Privacy Policy

1. Introduction

Earlyasset, Inc. ("the Company," "we," "us," or "our") operates eariyasset.com (the "Service"). We provide AI-generated share pricing reports and liquidity support for private-company equity to employees, founders, secondary buyers, and institutional equity holders seeking market-referenced pricing for private or pre-IPO shares. This Privacy Policy describes the personal information we collect, how we use it, and your available choices. It covers information collected through the Service and through direct communications with us.

As a financial information service, the Company may receive nonpublic personal financial information covered by the Gramm-Leach-Bliley Act (GLBA) when you request a pricing report or liquidity transaction. See Section 9.3 for GLBA-specific rights.

The Company is located at 48 Wall Street, Floor 11, New York, NY 10005. Contact us at [email protected].

2. Information We Collect

2.1 Information You Provide

We collect information you provide directly, such as:

• Contact details, including name, email, and phone, when you register, request a valuation report, or contact us;
• Share position information for pricing, including the company name, share class, position size, approximate grant or purchase date, and current holding-period context;
• Transaction details, such as whether you are considering a secondary sale, joining a tender offer, or seeking portfolio marks for fund reporting;
• Institutional account details, such as fund name, role, and assets-under-management context, if provided;
• The contents of messages, support requests, and forms you submit to us.

We use share position details and transaction context submitted for a pricing report only to produce that report. The Company does not use individual valuation submissions to train AI models. Our pricing AI is trained using aggregated market signal data, including secondary transaction data, funding round filings, and comparable exit records, independently of user submissions.

2.2 Information Collected Automatically

When you visit eariyasset.com, we automatically collect limited technical information:

• IP address and approximate city- or region-level location;
• Browser, operating system, and device type;
• Pages visited, referring URLs, time on page;
• Cookies and similar identifiers; see Section 5 and our Cookie Policy.

2.3 We Do Not Knowingly Collect Children's Data

eariyasset.com is not intended for children under 13, and we do not knowingly collect their personal information. If you believe a child has submitted information to us, contact [email protected]. We will promptly delete it.

3. How We Use Information

We use collected information to:

• Create an AI-generated share pricing report for the position details you provide;
• Provide buyer matching and transaction support through the Liquidity tier when you choose that service;
• Run, maintain, and improve the Service, including pricing model accuracy through aggregated, de-identified market signal data;
• Answer questions, provide support, and send service-related communications;
• Send marketing messages with your consent when required, subject to your right to opt out;
• Detect, investigate, and prevent fraud, unauthorized access, and Service misuse;
• Meet applicable legal and regulatory obligations, including GLBA Safeguards Rule requirements.

We do not sell personal information for monetary value. If state law treats certain advertising arrangements as a "sale" or "share," see your state's section below.

4. Sharing of Information

We share personal information with only:

• Service providers that work for us, such as cloud hosting, email delivery, and analytics providers, under contracts limiting their use of your information to those services;
• Prospective buyers in our network, only when you select the Liquidity tier and agree to deal-flow matching;
• Regulators or courts when required by law or legal process, or when needed to protect the rights, safety, or property of the Company or others;
• A successor entity after a merger, acquisition, or asset sale, subject to this Policy.

We do not sell personal information to third parties. Share position details provided for a pricing report are not disclosed to anyone other than the personnel and systems needed to create and deliver that report.

5. Cookies and Tracking

We use cookies and similar technologies to provide the Service, remember preferences, and measure use. We do not currently use third-party advertising or behavioural tracking cookies. See our Cookie Policy for details and available choices.

6. Data Retention

We keep pricing report submissions for 24 months after delivery to address support requests, maintain audit trails, and meet applicable recordkeeping obligations. Account profile information remains while your account is active and for 24 months after the last activity. Server access logs remain for 90 days and are then aggregated. Inactive marketing contacts are purged after 24 months. You may request earlier deletion, subject to Section 8 and applicable sector-specific obligations.

7. Security

We maintain administrative, technical, and physical safeguards intended to protect personal and financial information. These include TLS encryption in transit, restricted-access databases, least-privilege access controls, and measures addressing the GLBA Safeguards Rule. No system is completely secure, and we cannot guarantee protection from every threat.

8. Your General Rights

Your rights may depend on your jurisdiction and may include access, correction, deletion, and limits on certain processing. Send requests to [email protected]. We will respond within the period required by applicable law and may verify your identity before acting on certain requests.

9. New York Residents

New York does not currently have a comprehensive consumer privacy statute. As a matter of policy, the Company extends the following baseline rights to all U.S. residents regardless of state of residence.

9.1 Baseline Rights

• Right to Know: request the categories of personal information we have collected about you.
• Right to Delete: request deletion of personal information you have provided.
• Right to Correct: request correction of inaccurate personal information.
• Right to Opt Out of Marketing: unsubscribe from marketing emails or opt out via the link in each marketing message.

9.2 How to Exercise

Email [email protected] with a description of your request and enough detail for us to verify your identity. We respond within 45 days.

9.3 Sector-Specific Rights

If you are protected by federal sector laws, including the Gramm-Leach-Bliley Act (GLBA) with respect to nonpublic personal financial information you submit to Earlyasset in connection with a pricing report or Liquidity transaction, those laws may give you additional rights with respect to data covered by them. To request our GLBA Privacy Notice or to exercise opt-out rights under GLBA, contact [email protected].

9.4 California Visitors

If you are a California resident visiting from another state, you may also exercise the rights granted under the California Consumer Privacy Act ("CCPA") and California Privacy Rights Act ("CPRA"), including the right to know, the right to delete, the right to correct, and the right to opt out of sale or sharing. We do not sell personal information and do not "share" personal information for cross-context behavioural advertising.

To submit a CCPA/CPRA request, email [email protected] with the subject line "California Privacy Request."

10. Changes to This Policy

We may revise this Policy periodically. We will identify material changes with a new "Last updated" date and, when appropriate, a notice on the Service.

11. Contact

Send questions, requests, or complaints about this Policy to: