Template — review by legal counsel before launch; bracketed fields must be completed.

Privacy Policy

Last updated: [DATE]

This Privacy Policy explains how capsend collects, uses, and protects personal data when you use our website, sign up for a workspace, or view content shared through a capsend link. We are built for the EU market: your data is hosted on EU infrastructure, and shared links carry no third-party trackers.

1. Controller

The data controller for personal data processed via the Service is [COMPANY LEGAL NAME], [ADDRESS] ("we", "us"). This applies to account, billing, and website data. For data collected from viewers of a shared link, we act as a processor on behalf of the workspace owner who created that link — see Section 3 and our Data Processing Agreement. You can reach our data protection contact at [DATA PROTECTION CONTACT EMAIL].

2. Data We Collect

We process the following categories of personal data:

• Account data: name, email, sign-in provider details (Google account ID or magic-link email), and workspace membership for the people who sign up and manage workspaces.
• Workspace content: the decks, files, and data rooms you upload, and metadata about the links you create (expiry, branding, access settings).
• Viewer analytics:when someone opens a shared link, we record page/slide views, time spent, and coarse location derived from IP address, on a first-party basis (see Section 5 for the cookies involved). If the link owner enables the email gate, we also collect the visitor's email address before granting access — this address is shown to the link owner and, where watermarking or NDA acceptance is enabled, is stamped into the served document and recorded in an acceptance log.
• Billing data: plan, billing address, and transaction history. Card details are collected and stored directly by Stripe; we never see or store full card numbers.
• Support data: correspondence you send to [SUPPORT EMAIL].

3. Legal Bases & Purposes

We process account and billing data to perform our contract with you (Art. 6(1)(b) GDPR) — operating your workspace and charging your chosen plan. We process viewer analytics and email-gate data on behalf of the workspace owner as their processor, under their instructions and legal basis for engaging with their recipients; where we determine the purpose of processing (e.g. abuse prevention, service security), we rely on our legitimate interest (Art. 6(1)(f) GDPR). Where required, such as certain marketing communications, we rely on your consent (Art. 6(1)(a) GDPR), which you may withdraw at any time.

4. Processors & Subprocessors

We share personal data with the following processors, strictly to operate the Service:

A current list of subprocessors is also available in our Data Processing Agreement. We do not sell personal data, and we do not use viewer or Customer Content data to train machine-learning models.

5. Cookies & Tracking

Our marketing pages, dashboard, and shared links use only first-party, functional cookies — no third-party or advertising cookies, and no cookie banner is shown. Shared links (decks, files, data rooms) load no third-party scripts. For a viewer opening a shared link, we set two first-party cookies: a short-lived session cookie used to enforce link gates (email gate, NDA acceptance) and access controls, and a visitor_id identifier used to count and deduplicate unique visitors in the analytics shown to the link owner. Neither cookie is used for advertising, and we do not share them with third parties.

[Counsel: review visitor_id cookie lifetime vs consent requirements]

6. Data Retention

We retain account and workspace content for as long as the workspace is active, and for [RETENTION PERIOD] after deletion to allow recovery and to meet legal, tax, and accounting obligations. Viewer analytics and access logs are retained for [ANALYTICS RETENTION PERIOD] and then aggregated or deleted. Billing records are retained as required by applicable tax law.

7. International Transfers

Our primary infrastructure — database and file storage — is hosted in the EU. A small number of processors (see the table above) operate globally and may process data outside the EEA; where they do, we rely on Standard Contractual Clauses or an equivalent adequacy mechanism.

8. Your Rights

Subject to applicable law, you have the right to access, correct, delete, or export your personal data, to restrict or object to certain processing, and to lodge a complaint with your local supervisory authority — in [COUNTRY], this is [SUPERVISORY AUTHORITY]. To exercise these rights, contact [DATA PROTECTION CONTACT EMAIL]. If we process your data as a processor on behalf of a workspace owner (for example, as a viewer who supplied an email at a gate), we will direct your request to that workspace owner unless we are required to respond directly.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be announced on this page or by email to workspace owners. Continued use of the Service after a change takes effect constitutes acceptance of the updated policy.