Carthage Holdings Inc. Privacy Policy

Effective Date: 6-19-26

Introduction

Carthage Holdings Inc. (“Carthage,” “we,” “us,” or “our”) is committed to protecting the privacy of individuals whose information we collect. This Privacy Policy outlines our practices regarding the collection, use, disclosure, and protection of personal information, regardless of your state of residence. We strive to comply with all applicable U.S. state privacy laws, including but not limited to the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), the Virginia Consumer Data Protection Act (CDPA), the Colorado Privacy Act (CPA), the Connecticut Data Privacy Act (CTDPA), the Utah Consumer Privacy Act (UCPA), and other emerging state privacy laws.

1. Definitions

Personal Information: Information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Sensitive Personal Information: Personal information that reveals certain data points, including but not limited to Social Security numbers, driver’s license numbers, precise geolocation, racial or ethnic origin, religious beliefs, health information, or biometric information.

Sale/Sharing: The disclosure of personal information to a third party for monetary or other valuable consideration, or for targeted advertising purposes.

2. Information Collection

We collect personal information from various sources, including:

Directly From You:

• When you interact with our website (CARTHAGEESOP.COM), communicate with us via email, submit a resume, complete forms, or request information.

• This may include your name, contact information, company details, and any other information you choose to provide.

Automatically Collected Information:

• Technical data, such as IP addresses, browser types, device information, and browsing activity.

• Information collected through cookies and similar tracking technologies.

Employment-Related Information:

• Information provided in resumes and job applications.

3. Use of Personal Information

We use your personal information for purposes including:

• Providing and improving our website and services.

• Responding to your inquiries and requests.

• Processing job applications.

• Marketing and advertising, with your consent where required.

• Analyzing website traffic and usage patterns.

• Complying with legal obligations.

• Protecting our rights and interests.

4. Sensitive Personal Information

We collect and process sensitive personal information only when necessary and with your explicit consent, or as required by law. We implement heightened security measures to protect this information.

5. Sharing and Disclosure of Personal Information

We may share your personal information with:

• Service providers who assist us with our business operations.

• Third parties for marketing and advertising purposes (subject to your opt-out rights).

• Law enforcement or government authorities when required by law.

• Successor entities in the event of a merger, acquisition, or sale.

6. Cookies and Tracking Technologies

• We utilize cookies and similar technologies for website functionality, analytics, and targeted advertising.

• We use the Secure Privacy cookie banner to manage cookie consent and provide opt-out options.

• You can manage your cookie preferences through the cookie banner and your browser settings.

7. Consumer Rights

Regardless of your state of residence, you have the following rights:

Right to Know: You can request information about the categories and specific pieces of personal information we have collected about you.

Right to Access: You can request a copy of the personal information we hold about you.

Right to Correct: You can request that we correct inaccurate personal information.

Right to Delete: You can request that we delete your personal information, subject to legal exceptions.

Right to Opt Out: You can opt out of the sale/sharing of your personal information, targeted advertising, and certain profiling activities.

Right to Data Portability: You can request your data in a portable format.

Right to Limit Use of Sensitive Personal Information: You can limit the use of your sensitive personal information.

Right to Nondiscrimination: We will not discriminate against you for exercising your privacy rights.

8. Exercising Your Rights

To exercise your rights, please contact us at:

Email: webmaster@carthageesop.com

Address: 6612 Chancellor Drive, Suite 600, Cedar Falls, IA 50613

You can opt out of targeted advertising and profiling by adjusting your preferences on our consent banner. To request an export of your data or the deletion of your data, please fill out the data request form, located in the privacy popup, and we will process your request.

We will verify your identity before processing your requests.

9. Data Security and Retention

We take reasonable steps to protect your personal information, though it’s important to remember that no security system is completely impenetrable.

We hold onto your personal information only for as long as it’s necessary to fulfill the purposes for which we collected it. This includes meeting any legal, accounting, or reporting obligations we might have. To figure out how long we keep data, we consider several factors:

The duration of our ongoing relationship with you. We’ll retain your information for the entire time you’re an active user or customer.

Legal requirements. If there’s a law that requires us to keep certain data for a specific period, we’ll comply with that.

Our legal position. We also consider whether retaining data is advisable in light of potential legal situations, like applicable statutes of limitations, ongoing litigation, or regulatory investigations.

Data type and purpose:

-Short-term (90 days): This applies to data like basic logs or analytics that aren’t tied to specific users.

-Medium-term (up to 1 year): We retain user-level and event-level data, such as website visits, time spent on pages, and browse history, for up to one year.

10. Children's Privacy

Our website and services are not intended for children under the age of 13, and we do not knowingly collect, sell, or share personal information from children under 13 without verifiable parental consent, as required by the Children’s Online Privacy Protection Act (COPPA).

If you are a parent or guardian and believe that your child has provided us with personal information, please contact us at webmaster@carthageesop.com. If we learn that we have inadvertently collected personal information from a child under 13, we will promptly delete the information.

11. Changes to this Privacy Policy

We may update this Privacy Policy periodically. We will post any changes on our website and update the effective date.

12. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at the details provided above.