Last revised 12/06/2021

Ethena

 Privacy Policy

Ethena, Inc., together with its affiliates and subsidiaries (collectively, “Ethena,” “we,” “our,” or “us”) understands privacy is important to you, and we are committed to protecting the privacy of our users. This Privacy Policy explains what information we collect about you and use at Ethena, and the choices you have associated with that information. This Privacy Policy applies to the information we collect about you in the course of our business, including through Ethena websites or online application, pursuant to the Service Agreement between you or your employer or other entity or person in connection with using Ethena’s Services, and other online or offline offerings or events (collectively, “Services”).

Please carefully review this Privacy Policy to understand how we handle your information. Ethena maintains a separate agreement with organizations (e.g., your employer or another entity or third party) (collectively, “Customer” or “Customer Admin”), which also may cover processing of information related to the Services (the “Customer Agreement”). Your use of Ethena’s Services, including submission of information to us through our website or in accordance with the Customer Agreement, constitutes agreement to this Privacy Policy.  The Customer controls any information associated with its use of the Services or the information it receives from you in connection with your use of the Services related to your relationship with Customer.

Information We Collect

Ethena collects information about three types of individuals: 1) Customers; 2) individuals or end users granted access to Ethena’s Services through a Customer Agreement (collectively, “Learners”); and 3) individuals who visit our website (“Users”).

The information we collect about you depends on your relationship with Ethena and the Services you use, how you use them, and the information you provide us through use of our Services. The information we collect may include:

• Contact Information, such as name, email address, phone number, and username (“Contact Information”);
• Demographic Information, such as country and state (in U.S.);
• Employment Information, such as employer, job title, role and relationship with others within the organization, employment start date, and employer’s address;
• Training Tracking and Response Information, including time spent on each training module, date of training module start and completion, training completion progress, responses to check-on-learning exercises, responses to culture pulse surveys, and feedback on experience or content;
• Recruitment Information, such as curriculum vitae/resumes, work history, or qualifications for potential or actual applicants for a position at Ethena;
• Online Identifiers, such as IP Address, user agent, or device ID; and
• Any other information that you provide to us that can be used to identify you.

We may also collect information about your use of our websites, such as your browser information, pages clicked, and time spent navigating our websites. If you are a Learner who has participated in a training, this information can be used to identify you, but if you are a User who has never participated in a training, this information will be de-identified and cannot be used to identify you. De-identified information is not subject to any restrictions under this Privacy Policy, and we may use and disclose it to others for any purpose, without limitation. However, if this information were to be linked with information above or otherwise become identifiable, we will treat such linked information in accordance with this Privacy Policy.

Cookies and Similar Technologies

We collect information through cookies and other similar technologies, including when you visit our website and use our online Services. Please see our Cookies Policy to learn more.

How We Collect and Use Your Information

We collect information about you through:

• Direct interactions with you, such as when you create an account (if you are a Customer), participate in a training, request information or customer support, join our email marketing list, or otherwise contact us;
• Cookies and automated technologies, such as when you interact with our websites or click on links in our emails;
• Other sources, such as through the Customer (if you are a Learner or User) and analytics providers.

We use your information for the following purposes:

Create and manage Customer and Learner accounts: Customers may be asked to create an administrative account to access our Services and coordinate trainings for the Customer’s workforce. To create a Customer account, Customers will be asked to provide their name, email address and employment-related information (“Employment Information”), and the Customer may be asked to choose a password. Ethena will not receive the password. In accordance with our Customer Agreement, Ethena will also create an account for each individual Learner to use when accessing our Services. Ethena will collect from the Customer the Contact Information, Employment Information, and any other information the Customer deems relevant about each Learner to set up and service the Learner account.

We will use the received information for all purposes related to creating and managing each account, including, without limitation, providing administrative, maintenance, and support services; respond to inquiries, requests, or complaints; and servicing both Customer and Learner accounts.

• Enable your use of our Services: We will use your Contact Information, Employment Information, and Training Tracking and Response Information to provide you with our Services at your request or in accordance with our Customer Agreements.

• Assist with purchases of our Services: Customers may purchase our Services through use of our online portal. To purchase our Services, we will collect the Customer’s representative’s Contact Information and Employment Information so that we may provide you with confirmation regarding the Customer’s purchase, including the purchase amount. A third-party provider will collect your billing address and payment information, including your payment card number, security/CCV code, and expiration date. The third-party provider will use this information to process your payment.

• Use of electronic mailing lists: We will use your Contact Information to send you communications about Ethena, this Privacy Policy, our Services, and other important administrative announcements. We may also send you news, updates, announcements, newsletters, and other marketing communications via email. Some of these communications will be pursuant to our legitimate interest to keep you informed, while other communications may be pursuant to your consent (if we are required by law to obtain your consent).

• Process surveys, reviews, and feedback forms: We may use online surveys, reviews, and feedback forms to gather opinions, comments, and suggestions about Ethena and our Services. Should you choose to disclose information to us, we will collect and user such information to understand your comments, communicate with you regarding your feedback, and make changes to our Services accordingly.

• Respond to inquiries: You may submit inquiries or complaints to Ethena regarding our Services. We will use your name, email address, and any other information you shared with us to communicate with and respond to you.

• Maintain the security of the websites: We may use your information to detect security incidents, protect the websites against fraudulent and illegal activity, and enforce our Terms of Use.

• Our legal purposes: We may use your information to comply with our legal obligations or to establish, exercise, or defend legal claims.

• Other purposes for which we seek your consent: We may use your information for a specific purpose that we communicate to you. We will ask for your consent to process your information for such purpose in accordance with applicable legal requirements.

The laws in some jurisdictions require companies to tell you the legal grounds they rely on to process your information. Our processing of your information, as described in this Privacy Policy, is based on:

• Our legitimate interests in promoting and protecting Ethena, building and maintaining relationships, and providing our Services;
• Your consent, such as when you create an account or register for our newsletters or alerts; and
• Our obligation to comply with applicable law, when certain information is necessary to satisfy our legal or regulatory requirements.

How We Share Data

We share your information with the following categories of recipients as an essential part of being able to provide our Services to you:

• Our Affiliates and Partners. Subject to our Customer Agreements, we may share information within the Ethena family of companies and with our Partners to deliver and enhance our Services, operate and grow our business, and improve your user experience.  

• Service Providers. Unless prohibited by contract or applicable law, we may share information with our third-party service providers that help us operate our business and provide our Services, including payment service providers, website and application hosting providers, cloud providers, analytics providers, security providers, researchers, and marketing companies.

• Our Customers. Subject to our Customer Agreements, we may share certain Training Tracking and Response Information about our Learners and other Learner-generated data with our Customers. This information sharing would be limited so that our Customers received information about its Learner employees only and not the Learner employees of our other Customers. We may anonymize and/or aggregate Demographic Information and other Training Tracking and Response Information and share the anonymized, aggregated information with our Customers.

• Transactions or Business Transfers. If Ethena is merged, acquired, or sold, or in the event of a transfer, restructuring of some or all of our assets, or bankruptcy, we may disclose or transfer information in connection with such transaction. You acknowledge that such transfers may occur and are permitted by and subject to this Privacy Policy.

• Government or Law Enforcement Agencies. We may share your information (i) if we determine that disclosure is necessary to comply with any law or legal process applicable to us or a request from law enforcement or other regulatory agency; (ii) to protect the rights, privacy, property, interests, or safety of Ethena, our Customers, Learners, or our users, sponsors, employees, or the general public; (iii) to enforce this Privacy Policy and Terms of Use; (iv) to respond to an emergency; and (v) as otherwise permitted by applicable law.

We share your information with third parties only as described in this Privacy Policy, with your consent, or as disclosed at the time we collect your information.

Your Choices

We offer you choices and opportunities with respect to certain uses of your information.

• Adjust your marketing and communications preferences: You may at any time opt out of receiving marketing electronic mailings from Ethena by using the “opt out” or “unsubscribe” means provided in the electronic mailings you receive. You may also email us at the contact information provided below. Please note that even if we stop all marketing communications, you may still receive other important communications from us.

• Limit the information you provide to us: When you interact with us, you can choose to limit the information you provide. However, if you choose to do so, you may not be able to fully use many of our Services.

• Update your Customer account: Customers may update account sign in details and profile information for the Customer admin account. Customers may also be able to update the profile information for each Learner account affiliated with the Customer.  Customers may make these changes by logging into its Customer admin account and adjusting its account settings.

• Opt out of cookies: Follow the instructions in our Cookies Policy to opt out of our use of certain cookies.

Do Not Track (DNT) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. We do not recognize DNT.

Notice to Individuals in the UK or EEA

If you are located in the United Kingdom or the European Economic Area, you may request to exercise the following rights with respect to your information:

• Access to, or a copy of, your information
• Correction or amendment of your information
• Deletion of your information
• Transfer of your information to a third party
• Restriction or objection to certain uses of your information

If you have provided consent for us to use your information for a specific purpose, you may request to withdraw that consent.

If you wish to exercise any of your rights, please contact us using the means listed at the end of this Privacy Policy. We may ask you to provide us with information necessary to reasonably verify your identity before responding to your request. We will consider all requests and provide our response within the time period required by applicable law.  Please note, however, that certain information may be exempt under such requests. If we are unable to honor your request, we will let you know why.

Ethena acts as a Processor to Customers and Learners with respect to your use of our Services. There are limited situations where Ethena may act as a Controller, including when processing Recruitment Information.

California “Shine the Light” Disclosures

California residents may request information from us once per calendar year about any information shared with third parties for the third party’s own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. To request this information, please contact us using the information provided in the “Contact Us” section of this Privacy Policy. Your inquiry must specify “Shine the Light Request” in the subject line of the email or the first line of the letter, and include your name, street address, city, state and ZIP code.

Nevada Privacy Law

If you are a resident of Nevada, you have the right to opt-out of the sale of certain information to third parties who intend to license or sell that information. You can exercise this right by contacting us at privacy@goethena.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your information as sales are defined in Nevada Revised Statutes Chapter 603A.

Data Transfers to the United States

Ethena’s operations are located primarily in the United States. If you are outside of the United States and submit your information to us or otherwise use our Services, please be advised that (i) any information you provide to us or that we automatically collect will be transferred to the United States, where U.S. law may not offer the same privacy protections as the law of your jurisdiction; and (ii) by visiting our website or using our Services, you explicitly authorize its transfer to and subsequent processing in the United States in accordance with this Privacy Policy.

Children’s Privacy

Ethena’s Services are not directed at children under the age of 16. Ethena does not knowingly collect information from anyone under the age of 16. If we become aware that we have collected information from a child under 16, we will handle such information in accordance with applicable laws. 

Security and Retention of Your Information

We are committed to protecting your information, and we use a variety of technical, physical, and organizational security measures. However, no security measures are perfect or impenetrable. As such, we cannot guarantee the security of your information. When using your Ethena account, it is important that you select a strong password and do not share it with others. Alert us immediately if you have any concerns about unauthorized access to or use of your account.

We retain information for different periods of time depending on the purposes for which we collect and use it, as described in this Privacy Policy. We will delete or de-identify information when it is no longer needed to fulfill these purposes, unless a longer retention period is required to comply with applicable laws.

Third Party Websites

Our website may contain links to certain third-party websites not owned or operated by us. When you click on a link to a third-party website, you leave our Site and no longer will be subject to our Privacy Policy. Ethena does not control and is not responsible for the privacy policies or practices or the content of any third-party websites, and such links are not intended to be an endorsement. We encourage you to review the privacy policies of any third-party website prior to providing them with your personal information.

Updates and Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our data privacy practices. If we make any material changes, we will provide notice on goethena.com, and we may notify you by email (sent to the email address specified in your Service Agreement or used to create an account), prior to the change becoming effective. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices. Any amended Privacy Policy supersedes all previous versions. If you continue to use the Services after those changes are in effect, you agree to the revised policy.

Contact Us

If you have any other questions about our Privacy Policy or wish to exercise any rights you may have with respect to your personal information, please email us at privacy@goethena.com or use the contact details below.

Ethena, Inc.

WeWork c/o Ethena

134 N 4th St

Brooklyn, NY 11249