Privacy Policy

Charmtech Labs LLC ("Charmtech") values your privacy. This Privacy Policy applies to all Charmtech’s products, which includes Capti Accommodate, Capti Assess, Capti Higher Ed, Capti Personal, Capti Advance and website (collectively: "Capti"), and describes the types of personal information we collect, how we use the information, with whom we share it, and the choices you can make about our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices. We are compliant with all federal, state, and local regulations.

1 Information We Collect

A. Personal Accounts

In order to use any of Charmtech’s products, a user account is required. During the account registration, Charmtech will request your name, a username, an email address, and a password. Additionally, during purchases other than those made on the iOS AppStore, Charmtech will request your payment information which will be processed via PayPal. Charmtech does not retain cardholder data, and Charmtech payment processing system is PCI compliant.

Capti enables you to add content to a Playlist, which is stored only on your device by default. You may synchronize your Playlist to back up the Playlist and/or share it between your devices or with other users; these functionalities are enabled by storing a copy of your playlist on Charmtech servers.

You may choose to log in to 3rd party sources such as Dropbox and Google Drive to add their content to your Playlist. Charmtech servers do not receive the content of your sources. However, if you synchronize your Playlist, the Playlist data will be sent to the Charmtech server.

Charmtech applications provide conversion of many file types to speech. Certain file types are processed on Charmtech servers. When a user converts a file (including files accessed via the Internet) to speech, the contents of that file, including any personal information therein, may be processed, but are not stored, on the Charmtech servers, unless you synchronize your Playlist.

In addition, when you visit our website (, we collect certain information by automated means, including cookies. The information we collect in this manner includes IP address, browser type, operating system, referring URLs, information on actions taken on our site, and dates and times of website visits. A "cookie" is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser.

Charmtech may also collect, compile and analyze aggregate user data ("Aggregate User Data"), including user behavioral patterns in accordance with this Privacy Policy to improve Charmtech’s services.

Users can request to have their stored data deleted at any time. Stored data will be deleted upon request.

B. School/Organization Accounts

Charmtech products, including but not limited to Capti, are sold to schools and educational institutions as a package that includes a specified number of licenses. These licenses are accepted by administrators or teachers on behalf of students.

When an administrator or teacher creates an account on behalf of a student, Capti requests the following information. First name, Last name, and email address. If a student does not have an email address, Capti will provide a system email address to use as their username. This allows students to access and interact with the platform. Charmtech does not store any other data, including protected student records, on their servers at any time.

In compliance with all federal, state, and local regulations, a parent or guardian of a student using any Charmtech product on behalf of their school or educational institution may request to view, manage, or delete any information held on the Charmtech servers in relation to their child. If the guardian chooses to delete the data, the child will no longer be permitted to use Capti, or any other Charmtech product, without parental consent.

Teachers and administrators can view assignments, tracks uploaded to student’s playlists, and the scores they achieved on assigned tests.

C. ETS ReadBasix

Capti Assess is a reading diagnostic product that can be purchased independently or jointly with other Capti products. Capti Assess is powered by ETS ReadBasix, an assessment that was designed and is owned by Educational Testing Service. Educational Testing Service reserves the right to collect the following information from ETS ReadBasix for research purposes.

ETS uses anonymized and pseudonymized information for various research initiatives. For example, ETS may consider how certain types of test takers (such as nonnative English speakers) respond to specific test questions. Similarly, educational apps, such as Capti, collect data to help ETS understand and improve reading skills. ETS's research initiatives reflect our commitment to fairness and equity in testing, helping to ensure that our tests are accessible and free from bias. ETS also seeks to improve teaching, learning and assessment.

At no time does ETS receive any PII (Personal Identifiable Information) from Charmtech. If a parent or guardian requests their child’s data be removed from ETS, you will be required to contact ETS. Charmtech is not liable for any information stored on ETS servers.

By purchasing a license or multiple licenses of Capti Assess, you are accepting that Educational Testing Service will collect data for research purposes.

D. Other Applications

Some applications may require Capti to request permissions to access your account. Below is information we access from such applications. At no time will Capti have access to your password in another application. These permissions apply to both Personal and School/Organization accounts.

Capti Google Chrome Extension

  • Access your data on all websites
  • Access your tabs and browsing activity
  • Access data you copy and paste

Google Drive, Dropbox, OneDrive, Office 365 integration

  • View your email address
  • View basic information about your account
  • View and manage files

Canvas, Schoology, Blackboard LTI integration

  • View your email address
  • View your role

Google Classroom integration

  • View your email address
  • View your class in Google Classroom
  • Enable teacher to post links to Google Classroom

Clever integration

  • View your email address
  • View your role
  • View your rostering information

2 How We Use the Information We Collect

We may use the personal information we obtain about you in order to:

  1. Facilitate the account registration process, including confirmation emails
  2. Send users emails in accordance with their email preferences
  3. Provide and enhance services to our users
  4. Assist in the restoration of an account that a user has lost access to, such as when a user forgets their password
  5. Facilitate the addition of features to a user account
  6. Operate, evaluate and improve our business (including developing new products and services; analyzing our products and services; managing our communications; and performing accounting, auditing and other internal functions)
  7. Comply with applicable legal requirements and our policies, and enforce our Terms of Service and End User License Agreement.

In addition, by collecting information through automated means on our website, we learn how to best tailor our website to our visitors. We may use cookies to customize visits to our site and "remember" user account information for easier login. We may use IP addresses to help diagnose problems with our server and to administer our website. We also may use IP addresses to help identify visitors to our site for the duration of a session and to gather demographic information about our visitors. We may use clickstream data to determine how much time visitors spend on each web page of our website, how visitors navigate through the site, and how we may tailor our site to better meet the needs of our visitors.

We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

Capti collects and sends user data to Educational Testing Service as stipulated by our agreement and Section 1(c) of this document.

ETS uses anonymized and pseudonymized information for various research initiatives. For example, ETS may consider how certain types of test takers (such as nonnative English speakers) respond to specific test questions. Similarly, educational apps, such as Capti, collect data to help ETS understand and improve reading skills. ETS's research initiatives reflect our commitment to fairness and equity in testing, helping to ensure that our tests are accessible and free from bias. ETS also seeks to improve teaching, learning and assessment.

ETS may process Personal Information as needed to create de-identified datasets for research. ETS will not (and will not permit any third party to) associate identifying information with research data. Our research results do not contain any identifiable data, and research data are not used to target or profile individuals.

3 Information We Share

We do not sell or rent personal information about our members. In addition, we do not share or otherwise disclose such information except as described in this Privacy Policy.

We may share personal information with third parties for the purposes of providing services to Charmtech that directly or indirectly help us operate our business and applications. We do not authorize our service providers or other third parties with whom we share personal information to use or disclose the information for any purpose other than providing services to Charmtech or to comply with legal requirements. We require such third parties by contract to appropriately safeguard the privacy and security of personal information they process on our behalf.

We may publish Aggregate User Data.

We also may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.

We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets. If we enter into a business transition such as a merger, consolidation, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, or dissolution, your Personal Information may be among the assets we transfer. You acknowledge and consent that such transfers are permitted by this Privacy Policy, and that any acquirer of ours or that acquirer's affiliates may continue to collect and use your Personal Information as set forth in this Privacy Policy. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.

4 Your Choices

We offer you certain choices about what personal information we collect about you, how we use that information, and how we communicate with you.

You may elect not to have a unique cookie identification number assigned to your computer to avoid aggregation and analysis of data collected on our website. Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies you may not be able to take full advantage of all our website features.

You may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your personal information. We will apply your preferences going forward. In some circumstances, withdrawing your consent to Charmtech’s use or disclosure of your personal information will mean that you cannot take advantage of certain Charmtech products or services.

To update your preferences, ask us to remove your information or submit a request, please contact us as specified below.

5 Access and Correction

If you believe that the personal information we maintain about you is inaccurate, you may request that we erase, rectify, complete or amend the information by contacting us as indicated in the " How to Contact Us" section of this Privacy Policy. If we deny an access request, we will notify you of the reasons for the denial and offer an opportunity to challenge our decision.

6 Data Transfers

This is a U.S. website governed by applicable U.S. law. When you provide personal information on this site, we may process the information outside of the country in which you are located, including in the U.S.

7 How We Protect Personal Information

We maintain appropriate administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

We have procedures to deal with any suspected data security breach and will notify you and/or any applicable regulator or supervisory authority or other governmental entity where we are legally required to do so.

8 Links to Other Websites

Our website may provide links to other websites for your convenience and information. These websites may operate independently from Charmtech. Linked sites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not owned or controlled by Charmtech, we are not responsible for the sites’ content, any use of the sites, or the privacy practices of the sites.

9 Updates to Our Privacy Policy

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a prominent notice on our website to notify you of any significant changes to our Privacy Policy and indicate at the top of the policy when it was most recently updated. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an e-mail. Users will have a choice as to whether or not we use their information in a different manner.

10 How to Contact Us

If you have any questions or comments about this Privacy Policy, or if you would like us to update information we have about you or your preferences, please contact us:

Charmtech Labs LLC
77 Goodell St, Ste 570,
Buffalo, NY 14203.

Charmtech has further committed to refer unresolved privacy complaints under the US-EU [and US-Swiss] Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Charmtech, please visit the BBB EU SAFE HARBOR website at for more information and to file a complaint.

Charmtech complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Charmtech has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Charmtech certification, please visit