Privacy Policy

Content last updated: September 4th, 2019

This privacy policy (“Policy”) describes how eShares, Inc. DBA Carta, Inc., and its related companies (“Company” or “Carta”) collect, use, disclose, and share personal information of consumer users of this website, www.tablestakes.com (the “Site”). This Policy also applies to any of our other websites that post this Policy.

What we collect

We get information about you in a range of ways.

Information You Give Us

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, bank account information, as well as other information you directly give us on our website.

For customers who have paid software services, we collect your billing details such as credit card information, banking information, and/or billing address.

Information We Get From Others

We may get information about you from other sources, such as your employer when they issue you options or shares. We may add this to information we get from this website.

Information Automatically Collected

We may collect information about the devices accessing our website and application. Some examples are: type of device, operating system used, application information, unique device identifiers and crash data. The type of information we collect depends on the type of device used and its settings.

We may automatically log information about you and your computer. For example, when visiting our website, we log your computer operating system type, browser type, browser language, pages you viewed, how long you spent on a page, location, access times and information about your use of and actions on our website.

Third party data

Carta may receive data about organizations, industries, website visitors, marketing campaigns, and other matters related to our business from affiliates, subsidiaries, partners, or others that we use to make our own information better or more useful. This data may be combined with other information we collect and might include aggregate level data. One example is to help our customers know how many stakeholders have accepted their securities on our platform.

Use of personal information

We may use personal information as follows:

  • We use your personal information to operate, maintain, and improve the website, products, and services. This includes use of other information to support delivery of our services under contract, assist with service request, monitor for errors, remedy security or technical issues, analyze website and application performances.
  • We use your personal information to respond to comments and questions, verify permission access, and provide customer service.
  • We use your personal information to send information including confirmations, invoices and billing, technical notices, updates, security alerts, and administrative messages.
  • We use your personal information to communicate system updates, upcoming events, and other news about products and services offered by us. We may contact you to inform you about important services-related notices, such as privacy and policy update notices or changes in our terms of service. These communications are strictly necessary and you may not opt out of them.
  • We use your personal information to link or combine user information with other personal information. An example is when we combine the information a company has provided about their shareholders with the information entered by shareholders in their personal portfolios to improve the user experience.
  • We use your personal information to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
  • We use your personal information to provide and deliver products and service customers requests. An example is when an employee exercises their stock options and we may provide a tax form to the company for their IRS reporting requirements.

Sharing of personal information

We may share personal information as follows:
  • We may share information per our customers’ instructions.
  • We may share personal information in compliance with any applicable law.
  • We may share personal information when we do or negotiate a business deal involving the sale or transfer of all or a part of our business or assets in which a successor or purchaser will be operating a similar business. These deals can include any merger, acquisition, or bankruptcy transaction or proceeding. Any such successor or purchaser (or recipient of information during negotiation or due diligence) will be required to comply with reasonable confidentiality restrictions with respect to personal information.
  • We may share personal information for legal, protection, information security, and safety purposes. Examples include enforcing contracts or policies, reporting on security breaches, or assisting with investigating and preventing fraud or security issues.
  • We may share customer and user access on the customer’s account. Equity administrators for the customer, authorized users and other designated representatives may be able to add, modify or restrict access. An example is the company administrator designates a legal administrator to issue new securities on behalf of the company.
  • We may share information to comply with laws and regulatory requests. Examples include responding to lawful requests and legal or regulatory processes.
  • We may share information to protect the rights and property of Carta, our agents, customers, and others. This includes enforcing our agreements, policies, and terms of use.
  • We may share information with those who need it to do work for us. An example is granting a Carta employee the necessary access in order to perform their duties.
  • We may share aggregated or anonymized data. We may disclose or use aggregated or anonymized data for any purpose. An example would be for marketing, analytics or research purposes.
  • We will not share personal information with investors of the Company beyond any personal information that such investors are entitled to for customary legitimate business purposes.
  • We may share other information with consent with third parties when we have consent to do so. We may engage third party companies or individuals as service providers to process information and support our services. An example would be cloud services for data center colocation and storage services.
  • Customers may authorize access to customer data to third parties. An example is when a company grants their financial auditors access for annual audits.

Legal Requirements

To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. What this means for you: we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents.

Age Limitations

To the extent prohibited by applicable law, Carta does not allow the use of our services and Site by anyone younger than 18 years old. If you learn that anyone younger than 18 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

Information choices and changes

Our marketing emails tell you how to “opt out.” If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you that are necessary for fulfilling our obligations to our customers.

You may send requests about personal information to our Contact Information below. You can request to change contact choices, opt-out of our sharing with others, and update your personal information.

You can typically remove and reject cookies from our website with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it may affect how our website works for you.

We strive to provide you the tools to update your personal information. If you are unable to correct inaccurate information on your own, you may request our assistance to update such information by contacting privacy@Carta.com.

Notice for Residents of the European and Swiss Economic Areas, Privacy Shield and Contractual Terms

Carta complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.  Carta has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

The following Carta subsidiaries also adhere to the Privacy Shield Principles: Carta Securities LLC, Carta Valuations LLC, and Carta Investor Services, Inc.

Carta is responsible for the processing of personal data we receive, and subsequently transfers to a third party acting as an agent on our behalf. Carta abides by the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including, unless we prove that we are not responsible for the event giving rise to the damage, the onward transfer of liability provisions.

Carta commits to cooperate with EU data protection authorities and the Swiss Federal Data Protection and Information Commissioner and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.

Carta is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Carta may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

EU or Swiss residents with inquiries or complaints regarding this Privacy Policy should first contact Carta at privacy@Carta.com. Please allow a reasonable amount of time to respond to your request. If you do not receive timely acknowledgement of your complaint, if your complaint is not satisfactorily addressed by Carta, or if you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

If these processes do not result in a resolution, you may then contact your local data protection authority, the U.S. Department of Commerce, and/or the Federal Trade Commission for assistance.

Under certain circumstances an arbitration option is available to you to determine, for residual claims, whether Carta has violated its obligations to you under the Privacy Shield Principles, and whether any such violation remains fully or partially unremedied.  This option is available only for these purposes. Please be advised that the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the resident.

Carta may transfer your Personal Data to countries other than the one in which you live. We deploy the following safeguards if Carta transfers Personal Data originating from the European Union or Switzerland to other countries not deemed adequate under applicable data protection law.

These frameworks were developed to enable companies to comply with data protection requirements when transferring personal data from the European Union and Switzerland to the United States. Carta offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our Customers that operate in the European Union, and other international transfers of Customer Data. A copy of our standard data processing addendum, incorporating Model Clauses, is available upon request to privacy@Carta.com.

Contact information

We welcome your comments or questions about this Privacy Policy. You may also contact us at our address:

eShares, Inc. DBA Carta, Inc. 195 Page Mill Road, Suite 101 Palo Alto, California 94306

Changes to this Privacy Policy

We may change this privacy policy. If we make any substantive changes related to how we collect or use data, we will change the content last updated date above. Other changes including grammar or spelling corrections will automatically update the timestamp at the bottom of this document.

Terms of Service

Welcome, and thank you for visiting Table Stakes by Carta! When you use our products and services, you’re agreeing to our terms, so please take a few minutes to read over the Terms of Service below.

Note: By registering as a user on www.tablestakes.com you are entering into a legally binding agreement with eShares, Inc. DBA Carta, Inc.

Terms of Service

These Terms of Service govern your access to and use of Carta at www.tablestakes.com (“Website”), as well as the information and materials on this Website (collectively, the “Content”). If you are a paying customer of our services, you are also subject to the terms of the Master Subscription Agreement located here. By accessing or using this Website, you agree that you have read, understood, and accept these Terms of Service, our Privacy Policy, and all other policies or notices posted by us on our Website. IF YOU DO NOT ACCEPT OR AGREE WITH THESE TERMS OF SERVICE, YOU MAY NOT ACCESS OR USE THIS WEBSITE OR CONTENT. This Website is operated by Carta. (“Carta” or “we” or “us”).

Carta reserves the right, at its sole discretion, to change, modify, add or remove portions of these Terms of Service, at any time. It is your responsibility to check these Terms of Service periodically for changes. Your continued use of the Website following the posting of changes will mean that you accept and agree to the changes. As long as you comply with these Terms of Service, Carta grants you a personal, non-exclusive, non-transferable, limited privilege to enter and use the Website.

Terms of Restrictions on Access and Use

You may use this Website provided that (i) you are over 18 years of age, (ii) you are using the Website for your own personal use, (iii) you do not copy the Website or any part of it, (iv) you do not modify the Website or any part of it, and (v) you comply with all applicable laws, rules, regulations, and court orders.

Carta or its suppliers retain all right, title and interest (including all copyright, trade secret, patent and other rights) in and to the Website and Content which is included in the Website. If you give feedback on the Website, for example recommendations for improvements or features, such feedback will be deemed non-confidential and non-proprietary, and implementation of that feedback is owned by us and may become part of the Website without compensation to you. We reserve all rights in and to the Website unless we expressly state otherwise. The Website contains proprietary and confidential information that is protected by applicable intellectual property and other laws.

All text, graphics, user interfaces, visual interfaces, photographs, trademarks, logos, sounds, music, artwork, and computer code, including but not limited to the design, structure, selection, coordination, expression, “look and feel” and arrangement of Content, contained on the Website is owned, controlled, or licensed by Carta, and is protected by trade dress, copyright, patent and trademark laws, and other various intellectual property rights and unfair competition laws.

Except as expressly provided in these Terms of Service, no part of the Website and no Content maybe be copied, reproduced, uploaded, posted, publicly displayed, encoded, translated, transmitted or distributed in any way (including mirroring) to any other computer, server, Web site or other medium for publication or distribution or for any commercial enterprise, without Carta’s express written consent.

You may download publicly-available Content on this Website only for your personal, non-commercial use, provided that: (i) you keep intact all copyright and other proprietary notices; and (ii) if your copying or use of copyrighted materials on this Website is other than “fair use” under federal copyright laws, you must seek permission directly from us.

Your access to and use of this Website and the Content may be terminated by us at any time without notice.

You may not do any of the following:

  • Violate any copyrights, and other proprietary or intellectual property rights in this Website or the Content;
  • Engage in any “data mining,” “deep-link,” “page-scrape,” or use “bots/spiders” or similar data gathering and extraction tools or methods in connection with this Website or the Content;
  • Decompile, reverse engineer, disassemble, lease, sell, distribute, or reproduce this Website;
  • Transmit, post, or otherwise make available: (a) content that is unlawful, false, inaccurate, harmful, obscene, or otherwise objectionable, including but not limited to any content that infringes on any intellectual property right or proprietary right; (b) viruses, Trojan horses or other harmful programs or material; or (c) not use any device, software or routine to interfere with the proper working of the Website, (d) advertising or promotional materials, “spam,” or any other form of solicitation;
  • Misrepresent your affiliation with or impersonate any person or entity;
  • Interfere with or disrupt this Website, including imposing an unreasonable or disproportionately large load on the infrastructure of the Website, or attempt to circumvent this Website’s security features;
  • Remove or modify any copyright notices, other proprietary notices, or references to these Terms of Service in the Content or on this Website;
  • Misrepresent the Content or this Website, or misinform others about the origin or ownership of the Content or this Website; and
  • Probe, scan, or test the vulnerability of the Website or any network connected to the Website, nor breach the security or other authentication measures on the Website or any network connected to the Website.

User Content

If you establish an account on this Website, you are responsible for maintaining the confidentiality of your user ID and password, and you are responsible for all activities that occur under your password or user ID. You agree to: (i) log out from your account at the end of each session; and (ii) immediately notify Carta at support@carta.com of any unauthorized use of your password or user ID or any other breach of security.

You are responsible for all content that you transmit or otherwise make available to this Website. Your access to and use of this Website may be monitored, including but not limited to, for the purpose of identifying illegal or unauthorized activities.

All personally identifiable information collected from you is governed by our Privacy Policy.

Sale of Services

We may offer for sale or download licenses to certain Carta products or services (“Services”). Your use of such Services will be subject to licensing terms applicable to such Services, or a separate written agreement between you and Carta. If you have previously purchased Services, those Services are subject to the terms and conditions of the Master Subscription Agreement located at https://carta.com/msa/.

Disclaimers and Limitation of Liability

THIS WEBSITE AND THE CONTENT ARE PROVIDED ON AN “AS IS,” “AS AVAILABLE” BASIS, AND MAY BE SUBJECT TO ERRORS, INACCURACIES OR OMISSIONS.

CARTA MAKES NO REPRESENTATIONS OR WARRANTIES REGARDING THIS WEBSITE OR THE CONTENT, INCLUDING BUT NOT LIMITED TO THEIR COMPLETENESS, ACCURACY, TIMELINESS, NON-INFRINGEMENT OF THIRD-PARTY RIGHTS, OR FREEDOM FROM COMPUTER VIRUSES. YOUR ACCESS TO AND USE OF THIS WEBSITE AND THE CONTENT ARE AT YOUR SOLE RISK. CARTA SHALL NOT BE RESPONSIBLE FOR ANY DAMAGES (INCLUDING BUT NOT LIMITED TO ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR EXEMPLARY DAMAGES), LOSSES, CLAIMS OR LIABILITY, KNOWN OR UNKNOWN (INCLUDING BUT NOT LIMITED TO LOSS OF PROFITS, GOODWILL, USE OR DATA), ARISING OUT OF THE USE OF (OR INABILITY TO USE) THIS WEBSITE, THE CONTENT, OR ANY THIRD-PARTY SITE LINKED TO THIS WEBSITE.

The above disclaimer applies to any damages liability or injuries caused by any failure of performance, error, omission, interruption, deletion, defect, delay in operation or transmission, computer virus, communication line failure, theft or destruction of or unauthorized access to, alteration of, or use, whether for breach of contract, tort, negligence or other cause of action.

Linking and Third Parties

This Website may include links to third-party sites, such as social media and file-sharing sites to distribute our Content. When you access these sites, you are subject to third-party terms of use and privacy/security policies, which we recommend that you review. We are not responsible for the accuracy, completeness, legality, practices, or availability of linked sites (including any related services, content, software applications, and other technologies). In addition, we are not responsible for any interruption of services, malfunctions, or security breaches involving these third-party sites. This product includes GeoLite2 data created by MaxMind, available from https://carta.com/msa/. References or links in this Website to any commercial products or services, or the use of any trade, firm or corporation name do not constitute endorsement by Carta.

General

These Terms of Service constitute the entire agreement with respect to your access to and use of this Website and the Content. For avoidance of doubt, Carta’s obligations, if any, with regard to its products and services are governed solely by the agreements pursuant to which they are provided, and nothing on this Website should be construed to alter such agreements.

You agree that Carta may, in its sole discretion and without prior notice, terminate your access to the Website and/or block your future access to the Website if we determine you have violated these Terms of Service or other agreements or guidelines which maybe be associated with your use of the Website. You also agree that any violation by you of these Terms of Service will constitute an unlawful and unfair business practice, and will cause irreparable harm to Carta, for which monetary damages would be inadequate, and you consent to Carta obtaining any injunctive or equitable relief that Carta deems necessary or appropriate in such circumstances. These remedies are in addition to any other remedies Carta may have at law or in equity.

If any provision of these Terms of Service is unlawful, void or unenforceable, then that provision will be deemed severable from the remaining provisions and will not affect their validity and enforceability. The failure by Carta to enforce any provision in these Terms of Service will not constitute or be construed as a waiver of such provision or of the right to enforce it at a later time. California law, without regard to conflict of laws provisions, will govern these Terms of Service and any matter or dispute arising out of this Website or the Content. The state and federal courts located in San Francisco, California will have exclusive jurisdiction over any dispute relating to these Terms of Service, this Website or the Content. We will have the right to use for any purpose, free of charge, all information or content submitted via this site except those submissions made under separate legal contract.

Finally, Carta may disclose any information we have about you (including your identity) if we determine that such disclosure is necessary in connection with any investigation or complaint regarding your use of the Website, or to identify, contact or bring legal action against Carta’s rights or property of visitors to or users of the Website, including Carta’s customers. Carta reserves the right at all times to disclose any information that Carta’s deems necessary to comply with any applicable law, regulation, legal process or governmental request. Carta may also disclose your information when Carta determines that applicable law requires or permits such disclosure, including exchanging information with other companies and organizations for fraud protection purposes.

If you have any questions about these Terms of Service, please contact us at support@carta.com.

Content last updated: March 6th, 2018.

Privacy Policy | © 2019 eShares Inc. dba Carta, Inc.