Privacy Policy

1. Who We Are

SecondaryOS is a software product operated by Earlyasset, Inc., a Delaware corporation ("Earlyasset," "we," "us," or "our"). Our registered address is on file with the State of Delaware. If you have questions about this policy, contact us at shawn@earlyasset.com.

This Privacy Policy explains what information we collect when you visit secondaryos.com, join our waitlist, or interact with the SecondaryOS platform, and how we use and protect that information.

2. Information We Collect

Information you provide directly

• Waitlist registration: First name, last name, company name, job title, work email address, and estimated timeline for needing secondary transaction support.
• Certificate of Incorporation upload: If you upload a Certificate of Incorporation (COI) to add your company to our database, we collect the document and the company name associated with it.
• Communications: If you contact us by email, we retain those messages and your contact information.

Information collected automatically

• Usage data: We may collect standard web analytics data including pages visited, time on site, browser type, and referring URL through services such as Google Analytics or similar tools.
• Log data: Our hosting provider (Netlify) may log IP addresses, request timestamps, and other standard server log information.

Information we do not collect

We do not collect payment information. We do not require account creation on the current site. We do not knowingly collect information from individuals under 18 years of age.

3. How We Use Your Information

• To contact you about your waitlist registration and notify you when SecondaryOS launches.
• To build and verify your company's profile in our database.
• To respond to your questions or requests.
• To improve the SecondaryOS platform and website.
• To comply with applicable legal obligations.

We will not send you unsolicited marketing communications unrelated to SecondaryOS without your consent. You may opt out of any email communications at any time by replying "unsubscribe" to any message or by contacting us directly.

4. How We Share Your Information

We do not sell your personal information. We do not share your information with third parties for their own marketing purposes. We may share information in the following limited circumstances:

• Service providers: We use third-party services to operate the site and manage communications (including Netlify for hosting and form processing). These providers process data only on our behalf and under our instructions.
• Legal requirements: We may disclose information if required by law, court order, or government authority, or to protect the rights, property, or safety of Earlyasset, our users, or the public.
• Business transfers: If Earlyasset is acquired or merged with another company, your information may be transferred as part of that transaction. We will notify you via email or prominent notice on the site before your information becomes subject to a different privacy policy.

5. Data Retention

We retain your information for as long as necessary to provide the services described in this policy and to comply with our legal obligations. Waitlist information is retained until SecondaryOS launches and you have had a reasonable opportunity to create an account, or until you request deletion. You may request deletion of your information at any time by contacting shawn@earlyasset.com.

6. Your Rights

Depending on where you are located, you may have the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you.
• Correction: Ask us to correct inaccurate or incomplete information.
• Deletion: Request that we delete your personal information.
• Opt-out: Opt out of marketing communications at any time.

To exercise any of these rights, contact us at shawn@earlyasset.com. We will respond within 30 days.

California residents: Under the California Consumer Privacy Act (CCPA), you have additional rights including the right to know what personal information is collected, the right to know whether your personal information is sold or disclosed, the right to opt out of the sale of personal information (we do not sell personal information), and the right to non-discrimination for exercising your CCPA rights.

EEA/UK residents: If you are located in the European Economic Area or the United Kingdom, you may have rights under the General Data Protection Regulation (GDPR) or UK GDPR, including the rights listed above plus the right to data portability and the right to lodge a complaint with a supervisory authority. Our legal basis for processing your information is your consent (for communications) and our legitimate interests in operating and improving our business.

7. Cookies and Tracking

Our website may use cookies or similar tracking technologies for analytics and to improve user experience. You can control cookie settings through your browser. Disabling cookies may affect some site functionality. We do not use cookies for advertising or to track you across other websites.

8. Security

We take reasonable technical and organizational measures to protect your information against unauthorized access, alteration, disclosure, or destruction. Our site is served over HTTPS. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

9. Links to Other Sites

Our site contains links to third-party websites including earlyasset.com and earlyassetcapital.com. This Privacy Policy applies only to secondaryos.com. We are not responsible for the privacy practices of any third-party sites.

10. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date at the top of this page. For material changes, we will provide more prominent notice (such as an email to waitlist members). Your continued use of SecondaryOS after any changes constitutes your acceptance of the updated policy.

11. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact: