Carbyne Data Privacy Framework Notice

This Data Privacy Framework Notice (“DPF Notice”) describes how Carbyne, Inc. (“Carbyne”, “we”, “our”, or “us”) collect, use, and disclose certain personally identifiable information that we receive in the United States (“U.S.”) from the EEA, the UK and Gibraltar, and Switzerland (“Personal Data”). This DPF Notice supplements our Privacy Policy and unless specifically defined in this DPF Notice, the terms in this DPF Notice have the same meaning as in our Privacy Policy. In the event of any conflict between the terms of our Privacy Policy and this DPF Notice, the latter shall prevail.

Scope

Carbyne, Inc. has self-certified compliance with the EU-U.S. Data Privacy Framework, the UK extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework as set forth by the U.S. Department of Commerce (collectively, the “Data Privacy Framework”) with respect to personal information relating to individuals from the EEA, the UK and Gibraltar, and Switzerland. 

Carbyne’s Data Privacy Framework certification applies to personal information that we collect and process in the course of our business, as described in the Carbyne Privacy Notice. It also applies to customer Personal Data (as defined in a customer’s terms and/or data processing addendum) that our customers and their authorized users upload and store in Carbyne services from the European Union and European Economic Area member states, the United Kingdom and Gibraltar, and Switzerland, except where the agreement with a customer stipulates a different transfer mechanism recognized by the relevant authorities (e.g., standard contractual clauses). The categories of personal information that our customers upload and store in our services are described in the applicable agreement and product documentation, and Carbyne only processes customer Personal Data in accordance with the customer’s instructions, as set forth in the applicable agreement. 

DPF Principles

Carbyne adheres to the Data Privacy Framework principles, including notice, choice, accountability for onward transfer, security, data integrity, purpose limitation, access, and recourse, enforcement, and liability, and the supplementary principles, regarding the collection, use, and retention of Personal Data transferred from the European Union and European Economic Area member states, United Kingdom, and Switzerland to the United States in reliance on the Data Privacy Framework. If there is any conflict between the terms in this DPF Notice and the DPF principles, the principles shall govern.

Enforcement

For purposes of enforcing compliance with the DPF Program, Carbyne is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission.  Additional information about the DPF Program and Carbyne’s self-certification can be found at https://www.dataprivacyframework.gov.

Your Rights

Under the DPF, you have rights in relation to your Personal Data. These include, as further described in our Privacy Policy and detailed in this DPF Notice:

  • Information on the types of Personal Data collected; 
  • Information on the purposes of collection and use;
  • Information on the type or identity of third parties to which your Personal Data is disclosed;
  • Choices for limiting use and disclosure of your Personal Data;
  • Access to your Personal Data;
  • Notification of the requirement to disclose your Personal Data in response to lawful requests by public authorities;
  • Reasonable and appropriate security for your Personal Data;
  • A response to your complaint within 45 days;
  • Cost-free independent dispute resolution to address your data protection concerns; and
  • The ability to invoke binding arbitration to address any complaint that the organization has violated its obligations under the DPF principles to you and that has not been resolved by other means. 

Personal Data Collection and Use 

Our Privacy Policy describes the categories of Personal Data that we may receive in the U.S. as well as the purposes for which we use that Personal Data. Carbyne will only process Personal Data in ways that are compatible with the purpose that we collected it for, or for purposes the individual later authorizes. Before we use Personal Data for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out. Carbyne maintains reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete, and current.

Sensitive Personal Data

When we directly collect sensitive Personal Data, we will obtain opt-in consent where the DPF requires, including if we disclose sensitive Personal Data to third parties, or before we use sensitive Personal Data for a different purpose than we collected it for or that you later authorized.

Data Transfers to Third Parties 

Third-Party Agents or Service Providers. We may transfer Personal Data to our third-party agents or service providers who perform functions on our behalf as described in our Privacy Policy. Where required by the DPF, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the DPF requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that (i) third-party agents and service providers process Personal Data in accordance with our DPF obligations, and (ii) to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of Personal Data that we transfer to them.

Third-Party Data Controllers. In some cases, we may transfer Personal Data to unaffiliated third-party data controllers. These third parties do not act as agents or service providers and are not performing functions on our behalf. We may transfer Personal Data to third-party data controllers for the purposes described in our Privacy Policy. We will only provide your Personal Data to third-party data controllers where you have not opted-out of such disclosures, or in the case of sensitive Personal Data, where you have opted-in if the DPF requires consent. We enter into written contracts with any unaffiliated third-party data controllers requiring them to provide the same level of protection for Personal Data the DPF requires. We also limit their use of your Personal Data so that it is consistent with any consent you have provided and with the notices you have received. If we transfer Personal Data to one of our affiliated entities within our Group, we will take steps to ensure that the Personal Data is protected with the same level of protection the DPF requires.

Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements. We will only do so in accordance with the DPF principles. 

Security

Carbyne maintains reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the DPF.

Access Rights

You may have the right to access the Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the DPF. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. 

If you would like to request access to, correction, amendment, or deletion of your Personal Data, you can submit a written request as set forth in the ‘Contact Us’ section below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.

Opt-out

Carbyne respects your privacy rights and offers you the opportunity to choose (opt-out) whether your Personal Data is disclosed to third parties or used for purposes materially different from the original collection purpose. You have the right to opt out of such disclosures or uses.  If you would like to exercise your right to opt out of such disclosures or uses, you can submit a written request as set forth in the ‘Contact Us’ section below. Please note, however, that in certain circumstances, such as when disclosure of your Personal Data is necessary for third parties acting as agents to perform tasks on our behalf and under our instructions, your opt-out right will not be applicable. However, we always establish contractual agreements with such agents to safeguard your personal data as further described under the section “Data Transfers to Third Parties” above.

Complaints

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Carbyne commits to resolve DPF principles-related complaints about our collection and use of your personal information. EEA, UK and Gibraltar, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Carbyne, using the details set out in our Privacy Policy at privacy@carbyne.com or via the contact form available here.

You can direct any questions or complaints about the use or disclosure of your Personal Data to us using those contact details. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data within 45 days of receiving your complaint. 

Independent Recourse Mechanism

For any unresolved complaints, we have agreed to cooperate with the EU data protection authorities, the UK ICO, or the Swiss FDPIC. If you are unsatisfied with the resolution of your complaint, you may contact the EU data protection authorities, the UK ICO, or the Swiss FDPIC for further information and assistance. Their details are set out in the ‘Additional Information for EEA, UK, and Swiss Residents’ section.

Additionally, in compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Carbyne commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office, and the Swiss Federal Data Protection and Information Commissioner with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF in the context of the employment relationship.

Binding Arbitration 

You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your complaint directly with Carbyne and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the U.S. Department of Commerce an opportunity to resolve the complaint (“Unresolved Complaints”) at no cost to you. For more information on binding arbitration, see U.S. Department of Commerce’s DPF: Annex I (Binding Nature of Decisions).

Carbyne commits to refer Unresolved Complaints concerning our handling of Personal Data received in reliance on the Data Privacy Framework to the International Centre for Dispute Resolution, the international division of the American Arbitration Association (“ICDR-AAA”), an alternative dispute resolution provider based in the United States. In the event of an Unresolved Complaint, please visit here for more information or to file a complaint.  The services of the ICDR-AAA are provided at no cost to you.

Contact Us

If you have any questions about this DPF Notice or would like to request access to your Personal Data or opt-out as described in this DPF Notice, please contact us using the details set out in the ‘Contact Information’ section of our Privacy Policy.

Changes to this DPF Notice

We reserve the right to amend this DPF Notice from time to time consistent with the DPF’s requirements.

Updated: June 29, 2026

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