Privacy Policy

In plain English

We're Capango. We help job seekers find hourly work and help small employers hire. To do that, we collect some information from you — things like your name, email, phone number, the jobs you're interested in, and how you use our app and website. We use that information to run the service. We don't sell your personal data. You can see, correct, export, or delete your data anytime by contacting us.

This Privacy Policy explains the details. We've tried to keep it short and readable. If a section has technical or legal language, there's a plain-English summary at the top.

Contents

1. Who we are
2. Information we collect
3. How we use your information
4. How we share information (and our service providers)
5. Text Message (SMS) Communications
6. Cookies and tracking technologies
7. How long we keep information
8. Your privacy rights
9. California residents — your CCPA/CPRA rights
10. Canadian residents — PIPEDA and Quebec Law 25
11. EU, UK, and EEA residents — GDPR rights
12. Residents of other U.S. states with comprehensive privacy laws
13. Automated decision-making
14. Children's privacy
15. International data transfers
16. Security and incident notification
17. Changes to this Policy
18. How to contact us

1. Who we are

Capango, Inc. is a Delaware corporation with offices at 44679 Endicott Drive, Suite 300, #527, Ashburn, VA 20147 ("Capango," "we," "us," "our").

Capango operates an online recruiting platform accessible through our website and mobile applications (the "Services"). The Services have two main user groups: job seekers (individuals using Capango to find hourly work) and employers (small businesses using Capango to fill open roles, plus the recruiters and hiring managers acting on their behalf).

For the purpose of applicable data-protection laws, Capango is the data controller of personal information collected directly from you through the Services. Where we process personal information on behalf of an employer (for example, applications submitted to that employer's job postings), the employer is the controller of that information and Capango acts as a data processor on the employer's behalf.

2. Information we collect

In plain English: We collect (a) what you give us when you sign up and use Capango, (b) information your device automatically reports when you visit the Services, and (c) limited information from your employer if you use Capango through them.

2.1 Information you give us

• Account information. Name, email address, phone number, password, and (for employers) company name and billing details.
• Profile information. For job seekers: your work history, skills, "Powers and Passions" tags, location preferences, availability, languages, and any photo or short video you choose to add. For employer users: your role at the employer, the locations you manage, and any settings you configure.
• Communications. Messages you send to Capango support and (for in-app messaging) messages exchanged between job seekers and employers within Capango.
• Payment information. For paying employers, billing contact, plan tier, and payment method. Card details are tokenized and handled by our payment processor — we don't store full card numbers on Capango systems.

We ask that you do not send us, and you do not disclose to us, sensitive personal data we do not need — such as Social Security numbers, information about racial or ethnic origin, political opinions, religion, health, biometrics or genetics, criminal background, or trade-union membership.

2.2 Information collected automatically

When you use the Services, we automatically receive:

• Device and connection data. Operating system, browser type, IP address, device identifiers, app version, language, time zone, and crash logs.
• Usage data. Pages you visit, features you use, the dates and times of your sessions, and how you navigate within the Services.
• Approximate location. Derived from your IP address and used to default your search to nearby jobs.
• Precise location (mobile app only) if you enable it. Used to show you jobs near where you actually are. You control this in your phone's settings.

2.3 Information from third parties

If your employer is a paying Capango customer and assigns you a Capango login, the employer may give us your name and work email so we can set up the account.

We don't buy personal information from data brokers and we don't enrich your profile with data from third-party sources.

3. How we use your information

In plain English: We use your information to run the Services — match seekers to jobs, let employers contact you, charge employers, prevent abuse, and improve what we offer. We only contact you for marketing if you've told us we can.

We process your personal information for the following purposes, with the corresponding legal bases shown for EU/EEA/UK users (see Section 11):

4. How we share information (and our service providers)

In plain English: We share what you've made available with employers (or seekers) so the platform can do its job, with our service providers (the companies that help us run Capango), and where the law requires. We do not sell your personal data.

4.1 With other Capango users

• Job seekers' profile information that you have published is visible to employers using Capango.
• Employer postings and the employer's name are visible to job seekers.
• Messages you send in Capango's in-app messaging are visible to the recipient and to authorized account administrators on the recipient's side.

4.2 With our service providers (sub-processors)

We use trusted vendors to operate parts of the Services. We share only the information they need to do their job, and they're contractually required to protect it. The current list of sub-processors is:

We update this list when it materially changes. The current version is always available at this page.

4.3 For legal reasons or to protect rights

We may share personal information when we believe in good faith that we are legally required to do so, or when sharing is necessary to:

• Comply with a subpoena, court order, or other legal process;
• Cooperate with law enforcement or a regulator;
• Enforce our Terms of Use;
• Protect the rights, property, or safety of Capango, our users, or others.

4.4 In a business transaction

If we are involved in a merger, acquisition, financing, or sale of all or part of our business, personal information may be transferred to the other party as part of that transaction. We will notify you and post a notice before your information becomes subject to a different privacy policy.

4.5 With your consent

We share information for any other purpose disclosed to you at the time and to which you consent.

4.6 What we do not do

We do not sell your personal information. We do not share your mobile phone number with third parties for those third parties' marketing. We do not rent, lease, or trade contact lists.

5. Text Message (SMS) Communications

In plain English: If you've opted in, we send job seekers a text when an employer expresses interest in their profile. You can reply STOP anytime to stop. We don't share your number with anyone for marketing.

If you provide Capango with your mobile phone number and consent to receive text messages from us, we will use that number to send you SMS messages related to your use of the Services.

What messages you may receive. Capango uses SMS for one transactional purpose at this time: to notify a job seeker when an Employer using Capango has expressed interest in their profile. A typical message reads:

"Hi [Your First Name], [Company Name] is interested in your Capango profile. View the role: [link] Reply STOP to opt out, HELP for help."

How consent works. You will only receive SMS messages from Capango if you have affirmatively opted in by checking the SMS-consent box during account registration, by enabling SMS notifications in your in-app Settings, or by otherwise providing express consent. Consent to receive SMS is not a condition of using Capango.

Frequency. Message frequency varies and is driven by employer interest in your profile. Most users receive zero to five messages per week. Capango does not send marketing, promotional, drip, or scheduled bulk SMS at this time.

Carrier charges. Standard message and data rates may apply per your mobile carrier plan. Capango does not charge for these messages.

How to opt out. You may stop receiving SMS messages from Capango at any time by: 1. Replying STOP to any Capango SMS message; 2. Toggling SMS notifications off in your in-app Settings; or 3. Contacting Capango support at support@capango.com.

Opt-out is processed immediately. After opting out, you will receive one confirmation message and no further SMS from Capango.

How to get help. Reply HELP to any Capango SMS for an automated response with support information, or email support@capango.com.

Sharing of mobile numbers. Capango does not sell mobile phone numbers and does not share them with third parties for those third parties' marketing. We share mobile numbers only with: (i) Twilio Inc., our SMS service provider, for the limited purpose of delivering messages you have consented to receive; (ii) mobile carriers, as required for message delivery; and (iii) other service providers, regulators, or legal authorities as described elsewhere in this Privacy Policy.

Carrier disclaimer. Mobile carriers, including without limitation T-Mobile, AT&T, Verizon, US Cellular, and others, are not liable for delayed or undelivered messages.

Geographic scope. Capango's SMS program is currently available only to mobile numbers issued by United States mobile carriers. Users outside the United States will not receive SMS messages from Capango regardless of opt-in status.

Changes. If we materially change the categories of SMS messages we send (for example, by adding marketing messages or two-way recruiter conversations), we will obtain renewed consent before sending those new messages.

6. Cookies and tracking technologies

In plain English: Cookies are small files that help websites remember things like your login. We use a few, mostly to keep the site working. You can manage non-essential cookies through our cookie banner.

You can accept, reject, or manage non-essential cookies through our cookie banner. You can also opt out of Google Analytics via the Google Analytics opt-out browser plugin.

We honor the Global Privacy Control (GPC) browser signal as an opt-out of any sharing of personal information for cross-context behavioral advertising.

In our mobile apps, we do not use third-party advertising SDKs at launch. If we add any in the future, we will disclose them here and obtain any required consent.

7. How long we keep information

In plain English: We keep your data only as long as we need it, then we delete or anonymize it. The table below shows our standard retention periods by data type.

When we no longer need information, we delete or anonymize it. If deletion is technically infeasible (for example, data on encrypted backups), we securely isolate it from further use until deletion is possible.

8. Your privacy rights

In plain English: You can ask us what we have, fix mistakes, get a copy of your data, delete your account, opt out of marketing, and object to certain uses. We respond within the times required by law.

Subject to your local law, you have the following rights:

• Access. Get a copy of the personal information we hold about you.
• Correct. Ask us to fix inaccurate information.
• Delete. Ask us to erase your data, subject to limited exceptions (legal obligations, security, fraud prevention).
• Portability / Export. Get a structured, machine-readable copy of the data you provided to us.
• Restrict or object. Ask us to limit certain processing or object to processing based on legitimate interests.
• Withdraw consent. Where we rely on your consent, you can withdraw it at any time.
• Opt out of marketing. Click the unsubscribe link in any marketing email, toggle marketing settings in your profile, or email us.
• Lodge a complaint. Contact your local data-protection authority (see Sections 9–12).

How to use these rights: email privacy@capango.com, write to us at the address in Section 18, or use the in-app tools where available. We may need to verify your identity (typically by confirming you control the email on file) before we act.

Response times: within 30 days for most U.S. states; within 1 month for EU/UK requests (extendable by 2 months for complex cases); within 30 days for Quebec and PIPEDA requests; California within 45 days (extendable by 45).

Authorized agents. California, Colorado, Connecticut, and several other states permit you to use an authorized agent. We will require written authorization from you and may verify your identity directly.

Non-discrimination. We will not deny service, charge different prices, or provide a different quality of service because you exercised a privacy right.

9. California residents — your CCPA/CPRA rights

In plain English: California residents have extra rights under the CCPA/CPRA. Most importantly: you can opt out of "sharing" for cross-context advertising (we currently don't share for that purpose at launch — and we honor the GPC browser signal regardless).

9.1 Categories of personal information we collect (last 12 months)

Mapped to the CCPA's enumerated categories:

We do not collect biometric information, Social Security numbers, racial/ethnic origin, religious or philosophical beliefs, union membership, or health/genetic data.

9.2 California rights

• Right to know what personal information we collect, use, disclose, and (if applicable) sell or share.
• Right to delete personal information we hold about you, subject to standard CCPA exceptions.
• Right to correct inaccurate personal information.
• Right to opt out of sale or sharing. Capango does not sell personal information and does not share for cross-context behavioral advertising at this time. If that changes, we will provide a "Do Not Sell or Share My Personal Information" link in our website footer and a clear opt-out flow.
• Right to limit the use of sensitive personal information. Currently the only sensitive PI we collect is precise geolocation, used only to show you nearby jobs in the mobile app. You can turn this off in your phone's settings.
• Right to non-discrimination for exercising any of these rights.

To exercise California rights, contact privacy@capango.com or call (833) 227-2646. We verify by confirming the email on file plus account-specific information.

9.3 Shine the Light

California Civil Code §1798.83 ("Shine the Light") permits California residents to request information regarding disclosure of personal information to third parties for those third parties' direct-marketing purposes. We do not engage in such sharing.

10. Canadian residents — PIPEDA and Quebec Law 25

In plain English: Canadian residents have rights under PIPEDA, and Quebec residents have additional rights under Law 25. You can also reach a named Privacy Officer.

10.1 PIPEDA

We follow the ten fair-information principles set out in PIPEDA: accountability, identifying purposes, consent, limiting collection, limiting use and disclosure, accuracy, safeguards, openness, individual access, and challenging compliance.

10.2 Quebec Law 25

• Privacy Officer (Person in Charge). VP of Operations, reachable at privacy@capango.com or +1 (833) 227-2646.
• Cross-border transfers. Personal information of Quebec residents is transferred to and stored in the United States. Before any such transfer, we conduct an assessment of the privacy implications and apply appropriate safeguards.
• Privacy impact assessments. We conduct privacy impact assessments for new projects involving personal information, as required by Law 25.
• French-language access. This Privacy Policy will be made available in French to Quebec residents on request. Contact privacy@capango.com.

10.3 Complaints

You may file a complaint with the Office of the Privacy Commissioner of Canada at priv.gc.ca or, for Quebec, with the Commission d'accès à l'information at cai.gouv.qc.ca.

11. EU, UK, and EEA residents — GDPR rights

In plain English: If you're in the EU, UK, or EEA, the GDPR (or UK GDPR) gives you a defined set of rights. Capango is the controller. See Section 8 for how to exercise these rights.

11.1 Controller

Capango, Inc., 44679 Endicott Drive, Suite 300, #527, Ashburn, VA 20147, U.S.A.

11.2 EU and UK representative

Capango has not designated an Article 27 (or UK GDPR equivalent) representative, as our EU/UK processing at launch does not meet the threshold requiring one.

11.3 Legal bases

We process EU/UK personal data on the legal bases identified in the table in Section 3 (contract performance, legitimate interests, legal obligation, and consent). Where we rely on legitimate interests, our interests are those of operating, securing, and improving the Services and of communicating with our users.

11.4 Your rights under GDPR

• Right of access (Art. 15)
• Right to rectification (Art. 16)
• Right to erasure / "right to be forgotten" (Art. 17)
• Right to restriction of processing (Art. 18)
• Right to data portability (Art. 20)
• Right to object to processing based on legitimate interests, including profiling (Art. 21)
• Rights related to automated decision-making (Art. 22) — see Section 13
• Right to withdraw consent at any time, where we rely on consent
• Right to lodge a complaint with your local supervisory authority

11.5 International transfers

EU/UK personal data is transferred to the United States under the European Commission's Standard Contractual Clauses (and the UK International Data Transfer Addendum, where applicable). On request, we will provide a copy of the relevant safeguards.

11.6 Data Protection Officer

Capango is not required to appoint a Data Protection Officer under GDPR Article 37. Our senior privacy contact is the VP of Operations, reachable at privacy@capango.com.

12. Residents of other U.S. states with comprehensive privacy laws

In plain English: Several U.S. states beyond California have passed privacy laws giving residents similar rights. We extend the same core rights — access, correct, delete, opt-out of sale/sharing/targeted advertising — to residents of those states.

If you are a resident of Virginia, Colorado, Connecticut, Utah, Iowa, Indiana, Tennessee, Texas, Oregon, Montana, Florida, Delaware, New Hampshire, Nebraska, New Jersey, Minnesota, Maryland, or any other state with a comprehensive consumer privacy law that applies to Capango, you have rights substantially similar to those in Section 8. Specifically:

• The right to confirm whether we process your personal data and to access it;
• The right to correct inaccuracies;
• The right to delete;
• The right to a portable copy;
• The right to opt out of (i) sale of personal data, (ii) targeted advertising, and (iii) profiling in furtherance of decisions that produce legal or similarly significant effects;
• The right to appeal a denied request.

To exercise these rights, contact privacy@capango.com. We honor universal opt-out signals (such as the Global Privacy Control) as an opt-out of sale, sharing, and targeted advertising. We will respond within the timeframe required by your state's law (typically 45 days, with one 45-day extension for complex requests). If we deny a request, we will provide a written explanation and instructions for appeal.

13. Automated decision-making

In plain English: Capango computes a match score that helps surface candidates to employers. It's a suggestion to a human, not an automatic decision. You can ask us for a manual review.

Capango computes a job-match score for each Seeker–Job pair based on factors you provide (skills, "Powers and Passions" tags, availability, location, experience). This score helps employers prioritize candidates but does not make hiring decisions. Hiring decisions are made by human recruiters and hiring managers acting for the employer.

Under GDPR Article 22 and similar provisions in Quebec Law 25 and California's CPRA, you have the right to:

• Be informed that automated processing is in use (this section);
• Receive meaningful information about the logic involved (factors listed above);
• Understand the significance and envisaged consequences (a suggestion ranked for an employer);
• Request a manual review or human intervention;
• Submit observations or context the score may not capture;
• Contest a decision and request its reconsideration.

To exercise these rights, contact privacy@capango.com.

If you are a New York City resident and the employer using Capango is subject to NYC Local Law 144 (Automated Employment Decision Tools), the employer is responsible for any required bias audit and pre-use notice.

14. Children's privacy

In plain English: Capango is not for kids. You must be at least 16 to use the Services.

The Services are intended for users age 16 and older. We do not knowingly collect personal information from anyone under 16. If you believe a child under 16 has provided us with personal information, please contact us at privacy@capango.com and we will delete the information promptly.

Some jurisdictions permit lawful employment of 14- and 15-year-olds in limited categories of work. If Capango decides to support those users in the future, we will obtain verifiable parental consent before collecting personal information and update this Policy.

15. International data transfers

We are based in the United States, and personal information we collect is stored and processed in the United States, where data-protection laws may differ from those in your country.

• EU/UK transfers: see Section 11.5.
• Canada transfers (including Quebec Law 25): see Section 10.2.
• All other transfers: we use appropriate contractual safeguards with our sub-processors and maintain reasonable security measures regardless of where the data is stored.

16. Security and incident notification

In plain English: We protect your information with reasonable safeguards. If there's a breach affecting you, we'll let you know and notify regulators where required.

We use technical, administrative, and physical safeguards designed to protect personal information against unauthorized access, alteration, disclosure, or destruction. These include access controls, encryption in transit and at rest for sensitive fields, audit logging, regular vulnerability scanning, and incident-response procedures. No system is impenetrable; we cannot guarantee absolute security.

Incident notification. If a security incident materially affects the confidentiality, integrity, or availability of your personal information, we will notify you and the relevant supervisory authorities as required by applicable law — for example: GDPR Article 33 (regulators within 72 hours; high-risk to individuals "without undue delay"); PIPEDA (Office of the Privacy Commissioner of Canada where there is "real risk of significant harm"); Quebec Law 25 (Commission d'accès à l'information without delay where risk of serious injury); U.S. state breach-notification laws (typically 30–60 days, varies by state).

17. Changes to this Policy

We may update this Privacy Policy from time to time. The current version is always available at https://www.capango.com/privacy.html with the "Last updated" date at the top.

If we make material changes — such as expanding the categories of information we collect, adding a new purpose of use, changing how we share information, or adding a new SMS message category — we will give you reasonable advance notice (for example, by email or in-app notice) before the change takes effect. Where required by law, we will obtain renewed consent.

18. How to contact us

For any privacy-related question, request, or complaint:

Capango, Inc. 44679 Endicott Drive, Suite 300, #527 Ashburn, VA 20147 USA

Email: privacy@capango.com Phone: (833) 227-2646 Privacy Officer (Quebec Law 25): VP of Operations

If you are not satisfied with our response, you may contact your local data-protection authority.