PRIVACY POLICY

Last modified: November 4, 2026

THIS PRIVACY POLICY IS SUBJECT TO AN ARBITRATION AGREEMENT DESCRIBED IN OUR TERMS OF USE, WHICH ARE INCORPORATED INTO THIS POLICY BY REFERENCE.

Carternity Inc., a Delaware corporation (“Carternity” the “Company,” “we,” “us,” or “our”), respects your privacy. This Privacy Policy (this “Policy”) describes the categories of personal information we collect, how we use and disclose it, and the choices available to you. This Policy applies to https://www.carternity.com (the “Website”), our mobile applications for iOS and Android and our web application (each, an “App”), our AI assistant Terni, the Community, Parts & Tools, and all related content and services we provide (collectively, the “Services”). Capitalized terms not defined in this Policy have the meanings stated in our Terms of Use.

By accessing or using the Services, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, you must not use the Services. If you are located in the European Economic Area, the United Kingdom, or Switzerland, the section “International Users” below states the legal bases on which we process your personal information; your acceptance of this Policy is not a consent to processing for the purposes of data-protection law, and where we need your consent, we ask for it separately.

Children Under 18

The Services are intended for individuals who are 18 years of age or older. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from an individual under 18, we will delete that information, except where retention is required by law. If you are a parent or guardian and believe your child has provided us with personal information, contact us at legal@carternity.com.

Categories of Personal Information We Collect

We collect the following categories of information from and about users of the Services:

  • Identifiers and account data. Your email address, name and profile picture if you sign in with Google, unique user and account identifiers, sign-in and session information, and records of your acceptance of our Terms of Use and this Policy.
  • Profile and onboarding data. Information you provide when you set up your account or profile, such as your experience level with vehicle maintenance and the topics you are interested in.
  • Vehicle data. Information about each vehicle you add, including its VIN, whether typed or read from a photo of the VIN; make, model, trim, and year; engine capacity and engine code; horsepower; transmission and transmission code; body type; fuel type; mileage; suspension; engine and body modifications; service reminders, events, and projects; and information derived from the VIN, such as specifications and recall information.
  • Photos and documents. Photos of your vehicle and of its VIN, and documents you upload, such as service invoices and inspection reports. Photos and documents may show license plates, other people, or personal information contained in them. We remove location information embedded in photos when you upload them.
  • Chats with Terni. The messages, questions, attachments, and voice input you send to Terni, and Terni’s responses.
  • Community content. Your Community profile, posts, comments, reactions, ratings, photos, videos, listings, and direct messages, and information about the users and groups you follow.
  • Purchase and plan data. Your plan, Credit balance and usage, and purchase history. Payments are processed by the Apple App Store, Google Play, or our payment processor; we do not receive your full payment card number.
  • Parts & Tools interactions. The offers you view and the links to Third-Party Providers you click.
  • Usage, device, and diagnostic data. Information about how you use the Services, device and browser type, operating system, IP address and the approximate location (such as country or region) derived from it, App version, push-notification tokens, advertising identifiers (with your permission where required), and diagnostic, crash, and performance data.
  • Communications and Feedback. Information you provide when you contact support, submit Feedback, report content, or subscribe to our newsletter.

We do not collect the precise location of your device. Please do not include in chats, photos, documents, or Community posts information about your health, finances, or other sensitive matters, or personal information of other people that you do not have the right to share.

How We Collect Information

We collect information: (i) directly from you, such as when you create an account, add a vehicle, chat with Terni, upload photos or documents, post to the Community, make a purchase, or contact support; (ii) automatically, through your use of the Services, including through cookies and similar technologies described below; and (iii) from third parties, such as sign-in providers, VIN-decoding and vehicle-data sources, app stores and payment processors, and our service providers.

Vehicle Data and VIN

We use your VIN and other vehicle data to identify your vehicle, retrieve its specifications and recall information, personalize Terni’s guidance, maintain your vehicle profile, reminders, and projects, and identify compatible parts. To decode a VIN, we send the VIN, without your name or other account information, to VIN-decoding services such as the U.S. National Highway Traffic Safety Administration’s vPIC database. Except as described in “Sale and Sharing of Personal Information; Personalized Advertising” below, we share vehicle data with a Third-Party Provider only when you choose to interact with that provider. VINs and license plate numbers are not included in the aggregated or de-identified data we use or disclose as described below.

Terni and AI Processing

When you chat with Terni, we send your messages, attachments, and relevant vehicle data to our third-party artificial-intelligence providers to generate Terni’s responses. Under our agreements with them, these providers process your information on our behalf and do not use it to train their own models. We record conversations, including any personal information they contain, in our monitoring and quality tools to operate, troubleshoot, secure, and improve Terni, and retain those records as stated in “Retention of Information” below. Our AI providers and monitoring tools may process your information outside your country of residence, including in the United States.

We use conversations, Feedback, and other information about your use of Terni to improve Terni’s responses and the Services, generally in de-identified form. We may also use your chats, photos, vehicle data, and Community content to develop and train our own artificial-intelligence models. If you are located in the European Economic Area, the United Kingdom, or Switzerland, you may object to this use at any time by contacting us at legal@carternity.com. If you object, we will not use your information in training that begins after we receive your objection. We do not use your information to train third-party providers’ models.

How We Use Your Information

We use your information to: (i) provide and operate the Services, including your account, vehicle profiles, Terni, reminders, projects, the Community, and Parts & Tools; (ii) process purchases and manage your plan and Credits; (iii) personalize the Services; (iv) improve and develop the Services, including as described in “Terni and AI Processing” above; (v) communicate with you, including service and transactional messages and, where you have opted in, our newsletter and marketing; (vi) moderate content, enforce our Terms of Use, and maintain the security of the Services and detect and prevent fraud and abuse; (vii) analyze use of the Services; (viii) personalize advertising and disclose personal information to third parties as described in “Sale and Sharing of Personal Information; Personalized Advertising” below; and (ix) comply with our legal obligations and establish, exercise, or defend legal claims.

Cookies and Similar Technologies

We and our service providers use cookies and similar technologies, such as local storage and software development kits, on the Website and in the Apps. Some are strictly necessary to sign you in, keep your session secure, and operate the Services. With your consent where required by law, we also use analytics technologies, such as PostHog, to understand how the Services are used and to improve them. You can manage your preferences through our cookie banner and settings and through your browser or device settings. With your consent where required by law, and subject to your right to opt out, we and our advertising partners may also use cookies, advertising identifiers, and similar technologies to show you personalized advertising and to measure its effectiveness. On iOS, we do so only if you permit tracking when asked.

Sale and Sharing of Personal Information; Personalized Advertising

The Services may display general, contextual, sponsored, and personalized advertising and offers, including from Third-Party Providers, and we may receive commissions when you click on or purchase from an offer. In addition, we may (i) use, and share with advertising partners, your vehicle data (other than your VIN), profile and interest data, usage data, advertising identifiers, and approximate location, so that we and they can show you advertising and offers tailored to your interests, inside and outside the Services; and (ii) disclose that information to selected third parties, such as parts sellers, repair and service providers, and other businesses in the automotive sector, for their own marketing purposes, in exchange for compensation. Under some U.S. state laws, these activities may constitute a “sale” of personal information, “sharing” for cross-context behavioral advertising, or “targeted advertising.” We do not sell or share for these purposes your VIN, license plate numbers, chats with Terni, photos, documents, direct messages, or payment information, and we do not knowingly sell or share personal information of individuals under 18.

If you are located in the European Economic Area, the United Kingdom, or Switzerland, we engage in these activities only with your consent, which you may give or refuse separately when you create your account and withdraw at any time in your account settings. If you are located in the United States, you may opt out at any time in your account settings, by contacting us at legal@carternity.com, or by enabling a recognized opt-out preference signal, such as Global Privacy Control, which we honor for the browser or device that sends it. We will not begin these activities until these choices are available in the Services.

Disclosure of Your Information

We disclose personal information to the following categories of recipients, solely to provide, secure, and improve the Services or as otherwise stated in this Policy. Each third-party recipient identified below has and operates under its own privacy policy and terms, and we are not responsible for a third party’s own privacy or data-handling practices.

  • Cloud hosting and infrastructure. Google Cloud, for computing, databases, file storage, encryption and key management, and system monitoring.
  • Authentication. Clerk, to manage sign-in and account security, and Google, if you choose to sign in using Google.
  • Artificial-intelligence processing. Google Gemini, to generate Terni’s responses.
  • Monitoring and analytics. Langfuse, to record and monitor Terni conversations, and PostHog, to analyze use of the Services.
  • Vehicle-data sources. VIN-decoding services such as the National Highway Traffic Safety Administration’s vPIC database, which receive VINs without account information.
  • Communications. Google gmail and Kit, for transactional email and our newsletter, and Apple Push Notification service and Firebase Cloud Messaging, for push notifications.
  • Payments. The Apple App Store, Google Play, and our payment-processing and subscription-management providers, to process and manage purchases and subscriptions.
  • Third-Party Providers. Sellers and service providers in Parts & Tools, when you choose to click on or interact with their offers.
  • Advertising partners and other businesses. Advertising networks and partners, and selected businesses in the automotive sector, as described in “Sale and Sharing of Personal Information; Personalized Advertising” above.
  • Other users and the public. Content you post to the Community is visible to other users and, as configured by your settings, in limited form to visitors who are not signed in and to search engines. Direct messages are visible to their recipients.
  • Legal and safety. We may disclose information to comply with law, legal process, or a government request; to enforce our Terms of Use; and to protect the rights, property, or safety of the Company, our users, or others.
  • Business transfers. We may disclose information in connection with a merger, acquisition, financing, or sale of company assets.
  • Professional advisors. Our lawyers, auditors, and insurers, under confidentiality obligations.

Except as described in “Sale and Sharing of Personal Information; Personalized Advertising” above, we do not sell personal information to any of the recipients above, and each service provider is contractually restricted to using personal information only to provide services to us.

Data Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, and disclosure, including encryption of data in transit and at rest, private storage of photos and documents accessible only through time-limited links, restricted access to our databases, and secure management of credentials. We may offer additional account-security features, such as two-step verification. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Retention of Information

We retain personal information only for as long as necessary to provide the Services, comply with our legal obligations, resolve disputes, and enforce our agreements. When you delete your account, we delete your personal information, including your vehicle data, chats, photos, and documents, except that: (i) copies in database backups are deleted in the ordinary course, generally within seven days; (ii) records of Terni conversations in our monitoring tools are deleted within 90 days after they are created; (iii) reports of abusive or unlawful content or conduct, and the related information, are retained for as long as necessary to protect the Services and our users, enforce our Terms of Use, and establish, exercise, or defend legal claims; and (iv) we retain information we are required to keep by law, such as transaction records for tax purposes. Community content you shared may remain visible to the extent it was copied or shared by other users before deletion. We may retain de-identified and aggregated information that no longer identifies you.

Your Rights and Choices

You may access, correct, and delete your personal information directly in the Services. Depending on your country or state of residence, additional rights may be available to you, as stated in “Your U.S. State Privacy Rights” and “International Users” below. To exercise any right, contact us at legal@carternity.com. We will respond to verifiable requests within the time required by applicable law, but not later than 45 days.

  • Delete your account. You may delete your account and the personal information associated with it at any time through the account settings in the App or on the Website.
  • Correct or update information. You may correct or update your profile, account, and vehicle information directly in the Services, or by contacting us.
  • Marketing communications. You may unsubscribe from our newsletter and marketing emails at any time using the link in each email.
  • Cookies and analytics. You may manage your cookie and analytics preferences as described in “Cookies and Similar Technologies” above.
  • Sale, sharing, and personalized advertising. You may opt out of, or withdraw your consent to, the activities described in “Sale and Sharing of Personal Information; Personalized Advertising” as stated in that section.
  • Device permissions. You may manage camera, microphone, photo-library, and notification permissions at any time through your device settings.

Your U.S. State Privacy Rights

Depending on your state of residence, including California, Colorado, Connecticut, Virginia, and other states with comprehensive privacy laws, you may have the right to: (i) know whether we process your personal information and access it; (ii) correct inaccuracies; (iii) delete it; (iv) obtain a portable copy; and (v) opt out of the sale of personal information, targeted advertising, and certain profiling. We may sell or share personal information and use it for targeted advertising as described in “Sale and Sharing of Personal Information; Personalized Advertising”, and you may opt out as stated there, including through a recognized opt-out preference signal. We do not use or disclose sensitive personal information for purposes that would give rise to a right to limit its use under California law. You may exercise your rights by contacting us at legal@carternity.com; an authorized agent may submit a request on your behalf as permitted by law. We will verify your request, and we will not discriminate against you for exercising your rights. If we deny your request, you may appeal by replying to our decision.

We collect the categories of personal information described in “Categories of Personal Information We Collect” above, from the sources described in “How We Collect Information,” for the purposes described in “How We Use Your Information,” and have disclosed them for business purposes to the categories of recipients described in “Disclosure of Your Information.” We retain each category as described in “Retention of Information.” In the 12 months before the “Last modified” date of this Policy, we have not sold or shared personal information.

International Users

The Company is based in the United States, and our servers and service providers are located in the United States, the European Union, and other countries. Wherever you are located, your information may be transferred to, stored, and processed in the United States and in the other countries in which our service providers stated in “Disclosure of Your Information” above operate.

European Economic Area, United Kingdom, and Switzerland

If you are located in the European Economic Area, the United Kingdom, or Switzerland, the General Data Protection Regulation, the UK GDPR, and the Swiss Federal Act on Data Protection may apply to our processing of your personal information. The Company is the controller of your personal information.

We process your personal information on the following legal bases:

  • Performance of our contract with you (GDPR Art. 6(1)(b)), to provide the Services you request, including your account, vehicle profiles and VIN decoding, Terni, reminders, projects, the Community, Parts & Tools, and purchases.
  • Our legitimate interests (GDPR Art. 6(1)(f)), to secure the Services and prevent fraud and abuse, moderate content, analyze and improve the Services, develop and train our own models as described in “Terni and AI Processing,” create de-identified and aggregated data, and establish, exercise, or defend legal claims. Our legitimate interests are operating a safe and reliable service and improving and developing it, and you may object to processing based on them as described below.
  • Your consent (GDPR Art. 6(1)(a)), for non-essential cookies and analytics technologies, for personalized advertising and the disclosure of personal information to third parties described in “Sale and Sharing of Personal Information; Personalized Advertising”, and for our newsletter and marketing emails. You may withdraw your consent at any time, without affecting the lawfulness of processing before withdrawal.
  • Compliance with legal obligations (GDPR Art. 6(1)(c)), such as keeping transaction records for tax purposes and responding to lawful requests from authorities.

We do not intend to process special categories of personal data. Providing information is necessary to use the Services; if you do not provide it, we may be unable to provide some or all of the Services.

When we transfer your personal information outside the European Economic Area, the United Kingdom, or Switzerland to a country not recognized as providing an adequate level of protection, we rely on appropriate safeguards, such as the EU-U.S. Data Privacy Framework and its UK and Swiss extensions where the recipient is certified, or the standard contractual clauses approved by the European Commission and their UK and Swiss equivalents. You may request a copy of these safeguards by contacting us.

You have the right to access, correct, delete, and port your personal information, to restrict or object to our processing of it, including processing based on our legitimate interests and, at any time, processing for direct marketing, and to withdraw consent at any time. We do not make decisions based solely on automated processing that produce legal or similarly significant effects on you. You may exercise these rights by contacting legal@carternity.com, and you have the right to lodge a complaint with the supervisory authority in your country of residence or work, or where an alleged infringement occurred.

Dispute Resolution

Disputes arising out of or relating to this Policy or our data and privacy practices are subject to the binding arbitration and class-action-waiver provisions stated in our Terms of Use, which are incorporated into this Policy by reference, including the savings clause stated there for consumers resident outside the United States for whom mandatory consumer arbitration is not enforceable under the law of their country of residence.

Changes to This Privacy Policy

We may update this Policy from time to time. We will post any changes on this page and update the “Last modified” date above. If we make a material change to how we treat personal information, we will provide additional notice, such as an in-App notice or an email to the address associated with your account.

Contact Information

Carternity Inc. 8 The Green, Suite 13701, Dover, DE 19901. Questions about this Policy or our privacy practices may be directed to legal@carternity.com.