Privacy Policy

Cartesian FinOp Partners, LLC (“Cartesian”) values your privacy. To learn more about what personal and user data Cartesian collects, uses, retains, and shares; how we protect your personal data; and what choices and means of control you have over your personal data, please read this statement (the “Privacy Policy”) in its entirety.

This Privacy Policy was last updated on: September ___, 2024.

1. Applicability of this Privacy Policy

This Privacy Policy describes Cartesian’s privacy practices with respect to data collected in connection with our customer services, sales and marketing activities, and this website.

This Privacy Policy applies to information we collect:

• On this website.
• In email, text, and other electronic messages between you and Cartesian via the website or other means.
• When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this Privacy Policy.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by any third party (including our affiliates and subsidiaries); or
• Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or through Cartesian’s website.
• To Cartesian employee data practices.

Please also note that certain Cartesian websites, or software experiences may have links to third-party websites or services. In most cases, those third-party resources are subject to the privacy practices and policies of those third parties and not Cartesian.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use Cartesian’s website. By accessing or using Cartesian’s website, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see “Changes to Our Privacy Policy”). Your continued use of Cartesian’s website after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

2. Types of Personal Data Collected and Use of Such Personal Data

Cartesian may collect certain categories of data about you when you use our websites; use our services; receive our marketing communications; interact with us; and in other contexts. The data we currently collect, or may collect in the future, can be broadly categorized as follows:

• Personal Data: This is individually identifiable data that you may choose to provide us. This may include basic information such as your email address and phone number, or more sensitive information such as your full date of birth or your payment information.
• User Data: This is data that we may collect from users of our services. User data could include personal data such as a unique user ID or account username and password, but sometimes this user data is anonymous or “pseudonymous,” i.e., certain user data that could be made identifiable if associated with personal data.
• Location Data: This is data we collect that helps us determine a location based on your IP address in order to customize our services and for other uses consistent with this Privacy Policy.

Cartesian has various uses for your personal and user data you provide to us. Here are the principal contexts in which we may use, retain, and share your personal and user data:

• Websites and Account Management: Most often, you may browse our websites without providing any personal data to us. However, if you choose to establish a user account with Cartesian, engage in e-commerce, sign up for marketing communications, or interact with our customer service teams or participate in a forum on our website, we will likely need to collect some personal or user data from you. In addition, our web servers automatically collect certain data by default, such as IP addresses and other activity logs. This type of data is used for website security and site improvement purposes. Much of that data is not readily identifiable and is usually kept anonymous. In order to maintain and improve our websites, Cartesian currently uses, or may in the future use, third-party hosting, content management, and security partners, vendors, and suppliers.
• Sales: If you decide to purchase a service from Cartesian, we will need to collect certain personal data from you, including payment-related information. Typically, we use third-party partners, vendors, and suppliers, such as payment processing companies during our sales.
• Marketing & Social Media: You may choose to receive Cartesian marketing communications, participate in an event/contest/promotion with us, or connect with Cartesian via social media. If you do so, we will collect certain personal data about you, such as your contact information, social media profile information and, in order to determine your eligibility for a contest or promotion, your full or partial dates of birth. Cartesian may share your personal data with our marketing agencies and partners to carry out our marketing campaigns, contests, and promotions. If you wish to unsubscribe from our marketing, please follow the opt-out link in the communications you receive from us; update your contact preferences in your Cartesian account settings, if applicable; or email us at info@cartesian.com.
• Product Registration: If you use Cartesian services, you may choose to establish a Cartesian user account, if applicable. A Cartesian user account profile may include your username, password, settings, preferences, contact information, device ID information, and related data. Cartesian may share this information with other Cartesian subsidiaries, affiliates, vendors, and suppliers, such as third-party hosting partners. Certain Cartesian product settings, preference information, applications history, and location-based information may be used by Cartesian product development and improvement and customer service teams if you choose to enable enhanced customer support services.
• Customer Service & Support: If you choose to interact with Cartesian customer service and support – whether it be via our website, social media, chat, email, or phone – Cartesian customer service teams (some of whom work for outsourced vendors and suppliers of Cartesian) may have access to your account information, product information, contact information, and payment information. You may also be required to answer certain security questions to verify your identity and your call or session with Cartesian customer support may be recorded for quality and training purposes.
• Job Opportunities: You may choose to apply for employment opportunities at Cartesian through Cartesian’s website. If you complete an application for a job at Cartesian, we may collect your contact information, job history info, and certain other information that may be required or allowed under applicable laws to screen candidates for employment. We may share this information with other Cartesian subsidiaries, affiliates, vendors, and suppliers who provide us with candidate search and hiring services.

The following table provides further information on some of the specific types of personal or user data we may collect from you, how we use it, and with whom we may share it:

3. Cookies and Related Technologies

Cookies are small pieces of data that are sent to your browser from a web server and stored on your computer. Websites, including Cartesian’s sites, use cookies to help remind us who you are when you visit our site; to help you navigate our site during your visits; and to save preferences and shopping cart contents for you so you will not have to re-enter them.

Cartesian may also use cookies to store and help track information about you, including for online advertising purposes and specifically to determine which interest-based ads to display. Where required by applicable law, Cartesian will acquire consent from you prior to using certain cookies during your Cartesian website experience or will offer you the opportunity to choose which types of cookies to enable or disable. To review or change your cookie preferences on our site, please click here.

To serve and manage cookies, and related technologies such as tags and website data analytics tools, Cartesian may use products and services hosted by companies such as Google, Facebook, and Twitter. These services may collect information, such as your IP address, sent by your browser or via cookies.

We do not control third-party cookies or how they are used. The use of such cookies is relatively standard. Most browsers are initially set up to accept them. However, if you prefer not to store cookies, you can choose to:

• not use our sites
• set your browser to notify you when you receive a cookie
• set your browser to refuse to accept cookies
• update or change your cookie preferences through our website tool here
• delete our cookies after visiting our site
• browse our site using your browser’s anonymous usage setting (e.g., “Incognito” mode in Chrome)

You should also understand that some features of the Cartesian website might not function properly if you do not accept cookies.

If you do not know how to control or delete cookies or would like to opt-out of receiving certain targeted ads based on your browsing history, you may wish to visit Network Advertising, About Ads, or Your Online Choices for detailed guidance, including opt-out instructions.

If you would like to opt-out of certain third-party supported Internet advertising and behavioral targeting services, please visit any of the following:

• Google
• Facebook
• Twitter
• Adobe Marketing Cloud

For additional information: Consumer FTC

4. Personal Data of Children Under 18

Cartesian’s websites, products and services are intended for adults aged 18 and older. If we learn we have collected or received personal information from a child under 18, we will take the appropriate steps to delete and purge that information. If you believe we might have any information from or about a child under 18, please contact us at info@cartesian.com.

5. Retention of Your Personal Data

Cartesian intends to retain personal data only as long as necessary to complete the purposes of use described above in Section 2. When those purposes have been fulfilled, we will securely delete personal data as appropriate. However, we may retain your personal data as long as any of the following circumstances apply:

• Your Cartesian account or marketing subscription is active
• To provide you with services or support that you have requested
• To comply with applicable laws, including for tax and audit purposes
• To enforce Cartesian’s rights, including litigation and debt collection

6. Disclosing or Selling Your Personal Data

We may disclose aggregated information about our user and information that does not identify any individual, without restriction.

We may disclose personal information that we collect, or you provide as described in this Privacy Policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Cartesian’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Cartesian about our website users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms found in any service agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Cartesian, our customers, or others.

While Cartesian may share personal data it collects pursuant to the purposes described above and in Section 2, Cartesian does not sell personal data. If Cartesian did decide to sell personal data at any point, we would provide appropriate notice and consent mechanisms to individuals as required by applicable laws.

In addition, please note that if Cartesian or any of its businesses or operations were to be sold to another entity at any point, that sale could involve the transfer of personal data held by Cartesian to the acquiring organization. In such a circumstance, Cartesian would provide appropriate notice and consent mechanisms to individuals as required by applicable laws.

7. Transfer of Personal Data Across Borders

Cartesian may collect, process, use, retain and transfer personal data across borders in order to fulfill our purposes of use as described above in Section 2. This may include transfers of personal data to countries that may not have equivalent privacy or data protection laws to those in your own country.

However, regardless of where we transfer personal data to, Cartesian takes appropriate steps to ensure that your personal data enjoys consistent standards of care. This includes signing contracts between Cartesian affiliates and with our vendors and suppliers to make sure that both parties are following consistent privacy and security principles, processes, and protections.

For transfers involving European personal data, Cartesian uses Standard Contractual Clauses with its partners.

8. Protection of Your Personal Data

Cartesian believes that privacy and security go hand-in-hand. We use appropriate physical, technical, and administrative controls to protect the personal data we are responsible for. That includes encryption and other enhanced security measures, where appropriate or required. We also take appropriate steps to make sure that our vendors, suppliers, and certain other partners adopt consistent standards of protection for the personal data that Cartesian is responsible for.

However, it is important to note that no technology is guaranteed to be invulnerable to threat or attack. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the website like message boards. The information you share in public areas may be viewed by any user of Cartesian’s website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. Therefore, please be sure to exercise care when using any website or product. If technology you use is configured with privacy or security controls or features, please be sure to utilize those.

9. Correcting, Amending, or Deleting Your Personal Information

If you have a Cartesian account, you may have the ability to review, correct, amend, or delete your personal data through your account profile. To do so, please visit your account and click on “Settings.”

In addition, under this Privacy Policy and certain applicable laws, you may submit a request to Cartesian to review, correct, amend or to delete your personal data that Cartesian has about you. You may also have the right to request a machine-readable copy of your personal data. To submit such a request to Cartesian, please contact us at info@cartesian.com.

Please note that we will review, respond to and act upon such requests as soon as possible and in accordance with applicable laws. We are also required to verify your identity before granting you access to your personal data. If you have a Cartesian account, we may verify your identity by requiring you to sign into your account. If you do not have a Cartesian account, or an email address on file with us, then we may request additional limited information from you in order to verify your identity. Please note that if you do not have an account with Cartesian, or an email address on file, or if we are unable to verify your identity in our records, we may deny your request.

You may also use an authorized agent to submit a request under this section on your behalf. If you choose to have an authorized agent submit such a request on your behalf, Cartesian will require: (i) You to provide the authorized agent written permission to do so; and (ii) your agent to verify their identity directly with Cartesian. Cartesian may deny a request from an agent that does not meet these requirements.

In addition, you have the right to raise questions or complaints with your applicable national data protection authority at any time.

Please note we may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

10. Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on Cartesian’s website home page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the website home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our website and this Privacy Policy to check for any changes.

11. Contact Cartesian

If you have any additional questions, complaints, or concerns regarding privacy at Cartesian. Please feel free to reach us at info@cartesian.com.