Privacy Policy

Citrate Inc. operates this data room to share confidential materials with individually authorized, prospective investors. Questions about this policy or your data can be sent to partners@citrate.ai.

We deliberately minimize what we hold. Specifically:

• Authentication identity. You sign in through Citrate’s own identity provider (auth.citrate.ai) using OpenID Connect. We receive a pseudonymous subject identifier and the email/profile claims you authorize — we never see your password.
• Email of record. The work email you provide, which we confirm with a one-time code. Used to contact you about your access request.
• Contact details. Optional name and firm you enter to address you.
• Identity verification (KYC).Performed by Citrate’s own identity service (auth.citrate.ai), server-blind: your ID and face are encrypted on your device before upload and cannot be read by our servers, and your face is deleted immediately after the one-time identity match. The data room never receives or stores any of it— it reads only a verified / not-verified status.
• Accreditation declaration. The Regulation D self-certification you submit (investor type, qualifying basis, US-person status). Any entity name is encrypted at rest. We do not collect government identifiers such as SSNs.
• NDA record. Your typed signature (encrypted at rest), the NDA version, a timestamp, and hashed (not plaintext) signer metadata.
• Access log. A tamper-evident, append-only record of access events tied to your identifier, kept to protect the confidentiality of the materials.
• Strictly-necessary cookies. Secure, httpOnly session cookies used only to keep you signed in. No advertising or cross-site tracking cookies are used.

To grant and administer access, verify your eligibility (accreditation and identity), maintain the confidentiality and audit trail of the materials, communicate with you about your request, and comply with applicable securities law.

We do not sell your data, and we do not send your identity documents or biometrics to any third-party verification vendor. We share the minimum necessary with service providers that help us operate: our own identity service (auth.citrate.ai) and infrastructure providers that host the application and store data (Vercel, Neon, Upstash). We may disclose information only where required by law or to protect our legal rights.

Sensitive fields are encrypted at rest (AES-256-GCM); all traffic is encrypted in transit (TLS). The room follows a least-data design — it stores no identity documents and no government identifiers — and access is individually credentialed and logged.

We retain your information for as long as you have access and as required for our legal, audit, and compliance obligations, then delete or de-identify it. The access log is append-only and retained as an integrity record.

To access, correct, or request deletion of your information (subject to legal retention requirements), contact partners@citrate.ai. Identity-document handling is governed by the verification vendor’s own privacy policy.

We may update this policy; material changes will be reflected by the “last updated” date above. Continued use after an update constitutes acceptance of the revised policy.