Privacy Policy

Last Updated: March 19, 2025

At Ethena, we value your privacy. This Privacy Policy describes the privacy practices of Ethena, Inc. (“Ethena”, “we” or “us”) and applies to the information we collect about you when you use our website and online services (collectively, the “Services”), or when you otherwise communicate with us.

Please note that this Policy does not apply to the information we process on behalf of our customers via our compliance training platform and services (which we process as a data processor pursuant to our customer agreements), but it does apply to the information we collect about the admin users that use those services on behalf of our customers.

Also, note that our Services are designed for business customers, and the personal information we collect under this Policy is typically collected in a commercial or employment context. As a result, certain exemptions or limitations may apply under various U.S. state comprehensive privacy laws (other than California’s CCPA) regarding the processing of such information.

COLLECTION OF INFORMATION

Information You Provide to Us

We collect information when you register for an admin account, request a demo or to talk to our sales team, fill out a form or a survey, attend a webinar or event, make a purchase, request customer support, access resources or content on our website (like a template or checklist), or otherwise communicate with us. The information you may provide includes your name and contact information (including email, phone, and address), company information (including name and job title), social media handles, account username and password, payment method information, and any other information you choose to provide us.

Automatically Collected Information

When you use our Services or contact us by phone, we collect the following information about you:

Device, Usage, and Activity Information: We collect information about how you access our Services, including data about the device and network you use (such as your hardware model, operating system version, IP address, unique device identifiers, browser type, and app version). We also collect information about your activity on our Services, including the route by which you access our Services, access dates and times, browsing behavior (such as pages viewed and links clicked), and information about your activity on specific pages.
Customer support recordings: If you contact customer support, we may monitor or retain any recordings of those conversations in accordance with applicable law.
Transactional Information: When you make a purchase of our Services, we collect information about the transaction.
Information Collected by Cookies and Similar Tracking Technologies: For information about cookies and other tracking technologies we use, and options to disable them, please see our Cookie Policy.

Information We Generate

We generate some information about you based on other information we have collected. For example, like many platforms, we use your IP address to derive the approximate location of your device. We also take notes and observations about the business contacts of our customers to help evaluate sales opportunities.

Information We Collect from Other Sources

We also obtain information about you from third-party sources, including from companies we partner with to sponsor events, public databases, and other third parties from whom we have purchased data. For instance, we receive information about contacts of potential customers through other sites that help manage and distribute our content or webinars, from data analytics and marketing services, and through online social networks made available on our Services (such as when you click “Share This” using social media buttons or plug-ins). This information may include name, contact information (including email and phone), job title, and company.

USE OF INFORMATION

We use the information we collect to:

Provide, maintain and improve our Services, and develop new products and services.
Process transactions and send you related information, including confirmations and invoices.
Evaluate sales leads and identify contacts for new customers.
Send you technical notices, security alerts, account notifications, and other administrative messages.
Respond to your comments, questions, and customer support requests.
Communicate with you about content, services, and events offered by Ethena and others, and provide news and information we think will be of interest to you.
Monitor and analyze trends, usage, and activities in connection with our Services.
Detect, investigate and prevent security incidents or other malicious, deceptive, fraudulent, or illegal activities and protect the rights, health, safety and property of Ethena and others.
Personalize your online experience and the advertisements you receive, including by targeting advertisements to you on third-party platforms and websites.
Protect our company and others, such as to detect, investigate, and activities that are illegal or violate our policies, exercise a legal claim, and comply with applicable laws and regulations.
Comply with our legal and financial obligations.

DISCLOSURE OF INFORMATION

We disclose information about you as follows or as otherwise described in this Privacy Policy:

With vendors, professional advisors, and contractors that perform services for us, including web and application hosting, cloud providers, email services, customer relationship management, payment processing, fraud prevention, reporting and analytics, marketing and advertising, and other services.
In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of Ethena or others.
In connection with, or during negotiations of any merger, sale of company assets, reorganization, financing or acquisition of all or a portion of our business by another company or similar corporate transactions.
Between and among Ethena and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership for use consistent with this Privacy Policy.
With your consent or at your direction.

We may also disclose aggregated, anonymous or, where permitted by law, de-identified information that cannot reasonably be used to identify you. We will not attempt to re-identify such information, except as permitted by law.

ADVERTISING AND ANALYTICS

We engage others to provide analytics services, serve advertisements, and perform related services for us. To do this, we and these partners may use cookies, pixels, and similar technologies to collect information about your use of our Services, including your device identifiers, IP address, web browser and mobile network information, pages viewed, time spent on pages, links clicked, purchase information and conversion information. This information is used to deliver advertising targeted to you on other companies’ websites and online services, understand the effectiveness of this advertising, analyze and track data, determine the popularity of certain content, and better understand your activity.

In addition to ad targeting activities that rely on cookies and similar technologies, we work with advertising partners to translate other identifiers, such as your email address or phone number, into a unique identifier (called a hashed value) that such partners can then use to show personalized ads to you across other websites and online services.

Some of the activities described in this section may constitute “sharing,” or “selling” under California privacy law that are subject to your right to opt-out. See the Information for California Residents section below for details.

You can also learn more about interest-based ads, or opt out of having your web browsing information used for behavioral advertising purposes by companies that participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices or www.youronlinechoices.eu (if you reside in Europe) or https://youradchoices.ca (if you reside in Canada). Your device may also include a feature that allows you to opt out of having certain information collected through mobile apps used for behavioral advertising purposes.

YOUR CHOICES

Account Information

You may update certain account information you provide via our Services (such as your name and email address) by logging into your admin account, but note that we retain certain information when required or permitted by law.

Promotional Communications

You may opt out of receiving promotional messages from Ethena by following the instructions in those messages. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

Cookies and Similar Tracking Technologies

We use cookies and similar tracking technologies, as described above. You can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect some of the functionality of our Services.

INFORMATION FOR CALIFORNIA RESIDENTS

This section provides additional disclosures required by the California Consumer Privacy Act (“CCPA”). If you reside in California, this section applies to you and describes our data practices today and in the preceding 12 months.

Our Privacy Policy explains how we collect, use, and disclose information about you, as well as our targeted advertising and analytics practices. We use the tables below to provide a summary of this same information. As described in the Collection of Information section above, we collect personal information from various sources, including directly from you, automatically when you access or use our Services, and from third-party sources.

Use and Disclosure of Personal Information for Business Purposes

CATEGORIES OF PERSONAL INFORMATION	CATEGORIES OF RECIPIENTS	USE OF PERSONAL INFORMATION
Identifiers, such as name, device IDs and contact information Professional or employment-related information and education history, such as company name and title Internet or other network activity information, such as web browsing activities Audio, visual, or similar information, such as customer support recordings Inferences, such as approximate location Commercial or transactional information, such as items purchased	Analytics providers Cloud storage providers Customer relationship management providers Communications providers Marketing and advertising partners Payment processing and fraud prevention providers Customer support providers Government authorities Other parties with whom you choose to share your information or provide consent to do so	Provide, maintain and improve our Services, and develop new products and services Process transactions and send you related information, including confirmations and invoices Evaluate sales leads and identify contacts for new customers Send you technical notices, security alerts, account notifications and other administrative messages Respond to your comments, questions, and customer support requests Communicate with you about content, services, and events offered by Ethena and others, and provide news and information we think will be of interest to you Monitor and analyze trends, usage, and activities in connection with our Services Detect, investigate and prevent security incidents or other malicious, deceptive, fraudulent, or illegal activities and protect the rights, health, safety and property of Ethena and others Personalize your online experience and the advertisements you receive, including by targeting advertisements to you on third-party platforms and websites Protect our company and others, such as to detect, investigate, and activities that are illegal or violate our policies, exercise a legal claim, and comply with applicable laws and regulations Comply with our legal and financial obligations

We generally do not collect information that is considered “sensitive” under state privacy laws. In the limited circumstances that we do, such as collection of your account username and password, which is designated as “sensitive” under the CCPA, we do not use or disclose sensitive personal information for the purpose of inferring characteristics about you.

The length of time we retain your personal information depends on the status of our relationship with you and the requirements of applicable law. To determine that period, we take into account a number of factors, including our legal and regulatory obligations (such as financial reporting obligations) and whether we may need to retain personal information to resolve disputes, make and defend legal claims, conduct audits, pursue legitimate business purposes, and/or enforce our agreements.

Sales and Sharing

We disclose the following categories of personal information to third parties to engage in targeted advertising and other marketing activities, including to expand the reach and effectiveness of our own marketing campaigns. These disclosures may be considered “sales” or “sharing” under the CCPA:

CATEGORIES OF PERSONAL INFORMATION	CATEGORIES OF THIRD PARTIES
Identifiers (such as name and contact information) Internet or other network activity information (such as browsing behavior)	Advertising and marketing networks, data analytics providers, and social networks

We do not knowingly “sell” or “share” personal information about consumers under the age of 16.

Your Rights

Opt Out of Sales and Sharing

You may opt out of activities that we engage in that constitute “sharing” or “sales” of personal information under the CCPA by:

Cookies and Similar Technologies: using tools made available by your web browser to block all cookies from being set; and
Other Identifiers: Contacting us at [email protected] to opt out of “sharing” and “sales” based on your email address.

Access, Correction, and Deletion

You have the right to (1) request to know more about and access your personal information, including in a portable format, (2) request deletion of your personal information, and (3) request correction of inaccurate personal information.

To request access, correction, or deletion of your personal information, email us at [email protected]. To authenticate your request, we may ask you to provide certain information, such as your name, email address, and phone number.

Authorized Agents

If you are an authorized agent seeking to make a request to opt out of “sales” or “sharing” on behalf of a consumer, please contact us at [email protected].

You may also designate an authorized agent to submit an access, deletion, or correction request on your behalf. We may ask authorized agents to submit proof of their authority to make a request, such as a valid power of attorney or proof that they have signed permission from the consumer who is the subject of the request. In some cases, we may contact the individual who is the subject of the request to verify their own identity or confirm the authorized agent has permission to submit the request. If you are an authorized agent seeking to make an access, correction, or deletion request on behalf of a California resident, please contact us at [email protected].

Non-discrimination

We will not discriminate or retaliate against you for exercising your privacy rights.

ADDITIONAL DISCLOSURES FOR INDIVIDUALS LOCATED OUTSIDE THE UNITED STATES

We are based in the United States and process and store personal information on servers located in the U.S. We use third-party service providers that may be located in, or have servers in, another country. Where required by law, we provide adequate protection for the transfer of personal information in accordance with applicable law, such as by obtaining your consent, relying on the European Commission’s adequacy decisions, executing Standard Contractual Clauses, or complying with another approved data transfer mechanism. Where relevant, you may request a copy of these Standard Contractual Clauses by contacting us at [email protected].

Individuals in Europe

If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, this section applies to you where your local law applies to our processing activities.

Legal Basis for Processing. When we process your personal information, we will only do so when:

We need to use your personal information to perform our responsibilities under our contract with you, for example to deliver services that you purchase from us.
We have a legitimate interest in processing your personal information. For example, we may process your personal information to send you marketing communications, to communicate with you about changes to our Services, and to provide, secure, and improve our Services.
We find such processing is necessary to comply with our legal obligations.
We have your consent to do so. When your consent is the legal basis for our processing, you may withdraw such consent at any time.

Data Subject Requests. You have the right to (1) request to know more about and access your personal information, including in a portable format, (2) request deletion of your personal information, (3) request correction of inaccurate personal information, (4) request restriction of processing of your personal information, and (5) object to the processing of your personal information for certain purposes. To exercise any of these rights, please email us at [email protected].

Retention. The length of time we retain your personal information depends on the status of our relationship with you and the requirements of applicable law. To determine that period, we take into account a number of factors, including our legal and regulatory obligations (such as financial reporting obligations) and whether we may need to retain personal information to resolve disputes, make and defend legal claims, conduct audits, pursue legitimate business purposes, and/or enforce our agreements.

Questions or Complaints. If you have a concern about our processing of personal information that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en
For individuals in the UK: https://ico.org.uk/global/contact-us/
For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt.html

Individuals in Canada

If you reside in Canada, this section applies to you.

Your Rights. You may exercise your rights to access and correct the personal information we hold about you by emailing [email protected]. By submitting personal information to us or our service providers, you consent to the collection, use, disclosure, and transfer of your personal information in accordance with this policy and as permitted or required by law. You may withdraw your consent at any time by contacting us at [email protected]. If you withdraw your consent (or if you decide not to provide certain personal information), you acknowledge that we may not be able to provide you with certain products, services, or information.

CHANGES TO THIS POLICY

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. As required under applicable law, or in cases where there are material changes, we may also provide you with additional notice, such as adding notice on our homepage or sending you an email. We encourage you to review this Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

CONTACT US

If you have any questions about this Privacy Policy, please contact us at [email protected] or at Ethena, Inc., 33 Nassau Ave., Second Floor, Brooklyn, NY 11222.

- -