Legal
Privacy Policy
Last updated: March 15, 2026 · Earlyasset, Inc.
This Privacy Policy describes how Earlyasset, Inc. ("Earlyasset," "we," "us," or "our") collects, uses, and shares information in connection with SecondaryOS (the "Platform"), a product operated by Earlyasset, Inc. By accessing or using SecondaryOS, you agree to the practices described in this policy.
1. Who We Are
SecondaryOS is a platform operated by Earlyasset, Inc., a Delaware corporation. Earlyasset, Inc. is the data controller for personal information collected through SecondaryOS. Our principal place of business is in the United States.
2. Information We Collect
Information you provide directly
When you join our waitlist or interact with the Platform, we may collect:
- First and last name
- Work email address
- Company name
- Job title or role
- Information about the urgency or nature of your shareholder liquidity needs
- Any other information you choose to provide in correspondence with us
Information collected automatically
When you visit our website, we may automatically collect:
- IP address and approximate geographic location
- Browser type, operating system, and device information
- Pages visited, time spent on pages, and referring URLs
- Cookies and similar tracking technologies (see Section 6)
3. How We Use Your Information
We use the information we collect for the following purposes:
- Waitlist management — to record your interest in SecondaryOS and contact you before and at launch
- Platform onboarding — to set up your company's account and configure your secondary transaction page when the Platform launches
- Communications — to send product updates, launch announcements, and relevant information about the secondary market
- Service improvement — to understand how visitors interact with our site and improve the Platform experience
- Legal compliance — to comply with applicable laws, regulations, and legal obligations
- Security — to detect and prevent fraud, abuse, and other harmful activity
We do not use your information for automated decision-making or profiling that produces legal or similarly significant effects.
4. How We Share Your Information
We do not sell, rent, or trade your personal information to third parties for their marketing purposes. We may share your information in the following limited circumstances:
- Service providers — with vendors who help us operate the Platform (such as email delivery, hosting, and analytics providers), who are contractually required to protect your information
- Affiliates — with Earlyasset Capital and other affiliates within the Earlyasset, Inc. family of companies, for purposes consistent with this policy
- Legal requirements — when required by law, subpoena, or other legal process, or to protect the rights, property, or safety of Earlyasset, Inc., our users, or the public
- Business transfers — in connection with a merger, acquisition, or sale of all or a portion of our assets, in which case your information may be transferred as a business asset
5. Legal Basis for Processing (EEA/UK Users)
If you are located in the European Economic Area or United Kingdom, we process your personal information on the following legal bases:
- Consent — when you join our waitlist or sign up for communications
- Legitimate interests — to operate and improve the Platform, prevent fraud, and communicate with prospective customers
- Legal obligation — where processing is necessary to comply with applicable law
6. Cookies and Tracking Technologies
We use cookies and similar technologies to operate our website, remember your preferences, and understand how visitors use our site. You can control cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the site.
We may use third-party analytics tools (such as Google Analytics) to collect aggregated usage data. These tools have their own privacy policies governing how they use that data.
7. Data Retention
We retain your personal information for as long as necessary to fulfill the purposes described in this policy, including to maintain your place on our waitlist, to operate and improve the Platform, and to comply with our legal obligations. If you request deletion of your data, we will remove your information within 30 days, subject to any legal retention requirements.
8. Your Rights and Choices
Depending on your location, you may have the following rights with respect to your personal information:
- Access — request a copy of the personal information we hold about you
- Correction — request that we correct inaccurate or incomplete information
- Deletion — request that we delete your personal information
- Opt-out of communications — unsubscribe from marketing emails at any time using the link in any email we send
- Data portability — request your data in a portable format (where applicable)
- Restriction or objection — request that we restrict processing or object to processing based on legitimate interests
California residents may have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information is collected and to opt out of any sale of personal information (note: we do not sell personal information).
To exercise any of these rights, please contact us at contact@earlyasset.com.
9. Data Security
We implement industry-standard technical and organizational measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction. However, no transmission over the internet is completely secure, and we cannot guarantee the absolute security of your information.
10. Children's Privacy
SecondaryOS is intended for use by businesses and their authorized representatives. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that we have collected information from a minor, we will delete it promptly.
11. Links to Third-Party Sites
Our website may contain links to third-party websites, including earlyasset.com and earlyassetcapital.com. These sites have their own privacy policies, and we are not responsible for their privacy practices.
12. Changes to This Policy
We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date at the top of this page. If we make material changes, we will notify you by email (if you are on our waitlist) or by posting a prominent notice on our website. Your continued use of the Platform after any changes constitutes acceptance of the updated policy.
13. Contact Us
If you have questions or concerns about this Privacy Policy or our data practices, please contact us at:
Earlyasset, Inc.
Attn: Privacy
contact@earlyasset.com