Privacy Policy

Effective Date: January 1,2025

1. Introduction

We are committed to protecting your privacy and ensuring the safety of your personal data. This Privacy Policy explains the types of personal information we collect, how we use it, and your rights concerning your data. By using our services, you consent to the practices described in this policy.

2. What We Collect

We collect personal data in various ways:

• Information You Give Us: When you use our services, we may collect your name, postal address, email address, phone number, username, password, demographic information (such as your occupation), Social Security number, tax ID number, and bank account information. We collect this information when you create an account, make a purchase, or interact with our customer service.

• Information We Get From Others: We may collect data from third parties, such as employers providing equity information (options or shares) or other sources that share your data with us to enhance your user experience.

• Information Automatically Collected:

o Device Information: Data related to the devices you use to access our services, such as device type, operating system, unique device identifiers, and crash data.

o Transactional and Usage Information: Information about how you interact with our website, such as browser type, pages viewed, time spent on each page, location (IP address), and actions performed.

o Cookies and Similar Technologies: We use cookies and similar technologies to track interactions and personalize user experience, subject to your consent where required by law.

3. Use and Disclosure of Personal Information

We may use, process, or disclose your personal information for several purposes:

• Operational Use: To operate, maintain, and improve our services, including addressing service requests, monitoring for errors, and enhancing security.

• Communication: To send updates, confirmations, invoices, technical notices, and security alerts related to our services.

• Marketing: To send marketing emails with your consent. You may opt out at any time via unsubscribe links.

• Fraud Prevention and Legal Compliance: To protect against fraud, verify identities, comply with legal obligations, and ensure compliance with laws such as KYC (Know Your Customer) regulations.

• Advertising and Analytics: We may use third-party services to provide personalized advertising based on your interactions with our services. These companies may track your behavior across multiple platforms.

4. Sharing of Personal Information

We may share your personal data with third parties under the following circumstances:

• Business Partners: Our service providers, contractors, and business partners may have access to your data in the course of providing services to us.

• Legal Obligations: We may disclose information to comply with legal requirements, respond to lawful requests, or protect our rights and safety.

• Business Transactions: In the event of a merger, acquisition, or sale, your data may be transferred as part of that transaction.

• Plaid Integration: If you use banking services through our platform, we may share your financial data with Plaid Technologies, Inc., as detailed in the Plaid Privacy Policy.

5. Retention of Personal Data

We retain personal data for as long as necessary to fulfill the purposes for which it was collected, including legal, accounting, and reporting obligations. When no longer needed, we will delete, anonymize, or securely store the data until deletion is possible.

6. Your Rights and Choices

You have several rights concerning your personal data:

• Access and Correction: You may request a copy of the personal information we hold about you and correct any inaccuracies.

• Deletion: You may request deletion of your personal information, subject to legal restrictions.

• Opting Out of Marketing: You can opt out of receiving marketing communications by following the unsubscribe instructions.

• Cookies: You can manage your cookie preferences through your browser settings.

7. Age Limitations

Our services are not intended for children under 18. If we learn that we have inadvertently collected data from minors, we will take steps to delete it.

8. Do Not Track

We currently do not respond to “Do Not Track” requests from browsers.

9. California Residents' Privacy Rights

If you are a resident of California, you have specific rights under the California Consumer Privacy Act (CCPA). These rights include:

• Right to Know: Request information about the categories of personal data we have collected about you.

• Right to Access: Request a copy of the personal data we have collected about you.

• Right to Deletion: Request that we delete your personal information.

• Non-Discrimination: You may exercise your CCPA rights without facing discrimination.

To exercise your CCPA rights, contact us at privacy@carta.com or call _________________

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make changes, we will update the “Effective Date” at the top of the policy. Please review the policy periodically for updates.

11. Contact Us

For questions regarding this Privacy Policy or to exercise your privacy rights, please contact us at:

[Insert Contact Information]

Notice for California Residents

This notice applies to California residents and explains how entr3pnr collects, uses, and shares Personal Information in accordance with the California Consumer Privacy Act (CCPA). The term “Personal Information” follows the definition provided in the CCPA.

We do not sell (as defined by CCPA) your Personal Information. We collect, use, and disclose Personal Information solely for business purposes as described in our Privacy Policy.

Your California Privacy Rights:

Under the CCPA, you have the right to:

1. Request Information: Know what categories of Personal Information we have collected, sources of that information, and how it has been used or shared in the past 12 months.

2. Access: Request a copy of the Personal Information we've collected about you.

3. Deletion: Request the deletion of your Personal Information.

4. Nondiscrimination: Exercise these rights without facing discrimination.

To submit a request for information, access, or deletion, please contact us through our website. We may need to verify your identity to process these requests.

Personal Information We Collect

We collect Personal Information from various sources, including:

• Information You Provide: Your name, contact information, and other details you share with us.

• Automatically Collected: Device data, usage information, cookies, etc.

Notice for European Users (GDPR compliance) 

This notice applies to individuals located in the European Economic Area (EEA), United Kingdom (UK), and Switzerland (collectively, “Europe”). It outlines how we collect and process personal data, as well as your rights under the General Data Protection Regulation (GDPR).

Controller/Processor

Entr3pnr may act as a data controller or processor of your personal information.

EU Representative

For privacy-related matters, you may contact our EU representative through the website.

Legal Basis for Processing

Our legal bases for processing your data depend on the purpose and context, including performance of a contract, legitimate interests, consent, or legal obligation. Below are the key processing purposes:

• To provide our services: For example, operating, improving, and maintaining our services, responding to customer inquiries, and delivering products.

• Marketing and analytics: Based on our legitimate interests, unless overridden by your rights.

• Compliance: To meet legal requirements and protect against fraud or unauthorized activity.

Sensitive Personal Data

We request that you avoid providing sensitive data (e.g., racial, political opinions, health data). If you submit sensitive data, you consent to its processing as described in this policy.

Your Rights

Under GDPR, you have several rights concerning your personal data:

• Right to access: You can request access to your personal data.

• Right to rectification: You can request to correct inaccurate data.

• Right to erasure: You can request deletion of your data under certain conditions.

• Right to restrict processing: You can limit how we use your data.

• Right to data portability: You can receive your data in a structured, machine-readable format.

• Right to object: You can object to data processing based on legitimate interests or for marketing.

• Right to withdraw consent: If we process data with your consent, you can withdraw it at any time.

• Right to lodge a complaint: You may file a complaint with your supervisory authority if you believe your rights have been violated.

Cross-border Data Transfer

If your data is transferred outside Europe, we use safeguards such as Standard Contractual Clauses (SCCs) or obtain your consent where required.

Changes to This Policy

We may update this policy. Any changes will be communicated to you and posted on our services.

EU-U.S. Data Privacy Framework

Entr3pnr complies with the EU-U.S. and Swiss-U.S. Data Privacy Frameworks. For more details, please refer to the Data Privacy Framework.

Contact

For more information or inquiries regarding your privacy rights, please contact us through our website.