Privacy Policy.

This Privacy Policy explains how CaptVr, INC. collects, uses, stores, and shares your personal information, and describes your privacy rights. By using our Services, you agree to the practices described herein.

1. INTRODUCTION AND SCOPE

CaptVr, INC. ("CaptVr," "we," "us," or "our") is a Tennessee-based company operating platforms, portals, and subscription services for the entertainment industry. This Privacy Policy applies to all users of CaptVr's website(s), platforms, portals, and services (collectively, the "Services"), including Creator OS, First Position, Advisory Services, and all CaptVr gated access portals.

This Policy is designed to comply with applicable privacy laws including: the Tennessee Information Protection Act (TIPA); the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (CCPA/CPRA); the General Data Protection Regulation (EU) 2016/679 (GDPR) and UK GDPR, to the extent applicable; the Children's Online Privacy Protection Act (COPPA); and other applicable federal and state privacy laws.

By accessing or using the Services, you acknowledge that you have read, understood, and consent to the data practices described in this Privacy Policy.

2. INFORMATION WE COLLECT

2.1 Information You Provide Directly

We collect personal information you provide when you:

• Register for an account or subscription;
• Submit a portal access request form;
• Complete a consent agreement via Zoho Sign;
• Communicate with CaptVr by email, phone, or messaging;
• Inquire about or engage Advisory Services;
• Respond to surveys or questionnaires.

This includes: full name; email address; phone number; mailing address; professional title and company affiliation; financial information sufficient for accredited investor qualification (self-attested); payment information (processed by third-party payment processors—we do not store full payment card numbers); subscription and purchase history; and any content, communications, or materials you voluntarily submit.

2.2 Information Collected Automatically

When you use the Services, we and our service providers may automatically collect:

• Device information: device type, operating system, browser type and version, unique device identifiers
• Log data: IP address, access times, pages viewed, links clicked, referring URLs
• Usage data: features used, content accessed, session duration, navigation patterns
• Location data: general geographic location derived from IP address (not precise geolocation)
• Cookie and tracking data: as described in Section 7

2.3 Information from Third Parties

We may receive information about you from third-party sources, including: payment processors (transaction status and fraud signals, not full card data); Zoho platform services (form submissions, CRM data, electronic signature completion records, portal access events); and analytics providers. We handle such third-party data in accordance with this Policy and our agreements with those providers.

2.4 Sensitive Personal Information

To the extent we collect "sensitive personal information" as defined by applicable law (such as financial information used for accredited investor qualification), we collect such information only as necessary to provide the Services, and we do not use it for secondary purposes such as advertising profiling without your explicit consent. We do not collect biometric data, genetic information, precise geolocation, racial or ethnic origin, religious beliefs, political opinions, health information, or sexual orientation through the Services.

2.5 Children's Privacy

The Services are intended for users 18 years of age and older. We do not knowingly collect personal information from anyone under the age of 13. If we discover that we have inadvertently collected personal information from a child under 13, we will promptly delete such information. If you believe we have collected information from a child under 13, contact us immediately at support@captvr.com. For users aged 13 to 17, we do not engage in targeted advertising or sell their personal information without opt-in consent.

3. HOW WE USE YOUR INFORMATION

We use the personal information we collect for the following purposes:

3.1 Service Delivery

• Process subscription registrations, payments, and account maintenance
• Manage and verify portal access requests and consent completions
• Deliver Creator OS, First Position, and Advisory Services
• Enable Zoho Sign electronic consent processes
• Respond to inquiries and provide customer support
• Send transactional communications (receipts, access confirmations, password resets)

3.2 Business Operations

• Analyze usage patterns to improve and develop the Services
• Monitor for and prevent fraud, abuse, and unauthorized access
• Maintain security of our systems and data
• Comply with legal obligations and enforce our Terms of Service
• Conduct internal audits and record-keeping

3.3 Communications and Marketing

• Send marketing and promotional communications to which you have consented
• Provide updates on new products, services, and features
• Conduct research and surveys with your consent

We will not use your personal information for purposes materially different from those described in this Policy without providing prior notice and, where required by law, obtaining your consent.

4. HOW WE SHARE YOUR INFORMATION

4.1 Service Providers

We share personal information with third-party service providers who assist us in operating the Services, including: Zoho Corporation (CRM, Sign, Learn, Bookings, and related services); payment processors; email and SMS delivery providers; analytics platforms; and IT and security service providers. These providers are contractually required to use your information only as directed by CaptVr and in accordance with applicable privacy law.

4.2 Legal Requirements

We may disclose personal information when required to do so by law, legal process, regulation, court order, or governmental authority, or when we believe in good faith that disclosure is necessary to: (a) comply with applicable legal obligations; (b) protect and defend CaptVr's rights or property; (c) prevent or investigate possible wrongdoing in connection with the Services; or (d) protect the personal safety of users or the public.

4.3 Business Transfers

In the event of a merger, acquisition, asset sale, financing, reorganization, or similar business transaction, your personal information may be transferred to a successor entity as part of that transaction. We will provide notice before your information becomes subject to a materially different privacy policy.

4.4 With Your Consent

We may share personal information with third parties when you have given us your explicit consent to do so.

4.5 No Sale of Personal Information

CaptVr does not sell your personal information to third parties. We do not exchange your personal information for monetary or other valuable consideration with any third party for their own independent marketing purposes. We do not share your data with data brokers or advertising networks for targeted advertising without your consent.

5. DATA RETENTION

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, maintain your account, comply with legal obligations, resolve disputes, and enforce our agreements. Specifically:

• Account information: retained for the duration of your account plus 7 years following account closure, unless a shorter period is required by law
• Portal access records and consent documentation: retained for a minimum of 7 years following the consent event, to support regulatory and legal compliance
• Accredited investor qualification records: retained for a minimum of 7 years from the date of investor access or last transaction, consistent with securities recordkeeping standards
• Transaction and billing records: retained for 7 years in accordance with Tennessee and federal tax recordkeeping requirements
• Marketing consent records: retained for the duration of the consent plus 4 years following consent withdrawal or account closure
• Communications and support records: retained for 3 years following resolution

When personal information is no longer required for any of the above purposes, we will securely delete or anonymize it. Note that certain information may be retained in backup systems for additional periods in accordance with our business continuity practices.

6. DATA SECURITY

CaptVr implements reasonable and appropriate technical and organizational measures to protect the personal information we collect and process from unauthorized access, use, disclosure, alteration, or destruction. These measures include: encryption of data in transit using TLS; access controls and authentication requirements; periodic security reviews and assessments; vendor due diligence for third-party processors; and employee data handling training.

No method of transmission over the internet or method of electronic storage is completely secure. While we implement commercially reasonable safeguards, we cannot guarantee the absolute security of your information. In the event of a data breach that creates a material risk of harm to affected individuals, we will notify affected users and applicable regulatory authorities as required by applicable law.

7. COOKIES AND TRACKING TECHNOLOGIES

7.1 Types of Cookies We Use

We and our service providers use cookies, web beacons, pixels, and similar tracking technologies on our website and platforms. Categories include:

Strictly Necessary Cookies: Required for the Services to function. These cannot be disabled without affecting core functionality, such as session authentication and security.

Performance and Analytics Cookies: Collect information about how users interact with the Services, including pages visited, time spent, and errors encountered. Used to improve Service performance.

Functional Cookies: Enable personalization features, such as remembering your preferences and settings.

Marketing Cookies: Used to deliver relevant content and track the effectiveness of our marketing communications. Only deployed with your consent.

7.2 Cookie Management

You may control cookie preferences through your browser settings or, where a cookie consent manager is deployed on our site, through that interface. Disabling strictly necessary cookies may impair Service functionality. For analytics or marketing cookies, you may opt out without affecting core features. We honor Do Not Track (DNT) signals to the extent technically practicable.

8. YOUR PRIVACY RIGHTS

8.1 Universal Rights (All Users)

Regardless of your location, you have the right to: (a) access personal information we hold about you; (b) correct inaccurate personal information; (c) request deletion of personal information we hold about you, subject to legal retention obligations; (d) opt out of marketing communications at any time; and (e) receive a response to a verifiable privacy rights request within the applicable statutory timeframe.

8.2 California Residents (CCPA/CPRA)

If you are a California resident, you have the following rights under the CCPA/CPRA (effective January 1, 2026):

Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected about you, the sources, the purposes, and the third parties with whom we share it.

Right to Delete: Request deletion of personal information we have collected from you, subject to legal retention exceptions.

Right to Correct: Request correction of inaccurate personal information.

Right to Opt Out of Sale/Sharing: We do not sell or share personal information for cross-context behavioral advertising. If our practices change, we will provide a "Do Not Sell or Share My Personal Information" mechanism.

Right to Limit Use of Sensitive Personal Information: You may direct us to limit our use of sensitive personal information to purposes strictly necessary to provide the Services.

Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA/CPRA rights.

California residents may submit rights requests to support@captvr.com. We will respond within 45 days, with a possible 45-day extension with notice. We do not recognize Global Privacy Control (GPC) as a universal opt-out at this time but will review applicability as regulatory guidance develops.

8.3 Tennessee Residents (TIPA)

The Tennessee Information Protection Act (TIPA), effective July 1, 2025, confers consumer rights for qualifying Tennessee residents processed by controllers meeting applicable revenue and data volume thresholds. To the extent TIPA applies to CaptVr's operations, Tennessee residents have the right to: access their personal data; correct inaccurate personal data; delete personal data they provided or that was collected about them; obtain a portable copy of their personal data; and opt out of the processing of their personal data for targeted advertising, the sale of their personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects. Requests may be submitted to support@captvr.com. We will respond within 45 days.

8.4 EU/EEA and UK Residents (GDPR/UK GDPR)

If you are a resident of the European Economic Area (EEA), the United Kingdom, or another jurisdiction subject to the GDPR or UK GDPR, the following applies:

Lawful Basis for Processing: We process your personal data on one or more of the following lawful bases: (a) contract—processing necessary to perform our agreement with you; (b) legal obligation—processing required by applicable law; (c) legitimate interests—processing necessary for our legitimate business interests, where not overridden by your rights; and (d) consent—for marketing communications and non-essential cookies, where we rely on your freely given, specific, and revocable consent.

Under GDPR, you have the right to: access your personal data; rectification of inaccurate data; erasure ("right to be forgotten"), subject to legal grounds for retention; restriction of processing; data portability; and to object to processing based on legitimate interests or direct marketing. Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of processing prior to withdrawal. You also have the right to lodge a complaint with a supervisory authority in your country of residence.

International Data Transfers: If you are located in the EEA or UK, your personal data may be transferred to and processed in the United States, which may not provide the same level of data protection as your home jurisdiction. We implement appropriate safeguards for such transfers, including Standard Contractual Clauses (SCCs) approved by the European Commission, and will update our transfer mechanisms in accordance with evolving regulatory requirements.

Data Protection Contact: Inquiries regarding GDPR rights may be directed to support@captvr.com. We will respond to verifiable requests within 30 days in accordance with GDPR requirements.

9. SUBMITTING A PRIVACY RIGHTS REQUEST

To exercise any applicable privacy right, submit a verifiable request to support@captvr.com. Your request must include: your full name; the email address associated with your account or Services use; your state or country of residence; a description of the right you wish to exercise; and, if requesting access or portability, the categories of information you are requesting. We may ask you to verify your identity before processing your request. We will not fulfill requests that we cannot verify.

We do not charge a fee to process a verifiable consumer request unless the request is manifestly unfounded, excessive, or repetitive. If we determine a fee is warranted, we will notify you before proceeding. We will not discriminate against you for submitting a privacy rights request.

10. THIRD-PARTY LINKS AND INTEGRATIONS

The Services may contain links to third-party websites, platforms, or services including Zoho, payment processors, and booking tools. CaptVr is not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party service you access through our Services. This Policy applies only to CaptVr's own data collection and processing.

11. COMMUNICATIONS PREFERENCES

11.1 Email

We may send you transactional emails (account confirmations, receipts, access notifications) as part of delivering the Services. These are not marketing communications. For marketing emails, we will only send them with your consent (obtained separately). You may opt out of marketing emails at any time by clicking the unsubscribe link in any marketing email or by contacting support@captvr.com. Opting out of marketing emails does not affect your receipt of transactional communications.

11.2 SMS/Text Messages

We send SMS communications only with your prior express written consent as required by the Telephone Consumer Protection Act (TCPA) and applicable state law. Consent is obtained as a separate, standalone authorization at the time of opt-in and is not a condition of using the Services. Standard message and data rates may apply. To opt out of SMS communications, reply STOP at any time or contact us at support@captvr.com. Message frequency varies.

12. DO NOT TRACK

Some browsers include a "Do Not Track" (DNT) feature that signals websites not to track user activity. We currently assess DNT signals and endeavor to honor them where technically practicable. However, there is no uniform standard for DNT, and we cannot guarantee consistent implementation across all portions of the Services.

13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. When we make material changes, we will notify active users by email to the address on file and/or by prominent notice on the Services before the changes take effect. The "Last Updated" date at the top of this Policy will reflect the most recent revision. Your continued use of the Services after the effective date of any modification constitutes your acknowledgment of the revised Policy. If you do not agree to the revised Policy, you must discontinue use of the Services.

14. CONTACT US

For privacy inquiries, rights requests, or questions about this Policy, contact:

CaptVr, INC. - Privacy & Legal
6339 Charlotte Pike PMB D369
Nashville, TN 37209
Davidson County, USA
Email: support@captvr.com
Privacy requests response time: 30-45 days depending on applicable law