1. Who we are
Capo Marketing Ltd ("Capo", "we", "us", "our") is the controller of the personal data described in this policy. We are a company registered in England and Wales.
- Company number — [company registration number]
- Registered office — [registered office address]
- ICO data protection registration — [ICO registration number]
- Contact for privacy matters — privacy@capo.marketing
- Data protection lead — [name / role, or remove if not appointed]
If you are in the UK or EU and have concerns we cannot resolve, you can also contact your local supervisory authority (in the UK, the Information Commissioner's Office at ico.org.uk).
2. Controller vs processor — an important distinction
Capo handles personal data in two different roles, and it matters which one applies.
Where we are the controller — We decide how and why the following data is used, so this policy governs it:
- Account holders and their colleagues
- Prospects and website visitors
- People who contact us
- Billing contacts
Where we are the processor — When you connect a CRM, upload business context, or otherwise load personal data about your leads, contacts and customers into Capo, you remain the controller of that data and we process it only on your instructions to provide the service. Our handling of it is governed by the Terms and the Data Processing Agreement, not by this policy. You are responsible for having a lawful basis to load that data and to run marketing to those people.
3. The personal data we collect
Data you give us
- Account data — name, work email, password credentials (handled by our authentication provider), organisation name, role.
- Billing data — billing name, address, plan, and transaction records. Card details are handled directly by our payment provider; we do not store full card numbers.
- Business context you enter — your domain, product, positioning, ICP and other inputs you choose to share so Capo can generate strategy and content.
- Communications — messages you send us by email, support chat, or when booking a call.
Data we collect automatically
- Usage and device data — pages viewed, features used, actions taken, IP address, browser and device type, and diagnostic logs.
- Cookies and similar technologies — see our Cookie Policy.
Data from third parties
- When you connect an account (for example a CRM, LinkedIn, Google, or Webflow), we receive data from that service as needed to run the platform, subject to the permissions you grant.
- We may receive limited information from our authentication, analytics and payment providers.
4. Why we use your data, and our lawful bases
Where we rely on legitimate interests, we have weighed those interests against your rights. You can ask us about that assessment at any time.
5. AI and automated processing
Capo uses artificial intelligence to turn your inputs into marketing strategy, copy and campaign structures. This means content you enter is processed by AI models, including models provided by our AI sub-processor.
Capo does not make decisions producing legal or similarly significant effects about you through solely automated means. Generated output is presented for your review and requires a human action to publish or spend budget.
[confirm sub-processor data/training terms]
6. Sharing your data
We do not sell your personal data. We share it only with:
- Service providers (sub-processors) who help us run Capo, under contract and only for that purpose. Our current sub-processors include, by category: [cloud hosting], [authentication provider], [AI model provider], [web-scraping/enrichment provider], [analytics provider], [payment provider], [email/support provider]. Maintain a current list you can point customers to.
- Connected platforms you authorise (for example your CRM, LinkedIn, Google, Webflow), to deliver the features you use.
- Professional advisers, buyers or investors in connection with a sale, financing or reorganisation of our business.
- Authorities where we are legally required to disclose, or to protect our rights or the safety of others.
7. International transfers
Some of our providers are located outside the UK. Where personal data is transferred internationally, we rely on an adequacy decision where one applies, or on appropriate safeguards such as the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, together with any additional measures needed. You can ask us for details of the safeguards used.
8. How long we keep it
We keep personal data only as long as we need it for the purposes above. In practice that means for the life of your account and then for a reasonable period afterwards to meet legal, accounting, tax and dispute-handling duties.
Typical retention after account closure: [e.g. 6 years for financial records].
When data is no longer needed, we delete or anonymise it.
9. How we protect your data
We use technical and organisational measures appropriate to the risk, including encryption in transit, access controls, least-privilege permissions, and logging. No system is perfectly secure, but we work to protect your data and will notify you and the relevant authority of a personal data breach where the law requires.
10. Your rights
Subject to conditions in the law, you have the right to:
- Access your data
- Have it corrected
- Have it erased
- Restrict or object to processing
- Data portability
- Withdraw consent at any time where we rely on it
- Complain to a supervisory authority
To exercise any of these, email privacy@capo.marketing. We will respond within the timescales set by law (usually one month). If your request concerns data Capo processes on behalf of a customer, we will direct you to that customer, who is the controller.
11. Cookies
We use cookies and similar technologies. Strictly necessary cookies keep you logged in and the platform secure; other cookies run only with your consent. Full details, and how to change your choices, are in our Cookie Policy.
12. Children
Capo is a business tool and is not directed at children. We do not knowingly collect personal data from anyone under 18. If you believe a child has provided us data, contact us and we will delete it.
13. Changes to this policy
We may update this policy from time to time. When we make material changes we will update the date above and, where appropriate, tell you by email or in the platform. Please check back periodically.
14. Contact us
Questions about this policy or your data? Email privacy@capo.marketing or write to us at our registered office above.
