

- **Messages, images, and polls you sent to a group chat** may remain visible to the other members of that group chat, shown as sent by a deleted user. Content you sent to a shared space cannot be un-received.

- **Poll votes you cast** continue to count toward that poll's totals.

- **Copies other users saved or screenshotted** are outside our control (see Section 6.3).

- **Records we must keep** — such as security and audit logs, legal acceptance records, and information needed to resolve a dispute, prevent fraud, or comply with law — are retained for the periods described in Section 9.1.

If you want a specific message or image removed rather than your whole account, delete it in the app or contact us.

### 7.3 Verification

We will take reasonable steps to verify your identity before acting on a request, typically by confirming control of the email address or phone number associated with your account. For requests involving Sensitive Personal Data or large volumes of data, we may require additional verification. We use information provided for verification only for that purpose.

### 7.4 Authorized Agents

You may designate an authorized agent to submit a request on your behalf. We will require written proof of the agent's authorization and may independently verify your identity and confirm that you authorized the request.

### 7.5 Response Timeframes

We will confirm receipt within 10 business days and respond substantively within 45 calendar days. Where reasonably necessary, we may extend this by an additional 45 days and will notify you of the extension and the reason for it within the initial period.

Requests are free of charge. We may charge a reasonable fee or decline to act on requests that are manifestly unfounded, excessive, or repetitive, and will explain our reasoning if we do.

### 7.6 Appeals

If we decline your request, our response will explain why and how to appeal.

To appeal, reply to our decision or email `support@capzhq.com` with the subject line "Privacy Appeal." We will respond in writing within 45 days, explaining the reasons for our decision.

**If your appeal is denied, you may submit a complaint to your state Attorney General.** Contact information is available at the office of the Attorney General for your state of residence. This right applies in every state with a comprehensive privacy law, including California, Colorado, Connecticut, Virginia, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky, and Rhode Island.

---

## 8. OPT-OUT PREFERENCE SIGNALS

We honor the Global Privacy Control (GPC) and other recognized universal opt-out mechanisms transmitted by your browser or device. Because we do not sell Personal Data, share it for cross-context behavioral advertising, or use it for targeted advertising, receiving such a signal does not change how we process your data — but we recognize and respect it.

---

## 9. STATE-SPECIFIC PRIVACY DISCLOSURES

The rights described in Section 7 are available to all users. This section provides additional disclosures required by specific state laws.

### 9.1 California (CCPA/CPRA)

**Categories of Personal Data collected in the preceding twelve months**, using California statutory categories:

| Statutory Category | Collected | Sources | Business Purpose | Disclosed To |

|---|---|---|---|---|

| Identifiers (email, username, display name, optional phone, IP address, device identifier, push token) | Yes | You; your device | Account creation, authentication, communication, security | Hosting, email, and push-notification providers |

| Customer records (Cal. Civ. Code § 1798.80) | Yes | You | Account administration | Hosting provider |

| Commercial information (purchase records) | No | — | — | — |

| Internet/network activity (usage, diagnostics, message read status, poll votes, RSVP activity, notification history) | Yes | Your device; your use of Capz; mobile platform | Delivering Capz features, operations, debugging, security | Hosting provider; other users of the same group chat or event (see Section 6.2); mobile platform (crash reporting) |

| Geolocation | Coarse only (city/region inferred from IP; no GPS or precise location) | Derived from IP address | Security and fraud prevention | Hosting provider |

| Audio, electronic, visual information | Images only (profile, group chat, event, and organization photos you upload); no audio or video | You | Delivering Capz features | Hosting provider; other users you sent them to |

| Sensitive Personal Information | Photo ID (government identifier), full name, and school email — only if you create an organization; otherwise only if voluntarily included in content | You | Verifying organizations and preventing impersonation; operating the feature you used | Private storage (hosting provider) |

| Inferences | No | — | — | — |

**Retention.** We retain each category only as long as reasonably necessary for the purpose it was collected. Our current criteria:

- Account data — for the life of your account, then deleted within 30 days of account deletion

- User content (messages, images, polls, events, invite lists) — until you delete it or delete your account, then removed from active systems within 30 days and from backups within 90 days, subject to Section 7.2

- Poll votes — for the life of the poll's parent message

- Read status, notification history, muting preferences, and your blocklist — for the life of your account, or until you unblock the user

- Content reports and their evidence snapshots — 24 months, so repeat behaviour can be identified; the reporter's identity is unlinked if they delete their account

- Typing status — transient; broadcast in real time and not stored

- Invite codes — until revoked, exhausted, or the organization or invite list is deleted

- Organization audit logs — 24 months

- Security and access logs — 12 months

- Diagnostics and crash data — 90 days

- Support correspondence — 24 months

- Legal acceptance records — for the life of your account plus the applicable statute of limitations

- Organization verification documents — retained for up to one year, then deleted

Where legal obligations, active disputes, or security investigations require longer retention, we retain only what is necessary for that purpose.

**Sale and sharing.** We have not sold or shared Personal Data for cross-context behavioral advertising in the preceding twelve months, and we do not do so now. We do not have actual knowledge of selling or sharing the Personal Data of consumers under 16 years of age.

**Sensitive Personal Information.** The only Sensitive Personal Information we collect is the organization-verification documents described in Section 3.5, which we use solely to verify organizations and prevent impersonation — a purpose permitted under Cal. Code Regs. tit. 11, § 7027(m) — and retain for up to one year before deletion. Because we do not use or disclose Sensitive Personal Information beyond those permitted purposes, the right to limit does not apply, but you may still contact us about any sensitive information you have provided.

**Non-discrimination.** We will not deny service, charge different prices, provide a different quality of service, or retaliate against you for exercising any privacy right.

**Metrics.** Where required, our annual request metrics are available on request.

### 9.2 Colorado (CPA)

Colorado residents have the rights described in Section 7, including data portability and opt-out of targeted advertising, sale, and profiling. We do not conduct any processing that requires a data protection assessment under the CPA. Appeals are handled under Section 7.6; we will respond within 45 days, and if the appeal is denied you may contact the Colorado Attorney General.

### 9.3 Connecticut (CTDPA)

Connecticut residents have the rights described in Section 7. We do not process Personal Data for targeted advertising, sale, or profiling in furtherance of significant decisions. We do not knowingly process the Personal Data of a consumer we know to be between 13 and 16 years old for targeted advertising or sale.

### 9.4 Virginia (VCDPA)

Virginia residents have the rights described in Section 7. We do not sell Personal Data, use it for targeted advertising, or engage in profiling with legal or similarly significant effects, and therefore do not require consent for those activities.

### 9.5 Utah (UCPA)

Utah residents may access, delete, and obtain a copy of their Personal Data, and opt out of targeted advertising and sale. Utah law does not require an appeals process, but we extend the process in Section 7.6 to Utah residents.

### 9.6 Texas (TDPSA)

Texas residents have the rights described in Section 7. As required by the TDPSA: **We do not sell Personal Data. We do not sell Sensitive Personal Data. We do not sell biometric Personal Data.** Appeals are handled under Section 7.6, and if denied you may complain to the Texas Attorney General at texasattorneygeneral.gov.

### 9.7 Oregon (OCPA)

Oregon residents have the rights described in Section 7 and may additionally request a **list of the specific third parties** to which we have disclosed their Personal Data. Submit that request using the contact details in Section 7.1.

### 9.8 Montana (MCDPA)

Montana residents have the rights described in Section 7, including opt-out of targeted advertising, sale, and profiling. We honor universal opt-out mechanisms as described in Section 8.

### 9.9 Delaware (DPDPA)

Delaware residents have the rights described in Section 7 and may additionally request a list of the categories of third parties to which we have disclosed Personal Data.

### 9.10 New Jersey (NJDPA)

New Jersey residents have the rights described in Section 7. We do not process the Personal Data of consumers we know to be between 13 and 17 years old for targeted advertising, sale, or profiling.

### 9.11 New Hampshire (NHDPA)

New Hampshire residents have the rights described in Section 7 and may exercise them through the contacts in Section 7.1.

### 9.12 Nebraska (NDPA)

Nebraska residents have the rights described in Section 7. As required: **We do not sell Personal Data or Sensitive Personal Data.**

### 9.13 Iowa (ICDPA)

Iowa residents may access, delete, and obtain a copy of their Personal Data, and opt out of the sale of Personal Data.

### 9.14 Minnesota (MCDPA)

Minnesota residents have the rights described in Section 7 and may additionally:

- Obtain a **list of the specific third parties** to which we have disclosed Personal Data

- Question the result of any profiling that produces a legal or similarly significant effect, be informed of the reason for that result, and be told what actions they could take to secure a different outcome

We do not currently engage in profiling that produces legal or similarly significant effects.

### 9.15 Tennessee (TIPA)

Tennessee residents have the rights described in Section 7. Capz HQ LLC maintains a written privacy program reasonably conforming to the NIST Privacy Framework.

### 9.16 Maryland (MODPA)

Maryland residents have the rights described in Section 7. Maryland law imposes heightened obligations that we apply to all Maryland residents:

- We collect only Personal Data that is **reasonably necessary and proportionate** to provide or maintain Capz

- We do **not sell Sensitive Personal Data under any circumstances**

- We do **not sell the Personal Data of, or process it for targeted advertising for, any consumer we know or should know is under 18**

- We do not process Sensitive Personal Data except where strictly necessary to provide a service the consumer requested

### 9.17 Indiana (INCDPA)

Indiana residents have the rights described in Section 7 and may request either a copy of their Personal Data or a representative summary.

### 9.18 Kentucky (KCDPA)

Kentucky residents have the rights described in Section 7, including opt-out of targeted advertising, sale, and profiling.

### 9.19 Rhode Island (RIDTPPA)

Rhode Island residents have the rights described in Section 7. The categories of Personal Data we collect and the categories of third parties to which we disclose it are identified in Sections 3 and 6.

### 9.20 Florida (FDBR)

The Florida Digital Bill of Rights applies to entities meeting statutory revenue thresholds that Capz HQ LLC does not currently meet. Florida residents nonetheless have the rights described in Section 7.

### 9.21 Nevada

Nevada residents may direct us not to sell their covered information. We do not sell covered information as defined under Nev. Rev. Stat. Ch. 603A.

### 9.22 Other States

If you reside in a state not listed above, the rights in Section 7 are available to you.

---

## 10. DATA SECURITY

We maintain administrative, technical, and physical safeguards designed to protect Personal Data, including:

- TLS encryption for data in transit and encryption at rest for stored data

- Row-level access controls and the principle of least privilege, so each user can only reach the data they are authorized to see

- Private storage for message images and verification documents, served through short-lived, expiring access links rather than permanently public URLs

- Logging and monitoring of access to production systems

- Regular review of vendor security practices

- Incident response procedures

Capz does **not** use end-to-end encryption. Messages and images are encrypted in transit and at rest, but are readable on our servers so that the Service can function.

No system is completely secure, and we cannot guarantee absolute security. We authenticate accounts using one-time passcodes sent to your email address rather than stored passwords. You are responsible for maintaining control of the email account (and any phone number) associated with your account, for keeping one-time passcodes confidential, for safeguarding invite codes you generate or receive, and for notifying us promptly if you believe your account has been compromised.

---

## 11. DATA BREACH NOTIFICATION

If we determine that a security incident has compromised your Personal Data, we will notify you and applicable regulators as required by Pennsylvania's Breach of Personal Information Notification Act and the breach notification laws of your state of residence. Notification will be made without unreasonable delay and will describe, to the extent known, what happened, what data was involved, and what steps you can take.

---

## 12. AGE REQUIREMENTS AND MINORS

Capz is intended for individuals **18 years of age or older**. Before we send a sign-in code, you must affirm that you are at least 18 years old.

**Creating an organization requires you to be 18 years of age or older.** Because organization creation involves uploading identity and organization documents, you must affirm that you are at least 18 before you can submit those documents. We do not knowingly collect identity documents from anyone under 18.

We do not collect date of birth; eligibility is based on that affirmation at sign-in and on the age rating of the app store from which you downloaded Capz. We do not knowingly collect Personal Data from anyone under 18. If we learn that we have collected Personal Data from someone under 18, we will delete the account and associated data promptly, typically within 30 days, and will not use that data for any purpose in the interim.

If you believe a minor has provided us Personal Data, contact us at `support@capzhq.com` and we will investigate.

Consistent with Section 6.7, we do not sell Personal Data, use it for targeted advertising, or profile users — practices that several state laws specifically restrict for consumers under 18.

---

## 13. AUTOMATED DECISION-MAKING

We do not use automated decision-making that produces legal or similarly significant effects about you. Organization verification decisions are made by authorized Capz personnel reviewing the documents submitted, not by an automated system.

---

## 14. USERS OUTSIDE THE UNITED STATES

Capz is directed to residents of the United States and is not offered to individuals in the European Economic Area, the United Kingdom, or Switzerland. We do not target, market to, or knowingly provide Capz to individuals in those jurisdictions.

Personal Data is stored and processed in the United States. If you access Capz from outside the United States, you do so on your own initiative and are responsible for compliance with local law.

---

## 15. CHANGES TO THIS POLICY

We may update this Policy from time to time. When we do, we will revise the "Last Updated" date at the top.

**For material changes** — including any change that expands how we use or disclose Personal Data, or that introduces sale, sharing, targeted advertising, or profiling — we will provide notice at least 30 days in advance through Capz, by email, or both, and where required by law we will obtain your consent before applying the change to Personal Data already collected.

Prior versions of this Policy are available on request.

---

## 16. GOVERNING LAW

Except where a state privacy law provides otherwise, this Policy is governed by the laws of the Commonwealth of Pennsylvania. **This provision does not limit, waive, or override any right, remedy, or procedure available to you under the privacy or consumer protection law of your state of residence.** Where those laws apply, they control regardless of this section.

Contractual dispute resolution terms, disclaimers, and limitations of liability are set out in our Terms of Service and EULA.

---

## 17. CONTACT US

**Privacy inquiries and rights requests:**

support@capzhq.com

**Mailing address:**

Capz HQ LLC

226 E Beaver Ave, Room 24

State College, Pennsylvania 16801

United States

We aim to respond to all privacy inquiries within 10 business days.