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Privacy Agreement for Cap Tables (PACT)
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Recent events highlight the need for clear rules around cap table data.
We believe, unequivocally, that companies should have full control & privacy of their cap table
Anything less is not founder-friendly.
Full details are below.
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By co-signing this agreement, you are showing your support for a clear set of rules around how cap table data is used.
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Stakeholder Communications
- Solicitation: Vendors & their affiliates may not reach out to investors using cap table data provided in the system to solicit a sale or transfer of equity without company approval.
- Clarity: Cap table systems should be as clear as possible about what emails are being sent to stakeholders and allow companies to control them.
- Anti-spam: Any unsolicited marketing & promotional emails sent to stakeholders using information provided by the company may only be sent with the company's permission.
Privacy
- Internal Controls: Vendors can only use cap table information for purposes explicitly authorized by the company, such as for onboarding, customer service tasks, and data access should be logged. The access list should be made available to companies on request.
- Aggregate Data: Vendors may use cap table data for aggregate & anonymized reporting on statistics, but may not share specific, identifiable cap table information with data brokers or the public.
- Data Firewall: Only team members of the vendor that are directly involved with supporting companies on the cap table software are able to access private company information.
- Liquidity Firewall: If the company or affiliates has a secondary transaction business, they must not be able to access any information without company approval.
Data Ownership
- Ownership: Cap tables vendors must acknowledge that the company capitalization information belongs to the company. Should the company decide to discontinue their subscription, the vendor must provide a full export of all data, full reports, documents and additionally must not alter the status of any securities in the process.
- Integrity: The vendor cannot unilaterally make changes to the company’s data that were not authorized, such as execute transfers without company consent or cancel instruments without the direction of the company or its authorized users.
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