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Legal & Compliance

Privacy Policy

OneName Global, Inc. · Delaware Corporation · Effective: May 2026

GDPR AlignedSOC 2CCPADelaware Corporate CodeZero-Trust
§1

Scope of Architecture and Data Categorization

This Privacy Policy governs all data processing activities across the OneName Global Portal ecosystem. The platform operates a formally ring-fenced, multi-tier data storage architecture that separates data subjects into two operationally distinct classifications to enforce strict access control and regulatory compliance.

Class AVerified Investor Data

Comprises verified legal names, historical investment snapshots migrated from legacy registries (e.g., Cake Equity), share counts, original purchase values, bank details, and sensitive tax identifiers (EIN/SSN). This data class is subject to maximum access restriction and is accessible exclusively to verified shareholders whose identity has been reconciled against the official corporate ledger.

Class BGeneral Registered User Data

Comprises basic names, email addresses, and interaction history for interested parties or prospective partners without active holdings on the ledger. Class B data is maintained in a segregated data store with no cross-access pathways to Class A investment records, financial tables, or corporate cap table systems.

The system enforces these classifications at the infrastructure layer via role-based access control (RBAC) and immutable row-level security policies. No programmatic pathway exists for Class B principals to access Class A data stores, regardless of application-layer state.

§2

Core Data Processing Safeguards & Masking

OneName Global enforces a multi-layer data protection architecture that governs how sensitive financial identifiers are stored, transmitted, and displayed within the platform environment.

Cryptographic Storage at Rest

All tax identification numbers (EIN/SSN), banking routing information, and formal equity issuance signatures are encrypted at rest using AES-256 symmetric encryption. Decryption keys are managed via hardware security modules (HSM) with strict operational access logs maintained separately from primary data stores.

Automated Front-End Masking Protocols

The platform implements automated front-end masking to eliminate accidental data exposure during casual use, screen sharing, or collaborative reviews. Tax IDs are rendered strictly as XX-XXX4567, banking identifiers as ••••••1234, and SSNs as XXX-XX-6789. Full values are never transmitted to the client layer.

These masking protocols operate independently of user authentication state and cannot be overridden at the application layer. Any access to unmasked values requires explicit administrative authorization and generates an immutable audit record per Section 3 of this Policy.

§3

Forensic Audit Logging Framework

For the safety and structural integrity of the corporate cap table, all system interactions are subject to absolute, immutable forensic audit tracking. This framework operates at the infrastructure layer and cannot be disabled by any user, role, or administrative action.

Captured Metadata Per Interaction Event

actor_idUnique User ID of the principal performing the action
actor_emailVerified email address for cross-reference identification
timestampExecution timestamp in UTC (ISO 8601 format, millisecond precision)
action_typeEnumerated action class: LOGIN_VERIFY, TC_AGREE, CREATE, UPDATE, DELETE, VIEW_SENSITIVE
target_entityEntity name of the record being acted upon (e.g., Shareholder, Document)
target_idUnique record ID of the targeted data object
original_dataComplete JSON snapshot of record state BEFORE the action
final_dataComplete JSON snapshot of record state AFTER the action
metadata.ip_addressOriginating IP address of the network request
metadata.user_agentBrowser and OS fingerprint string
metadata.fingerprintComposite browser fingerprint for session continuity validation

Standard users explicitly consent to this cryptographic tracking upon completion of their portal onboarding flow. Consent is recorded as a TC_AGREE audit record and is itself immutable. Audit records are append-only — no update or delete operation is permitted against the AuditRecord store by any system principal, including administrators.

§4

Email and Communication Segment Security

OneName Global enforces strict role-based access control (RBAC) regarding all automated campaigns, investor relations broadcasts, and message distributions originating from the platform's communication infrastructure.

Recipient Segmentation Architecture

Investor

Verified stockholder roster — eligible to receive financial letters, K-1 distribution notices, cap table change notifications, and board communications. Segmented at the database layer from all general user records.

General

Prospective partners and general registered users — eligible for general communications and public-facing company updates only. Explicitly excluded from all financial tables, investor letters, and corporate cap table communications at both the API and UI layer.

The platform's email dispatch system enforces these segment boundaries at the payload construction layer. No administrative action can override recipient segmentation without generating a visible audit record. Cross-segment communications are architecturally impossible by design.

§5

Jurisdictional and Compliance Rights

While the OneName Global platform serves global distribution frameworks and international stakeholder bases, its primary structural ledger complies with Delaware Corporate Code (Title 8, Chapter 1) and international zero-trust data sovereignty standards. All corporate equity records are maintained in accordance with Delaware General Corporation Law § 219 (List of Stockholders).

GDPR

Right to access, correct, and erasure of personal profile data (where not in conflict with corporate record obligations). Lawful basis: Legitimate Interests and Contractual Obligation.

CCPA

California residents retain the right to know, delete, and opt-out of sale of personal information. Investment ledger data is explicitly excluded from deletion requests per Delaware Code.

SOC 2

Platform security controls are architected to meet SOC 2 Type II criteria across Security, Availability, Confidentiality, and Processing Integrity trust service categories.

Investment Ledger Restrictions

Users retain rights to inspect personal profiling parameters, correct inaccurate naming fields via the Profile Manager, and update communication toggle choices. However, restrictions apply to altering core investment ledger records. Share counts, original issuance dates, and transaction histories remain subject to formal board-approved administrative oversight and corporate secretary record reconciliation. No user-initiated request may modify these records without a duly executed corporate resolution.

To exercise any applicable rights, submit a formal written request to the designated Data Protection Officer at privacy@onename.global. Requests will be acknowledged within 72 hours and resolved within the timeframe mandated by the applicable jurisdiction.

This Privacy Policy was last reviewed and approved by the OneName Global Board of Directors on May 1, 2026. Changes to this policy will be communicated to all registered users via the portal notification system with a minimum 14-day advance notice period.

OneName Global, Inc. · 2711 Centerville Road, Suite 400 · Wilmington, Delaware 19808