CAP - Climate Accountability Platform

Privacy Policy

Effective starting: February 2026, Version 1.0

What this policy covers

Your privacy is important to us. We are also committed to being transparent about collecting and storing our customers’ personal information . This Privacy Policy covers the information we collect from our customers when they use our products or services, or otherwise interact with us (for example, when they communicate with us on the CAP platform which is one of Senoku Group ’s products), unless a different policy is displayed. Senoku Group, which is wholly owned by Arensen Group Pty Ltd, offers CAP platform to our customers. We refer to this product, together with our other products, services and websites as "Services " in this policy.

This policy also explains your choices surrounding how we use your personal information, which includes how you can object to certain uses of information and how you can access and update certain personal details. If you do not agree with this policy, please do not access, or use our Services or interact with any other aspect of our business.

Where we provide the Services under contract with an organization (for example, your employer) that organization controls the information processed by the Services. For more information, please see Notice to End Users below. This policy does not apply to the extent that we process personal information in the role of a processor on behalf of such organizations.

What Personal Information do we require from you?

We keep personal information when you provide it to us, when you use our Products and Services, and when other sources provide it to us, as further described below.

Content you provide through our websites: The Services include our websites owned and operated by us. We collect content that you submit to these websites. For example, you provide us with content through your feedback or when you participate in any interactive features, surveys, contests, promotions, activities, or events.

Information you provide through our support channels: The Services also include our customer support, where you may choose to submit information regarding a problem you are experiencing with a Service. Whether you designate yourself as a technical contact, open a support ticket, or otherwise engage with our support team, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would assist us in resolving your issue.

Information we collect automatically when you use the Services: We keep information about you when you use our Services, including browsing our websites and taking certain actions within the Services.

Your use of the Services: We keep certain information about you when you visit and interact with any of our Services. This information includes the features you use; the links you click on; the type, size and filenames of attachments you upload to the Services.

Cookies and Other Tracking Technologies: Any third-party partners may use cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to recognize you across different Services and devices.

How we use information we store

How we use the information we store depends in part on the Services you use, how the Services are used, and any user preferences. Below are the specific purposes for which we use the information we store about you.

To provide the Services and personalize your experience: We use information about you to provide you with Services such as customer support. Where multiple Services are used, we combine information about you and your activities to provide an integrated experience, such as allow ing you to find information from one Service while searching from another or to present relevant product information as you navigate our websites and applications.

For research and development: We are always looking for ways to make our Services smarter, faster, secure, integrated, and useful. We use information and collective learnings (including feedback) about how people use our Services to troubleshoot, to identify trends, usage, activity patterns, and areas for integration and to improve our Services and to develop new products, features and technologies that benefit our users and the public. In some cases, we apply these learnings across our Services to improve and develop similar features, to better integrate the Services you use, or to provide you with insights based on how others use our Services. We also test and analyse certain new features with some users before rolling the feature out to all users.

To communicate with you about the Services: We use your contact information to send transactional communications via email and within the Services, including responding to your comments, questions, and requests, providing customer support, and sending you technical notices, updates, security alerts, and administrative messages. We send you email notifications when you or others interact with you on the Services. We also send you communications as you onboard to a particular Service to help you become more proficient in using that Service. These communications are part of the Services and in most cases, you cannot opt out of them. If an opt out is available, you will find that option within the communication itself.

To promote and drive engagement with the Services: We use your contact information and information about how you use the Services to send promotional communications that may be of specific interest to you, including by email. We will communicate with you about new Services, product offers, promotions, and contests.

Customer support: We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyse information, and to repair and improve the Services. Where you give us express permission to do so, we may share information with a third -party expert for the purpose of responding to support-related requests. Currently, all our customer service is internal, within Senoku Group.

For safety and security: We use information about you and your Service to verify accounts and activity, to detect, prevent, and respond to potential or actual security incidents and to monitor and protect against other malicious, deceptive, fraudulent, or illegal activity, including violations of Service policies.

To protect our legitimate business interests and legal rights: Where required by law or where we believe it is in the interests of the protection of our legal rights, as well as the rights of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the progress of business.

With your consent: We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may seek your consent before we choose to publish testimonials or featured customer stories to promote the Services.

Legal bases for processing (for EEA users): If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have a specified legal basis for doing so under applicable EU laws. Each legal basis depends on the Services you use and how you use them.

This means we will only collect and use your information when :

If you have consented to our use of your information for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g., your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.

How stored information is shared

We make collaboration tools , and it is in the interests of ourselves and our users to continue to improve these tools and their features and functionality. This means sharing information through the Services and with certain third parties. We share collected information in the ways discussed below, including in connection with possible business transfers. We are not in the business of selling user information for the purpose of advertising or other third-party purposes.

Sharing with other Service users: When you use the Services, we share certain collected information with other Service users.

For collaboration: You can create content, which may contain your information, and grant permission to others in your company to see, share, edit, copy and download that content based on settings you or your administrator to select.

Sharing with third parties: We may share information with third parties that help us operate, provide, improve, integrate, customize, support and market our Services.

Service Providers: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, analysis, and other services, which may require them to access or use your information, which we will have noted down for customer service purposes. If a service provider needs to access your information to perform services on our behalf, they do so, follow our instructions and comply with our requirements, including appropriate security and confidentiality measures designed to protect our clients and their information.

CAP Partners: We work with third parties who provide consulting, sales, support, and technical services to deliver and implement customer solutions around the Services. We may share your information with these third parties in connection with their services and for specific purposes, for example, to provide localized support and to provide customizations to existing products and services. We may also share information with these third parties where our customers have consented to such sharing.

Third Party Apps: You, your administrator or other Service users may choose to add new functionalities or to change the behaviour of the Services by installing third party apps within the Services. Doing so may give third-party apps access to your account and your information, such as your name and email address, and any content you have chosen to use in connection with such apps. We do not control third-party app policies and procedures, and this privacy policy does not cover the ways in which third-party apps may use your information. We encourage you to review the privacy policies of third parties before connecting to or using their applications or services to learn more about their privacy and information handling practices. If you object to the sharing of your information with such third parties, please uninstall the third-party app.

Links to Third Party Sites: The Services may include links that direct you to other websites or services whose privacy practices may differ from ours. If you submit information to these third-party sites, your information will be governed by their privacy policies and not by ours. We encourage you to carefully read the privacy policy of any website you visit.

Third Party Services: We may offer you the ability to interact with or share information with third parties through the Services. For example, we may enable interactions with social media networks via links on the Services. When you intentionally interact with these third parties, we may share certain information with those third parties or receive information from those third parties, consistent with your privacy settings on the third -party service. Such information may include contact information, identification, and demographic information, and device information and identifiers. You should always check the privacy settings and notices in these third -party services to understand how they might use your information.

Third Party Widgets: Some of our services contain widgets and social media features, such as LinkedIn "like" button. These widgets and features may collect your IP address, which page you are visiting on the Services, and may set a cookie to enable the feature to function properly. Widgets and social media features are either hosted by a third -party or hosted directly on our Services. You should always check the privacy settings and notices in these third-party services to understand how those third parties may use your information.

With your consent: We share information about you with third parties when you consent to this specific action. For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside your testimonial.

Compliance with Enforcement Requests and Applicable Laws;

Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect - CAP platform , our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.

Sharing with affiliated companies: We share information we collect with affiliated companies and, in some cases, with prospective affiliates. Affiliated companies are companies owned or operated by us. The protections of this privacy policy apply to the information we share in these circumstances.

Business Transfers: We may share or transfer information we collect under this privacy policy in connection with any merger, sale of company assets, financing, or any business acquisition. You will be notified via email and/or a prominent notice on the Services if such a transaction is to take place, along with a number of choices regarding the further use of your information.

How we store and secure collected information

Information storage and security: We use industry standard technical and organizational measures to secure all stored information. While we implement safeguards that will protect and secure our clients’ information, no security system is impenetrable, and due to the constantly evolving nature of the Internet, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from outside intrusion. If you use our downloadable Services, responsibility for securing storage and access to all information connected with the Services will rest with you, the customer, and not with CAP platform and Senoku Group. We strongly recommend that server users configure SSL to prevent interception of information transmitted over networks and to restrict access to the databases and other storage points used.

How long we keep information: How long we keep information we collect about you depend on the type of information, as described in further detail below. After such time, we will either delete or de-identify your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.

Information you share on the Services: If your account is deactivated or disabled, some of your information and the content you have provided will remain to allow your team members or other users to make full use of the Services. For example, we continue to display messages you sent to the users that received them and continue to display content you provided, but when requested, identifying details will be removed.

Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period from the date you last expressed interest in our Services, such as when you last opened an email from us or ceased using your CAP platform. We retain information derived from cookies and other tracking technologies for a reasonable period from the date such information was created.

How to access and control your information

You have certain choices available to you when it comes to your information. Following is a summary of those choices, how they may be exercised, as well as certain limitations on these choices.

Your Choices:

You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. For all requests, you may contact us as provided in the Contact Us section below to request assistance.

Your request and choices may be limited, depending on circumstances: for example, if fulfilling your request may reveal information about another person, or if you ask to delete information which we or your administrator is permitted by law or have compelling legitimate interests to keep. Where you have asked us to share data with third parties, for example, by installing third -party apps, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.

Request that we stop using your information: In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don't have the requisite rights to do so. For example, if you believe a Services account was created for you without your permission or are no longer an active user, you can request that we delete your account through your administrator. Where you gave us consent to use your information for a limited purpose, your administrator can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. When you make such requests, we may need time to investigate and facilitate your request. If there is delay or dispute as to wheth er we have the right to continue using your information, we will restrict any further use of your information until the request is hono ured or the dispute is resolved, provided your administrator does not object (where applicable). If you object to information about you being shared with a third- party app, please disable the app or contact your administrator to do so.

Opt-out of communications: You may opt out of receiving our promotional communications (once we commence) by using the unsubscribed link within each email, updating your email preferences within your Service account settings menu, or by contacting us as provided below to have your contact information removed from our promotional email list. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages regarding our Services.

Send "Do Not Track" Signals: Some browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, our Services do no t currently respond to browser DNT signals. You can use the range of other tools we provide to control data collection and use, including the ability to opt out of receiving marketing from us as described above.

Data portability: Data portability is the ability to obtain some of your information in a format you can move from one service provider to another (for instance, when you transfer your mobile phone number to another carrier). Depending on the context, thi s applies to some of your information, but not to all your information.

International transfers of collected information

International transfers of information collected via our Services: We collect information globally and may transfer, process and store information outside of your country of residence, to wherever we or our third-party service providers operate and are domiciled for the purpose of providing you the Services. Whenever we transfer your information, we take every reasonable step available to secure and protect it.

Where the client is in Australia, personal information is collected and stored in Australia.

International transfers to third parties: Some of the third parties described in this privacy policy, which are contracted to provide us with services, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. Basically, when we share customer information in any given jurisdiction, we make use of data protection clauses available and applicable in these jurisdictions, to safeguard customer data. We also make use of binding corporate rules for transfers to data processors and all other appropriate legal mechanisms to safeguard each transfer.

Other important privacy information

Notice to End-Users

Many of our products are intended for use by organizations. Where the Services are made available to you through an organization (e.g., your employer), that organization is the administrator of the Services and is responsible for the accounts and/or Service sites over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the Services is subject to that organization's policies. We are not responsible for the privacy or security practices of an administrator's organization, which may be different than this policy.

Administrators can:

In some cases, administrators can also:

Please contact your organization or refer to your administrator’s organizational policies for more information.

Sharing your personal information: We do not sell your personal information. We do share your information with others as described in the ‘How we share collected information’ section of this policy.

Processing your information: This policy describes the categories of personal information we may collect, the sources of that information, and our deletion and retention policies. We have also included information about how we may process your information, which includes "business purposes" such as to protect against illegal activities, and for the development of new products, features, and technologies. If you have questions about the categories of information we may collect about you, please be sure to visit the section of this policy called, “What information we collect about you”, about our processing activities, please be sure to visit the section called, “How we use collected information”.

Our policy towards children: The Services are not directed to individuals under 18. We do not knowingly collect personal information from children under 18. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please inform us or take appropriate steps to prevent this information from being shared.

Changes to our Privacy Policy: Like all policies, this privacy policy is subject to change, as we aim to keep up with all alterations in applicable law. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by adding a notice on the Services Homepage, Contact Us page, login screens, or by notifying you via email. We will also keep prior versions of this Privacy Policy in an archive for your review. We encourage you to review our privacy policy whenever you use the Services to stay informed about our information practices and the ways you can help protect your privacy. If you disagree with any changes to this privacy policy, you will need to stop using the Services as outlined

Contact Us

Your information is controlled by Australian registered, owned and operated Arensen Group Pty Ltd, with the trading name as Senoku Group, based in Australia. The CAP Platform is a product of Senoku Group. If you have questions or concerns about how your information is handled, please direct your inquiry via the ‘Contact us’ in our CAP website https://capclimate.com.

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