Privacy Policy

1. Introduction

Capstone, Inc. (“Capstone,” “we,” “our,” or “us”) operates an AI-powered experiential learning and assessment platform that enables individuals to develop and demonstrate professional skills through Virtual Work Experiences (“VWEs” or “Simulations”). We are committed to protecting your privacy and handling your personal information with transparency and care.

Capstone offers two types of Simulations: Capstone Simulations, which are fully fictional environments created by Capstone, and Industry Simulations, which are co-created with real organisations and may incorporate real company contexts. This policy applies to both. Where Industry Simulations involve data shared with or received from partner organisations, this will be disclosed to you before enrolment.

This Privacy Policy explains what data we collect, how we use it, and the choices you have. It applies to all users of our platform, including job seekers, beta participants, and any other individuals who interact with Capstone's services.

By creating an account or using our services, you agree to the collection and use of information as described in this policy.

2. Information We Collect

2.1 Information You Provide Directly

• Account registration details: name, email address, password
• Professional profile information: work history, skills, career goals
• Application and screening responses submitted during onboarding
• Content you create during Virtual Work Experiences (Simulations): messages, documents, deliverables, and task completions
• Payment information processed securely through third-party payment providers (we do not store card details)
• Communications you send to Capstone support

2.2 Information Generated Automatically

• Session data: login timestamps, session duration, and activity patterns
• Interaction logs: your messages with AI agent personas within the simulation environment
• Behavioral signals: how you approach tasks, respond to prompts, manage time, and communicate
• Assessment outputs: scores, rubric evaluations, and competency ratings generated by our evaluation engine
• Device and technical data: browser type, operating system, IP address, and referral source

2.3 Information from Beta Participants

If you participate in a Capstone beta program, we collect additional feedback data, debrief responses, and qualitative research input as outlined in your beta participation agreement.

3. How We Use Your Information

3.1 To Provide and Operate the Platform

• Create and manage your account
• Deliver Virtual Work Experiences and assess your performance
• Generate competency scores and evaluation reports
• Process payments for platform access
• Communicate with you about your account, participation, and results

3.2 To Improve Our Services

Capstone uses data from your Virtual Work Experience (Simulation) participation to improve our platform, AI agent behavior, and evaluation engine. This is a core part of how we build a better product.

Importantly: all data used for AI model training and platform improvement is fully anonymized before use. No personally identifiable information (PII) is fed into our AI models. Anonymization includes removal of names, email addresses, and any other direct identifiers, combined with aggregation across multiple participants to prevent re-identification.

Specifically, we use anonymized and aggregated data to:

• Refine AI agent behavior and simulation realism
• Calibrate and improve our evaluation rubrics and scoring engine
• Build benchmark datasets that make assessments more accurate over time
• Identify and address platform quality issues

3.3 To Protect Platform Integrity

• Detect and prevent fraudulent, abusive, or inauthentic behavior
• Enforce our Terms of Service
• Maintain the reliability and security of our systems

3.4 Legal and Compliance Purposes

• Comply with applicable laws and regulations
• Respond to lawful requests from government authorities
• Protect Capstone's legal rights and interests

4. How We Share Your Information

4.1 We Do Not Sell Your Data

Capstone does not sell your personal information to third parties. We do not share your data with advertisers or data brokers.

4.2 Service Providers

We work with trusted third-party vendors who process data on our behalf under strict confidentiality obligations. These include:

• Cloud infrastructure providers (e.g., hosting, storage, computing)
• Payment processors for secure transaction handling
• Analytics providers for platform performance monitoring
• Communication tools for customer support

All service providers are contractually required to use your data only for the purposes we specify and to maintain appropriate security standards.

4.3 Legal Obligations

We may disclose your information where required by law, court order, or governmental authority, or where necessary to protect the rights, property, or safety of Capstone, its users, or others.

4.4 Business Transfers

In the event of a merger, acquisition, or sale of all or part of Capstone's assets, your information may be transferred as part of that transaction. We will notify you of any material changes to data ownership or use.

5. Data Retention

We retain your personal information for as long as your account is active or as needed to provide our services. Specifically:

• Active account data is retained for the duration of your account
• Virtual Work Experience (Simulation) performance data and assessment records are retained for a minimum of three years to support credential portability and platform improvement
• Payment records are retained as required by applicable financial regulations
• Anonymized and aggregated data may be retained indefinitely as it no longer constitutes personal information

You may request deletion of your account and associated personal data at any time. See Section 7 for your rights and how to exercise them.

6. Data Security

We implement industry-standard technical and organizational security measures to protect your personal information, including:

• Encryption of data in transit and at rest
• Access controls limiting data access to authorized personnel
• Regular security assessments and monitoring
• Incident response procedures for data breaches

While we take reasonable precautions, no system is completely secure. We cannot guarantee the absolute security of your information and encourage you to use strong, unique passwords and report any suspicious activity to hello@usecapstone.com.

7. Your Rights and Choices

Depending on your location, you may have the following rights with respect to your personal information:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete data
• Deletion: Request deletion of your personal information, subject to certain exceptions
• Portability: Request your data in a structured, machine-readable format
• Opt-out of marketing: Unsubscribe from promotional communications at any time

To exercise any of these rights, please contact us at hello@usecapstone.com. We will respond within 30 days. We may need to verify your identity before processing certain requests.

Please note that some data may be retained where required by law or where deletion would impair a legitimate legal or operational need.

8. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to operate the platform and improve your experience. These include:

• Essential cookies required for authentication and core functionality
• Analytics cookies to understand how users interact with the platform
• Preference cookies to remember your settings

You may disable non-essential cookies through your browser settings or our cookie preference center. Disabling essential cookies may impair platform functionality.

9. Children's Privacy

Capstone is not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected data from a minor, we will delete it promptly. If you believe a minor has provided us with personal information, please contact us at hello@usecapstone.com.

10. Additional Rights for California Residents

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, the right to request deletion, and the right to opt out of the sale of personal information (which we do not engage in).

To exercise your CCPA rights or submit a verifiable consumer request, contact us at hello@usecapstone.com. We will not discriminate against you for exercising your privacy rights.

11. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you by email or through a prominent notice on the platform prior to the change taking effect. Your continued use of Capstone after the effective date of the revised policy constitutes acceptance of the changes.

We encourage you to review this policy periodically.

12. Contact Us

If you have questions, concerns, or requests related to this Privacy Policy, please contact us:

We aim to respond to all privacy inquiries within 30 days.