Effective July 1, 2025
Working Draft
This policy is a draft awaiting review and has not been released.
Who this covers
This policy explains what personal information Carbotura, Inc. (“Carbotura”, “we”) collects through carbotura.com, why we collect it, who handles it for us, and the choices you have. It covers the public pages and the sign-in areas of carbotura.com: the finance and investor area, deal rooms, and the agent portal. Carbotura’s other sites, such as community sites and the Circular Materials Catalog, carry their own notices. The rules for using the site are in our Terms of Use.
What we collect
This is what the site collects, by what you do on it.
- Page views. When a page loads, our own counter records which page and section it was, a random session identifier, the kind of referrer (direct, search, email, internal or other) and your approximate location (country, region and city), which Cloudflare works out from your connection. It records no name, no email address and no cookie. Cloudflare also provides its own privacy-first web analytics for the site.
- Forms you submit. The contact form collects what you type: name, company, role, email address, your message, the kind of organization you represent and, if you ask for a preliminary analysis, the jurisdiction. Event registrations collect your first and last name, email address, organization and role. With each submission we also keep your IP address, browser details and country, and the result of an automated bot check by Cloudflare Turnstile, so that we can stop abuse. A submission our checks flag as suspicious is still kept, but is not passed on to our team.
- The site guide. If you use the site guide, we keep your questions and its answers, the page you were on, your approximate location (country, region and city), a scrambled (hashed) form of your IP address, and your sign-in email address if you are signed in. The guide also keeps your conversation in your browser’s local storage, so it carries across pages. Your questions are sent to Anthropic, which runs the AI model that writes the answers.
- Restricted areas. To enter the finance and investor area or a deal room, we collect your email address and send you a one-time code; the agent portal uses a PIN we issue. If you request access we also keep the name, organization, role and message you give. We keep records of sign-in attempts, access requests, any confidentiality acknowledgement you give and the documents you open, including the IP address and browser details they came from. Invited reviewers who leave comments on pages are identified by their sign-in email.
- Fonts. Many pages load typefaces from Google Fonts, so your browser asks Google’s servers for them and Google sees your IP address and browser details.
- Video. The home page shows a video from YouTube, which is owned by Google. Nothing is requested from YouTube until you press play. When you do, your browser contacts YouTube, which sees your IP address and browser details and may set cookies under its own policy.
How we use it
We use personal information to answer your enquiry, run the event or briefing you registered for, give you access to the restricted area you asked for, keep the site secure and free of abuse, and understand in aggregate which pages are useful. We use the site guide’s conversations to answer you and to check that the guide answers accurately.
We do not sell personal information. We do not use it for advertising, and we do not build advertising profiles or track you across other websites.
Who handles it for us
These service providers process information for us, under their own terms, and only for the purposes above. We also share information where the law requires it, and with a successor if the business is sold or merged.
- Cloudflare hosts and protects the site, runs the bot check and the sign-in gate for restricted tools, and provides web analytics.
- Resend delivers the emails we send you: one-time codes, registration confirmations, event reminders and replies.
- Attio is our customer relationship tool. Contact and registration details are recorded there so that we can follow up.
- Microsoft delivers internal notifications to our team in Teams when a form is submitted.
- Anthropic runs the AI model behind the site guide.
- Google serves the typefaces.
Cookies
We do not use advertising or tracking cookies, and our page-view counting uses none. The sign-in areas set a session cookie so that you stay signed in. Cloudflare, which protects and delivers the site, may set a security cookie to tell people from automated traffic, and signed-in reviewers carry a Cloudflare Access cookie. Separately, your browser’s session storage holds a random identifier for our page-view counter until you close the tab, and the site guide keeps your conversation in local storage. You can clear both in your browser settings.
How long we keep it
We keep personal information for as long as we need it for the purposes above and to meet legal and accounting obligations. You can ask us to delete it, and we will unless we are required to keep it. Records of who accessed a restricted document and under what terms are kept for as long as the access terms require.
Your rights
Depending on where you live, you can ask us to give you a copy of the personal information we hold about you, to correct it, to delete it, to restrict how we use it, or to send it to you in a portable format. You can object to a use of it, withdraw a consent you gave, and ask us to stop sending you event reminders. To use any of these rights, write to privacy[at]carbotura.com, or use the contact form, and say which right you want. We will confirm it is you before acting, and we will answer within 30 days. If you are not satisfied with our answer, you can complain to the data protection regulator where you live.
Residents of California and some other US states have specific rights over their personal information. We do not sell it or share it for cross-context advertising, so there is nothing to opt out of, and we will not treat you differently for using a right. If you are outside the United States, your information is processed in the United States, where our service providers operate.
Security
Restricted areas require a sign-in, and access to them is logged. Information moves over encrypted connections, and we limit access to personal information to the people at Carbotura who need it to do their work. If a breach of personal information is likely to put your rights at risk, we will tell the people affected and the authorities, as the law requires. No system is perfectly secure, so please do not send us sensitive personal information such as government identification numbers or health information through the contact form or the site guide.
Children
The site is meant for businesses, governments, investors and the people who work for them. It is not directed at anyone under 16, and we do not knowingly collect their personal information. If you think a child has given us personal information, tell us and we will delete it.
Changes and contact
We will post any change to this policy on this page and show the date of the change at the top. Where a change materially affects people whose contact details we hold, we will also tell them by email. For questions about this policy, write to privacy[at]carbotura.com or use the contact form. Legal notices go to legal[at]carbotura.com.