Privacy Statement &
Terms of Service

2.1 Data You Provide Directly

When you interact with Portal forms or contact mechanisms, we may collect:

• Identity data — name, title, organisation (if voluntarily provided in correspondence)
• Contact data — email address (for newsletter/alert subscriptions and enquiry responses)
• Community submission data — any information you voluntarily submit through our community intelligence submission forms, including textual descriptions and attachments
• Correspondence data — content of emails, messages, or feedback submitted to us

2.2 Data Collected Automatically

When you access the Portal, our hosting infrastructure may automatically collect:

• Usage data — pages viewed, documents accessed, time spent, navigation paths
• Technical data — IP address (anonymised where possible), browser type and version, device type, operating system, screen resolution
• Referral data — the URL of any page from which you navigated to our Portal

2.3 Data We Do Not Collect

2.4 Community Submissions — Source Protection

Carbotura is committed to source protection. Any individual who submits information to the Portal through our community intelligence submission mechanism may do so anonymously. We do not require you to identify yourself to submit information of public interest. Where you do choose to provide contact details, those details are held separately from any submitted content and are used only to communicate with you regarding your submission.

We process personal data only where we have a lawful basis to do so. The following table summarises our processing activities:

4.1 We Do Not Sell Your Data

Carbotura does not sell, rent, or trade personal data to third parties for commercial purposes under any circumstances.

4.2 Service Providers

We may share limited data with trusted third-party service providers who support Portal operations, including:

• Hosting and content delivery providers
• Email delivery services (for subscription fulfilment)
• Analytics services (using anonymised or pseudonymised data only)
• Security and monitoring services

All such providers are bound by data processing agreements and may only process data for the specific purposes we specify.

4.3 Legal Disclosure

We may disclose personal data where required by law, court order, or the lawful request of a competent authority. We will, where legally permissible, notify affected individuals of such disclosures.

4.4 Business Transfers

In the event of a merger, acquisition, or transfer of substantially all of Carbotura's assets, personal data held by us may be transferred to the successor entity, subject to equivalent privacy protections.

4.5 Source Confidentiality

The Portal uses a minimal, privacy-respecting approach to cookies and local storage. The following table describes all mechanisms in use:

You may disable cookies and clear localStorage at any time through your browser settings. Disabling functional storage will not prevent access to Portal content but may affect theme and preference persistence.

6.1 Retention Periods

• Subscription email addresses — retained for the duration of your subscription plus 30 days after unsubscribe
• Enquiry correspondence — retained for 24 months from the date of last correspondence
• Community submission data — retained for as long as required for the public interest purpose for which it was submitted, with a minimum review at 5 years
• Server logs (technical data) — retained for up to 90 days, then deleted or irreversibly anonymised
• Analytics data — retained in aggregated, anonymised form only; individual-level data purged within 13 months

6.2 Security Measures

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or destruction. These include:

• HTTPS encryption for all Portal connections (TLS 1.2 minimum)
• Access controls limiting data access to authorised personnel only
• Regular security reviews of Portal infrastructure
• Separation of submission contact data from submitted content

Depending on your jurisdiction, you may have the following rights regarding your personal data. To exercise any of these rights, contact us at privacy@carbotura.com.

We will respond to valid rights requests within 30 days of receipt. We may request proof of identity before processing a request to protect against unauthorised access to data.

The Portal is directed at adults and is not intended for use by persons under the age of 16. We do not knowingly collect personal data from children under 16. If we become aware that a child under 16 has submitted personal data to us without verifiable parental consent, we will delete that data promptly.

If you believe we have inadvertently collected data from a child, please contact us immediately at privacy@carbotura.com.

We may update this Privacy Statement from time to time to reflect changes in our practices, legal obligations, or Portal functionality. Material changes will be notified to newsletter subscribers by email and announced prominently on the Portal for a period of not less than 30 days prior to the change taking effect.

The "Last Reviewed" date at the top of this document indicates when the statement was most recently updated. Your continued use of the Portal after the effective date of any change constitutes your acceptance of the updated statement.

The Portal provides community-facing environmental intelligence reports, partnership briefing documents, data analyses, and related materials produced by Carbotura Inc. in connection with its Advanced Circular Management (ACM) programme and community engagement work. The Portal is provided as a public transparency service.

11.1 Nature of Content

• Portal documents are intelligence and analytical reports, not professional legal, financial, engineering, or investment advice
• Financial projections and modelled outcomes are expressly illustrative; they do not constitute forecasts or guarantees
• Documents are produced in good faith from available public-record sources and may be subject to revision as new information becomes available
• The Portal does not constitute an offer to enter any contractual arrangement

11.2 Service Availability

Carbotura aims to maintain continuous Portal availability but does not guarantee uninterrupted access. We reserve the right to suspend, modify, or discontinue any part of the Portal at any time, with reasonable notice where practicable.

Core Portal content is accessible without registration, in compliance with Transparency Standard 9 (no registration wall, no paywall). Certain services — including newsletter subscriptions, community submission forms, and partner-portal access — may require you to provide contact information or create credentials.

12.1 Account Responsibilities

• You are responsible for maintaining the confidentiality of any credentials you create
• You must provide accurate and truthful information when registering for any Portal service
• You must notify us immediately of any unauthorised use of your account at security@carbotura.com
• You may not create accounts using automated means or create multiple accounts to circumvent access controls

12.2 Partner Portal Access

Access to restricted partner-facing sections of the Portal (where applicable) is governed by the terms of the applicable partnership or engagement agreement, which take precedence over these general Terms in the event of conflict.

13.1 Permitted Uses

You may access and use the Portal for the following purposes:

• Personal, non-commercial research and reference
• Journalistic reporting and public interest commentary, subject to appropriate attribution
• Academic research and education, with proper citation
• Community engagement and civic participation activities
• Internal briefing within your organisation, provided content is not redistributed commercially

13.2 Prohibited Conduct

You must not:

• Use the Portal or its content for any unlawful purpose or in violation of these Terms
• Reproduce, republish, or redistribute Portal content for commercial gain without prior written consent from Carbotura
• Misrepresent the source, authorship, or conclusions of any Portal document
• Selectively quote or edit Portal documents in a manner that materially misrepresents their findings
• Attempt to gain unauthorised access to restricted Portal areas, servers, or databases
• Introduce malware, scrapers, or automated bots that disrupt Portal operation or circumvent rate-limiting measures
• Use Portal data to harass, intimidate, or harm any individual named therein
• Conduct denial-of-service attacks or any action that degrades Portal availability
• Circumvent, disable, or interfere with security features of the Portal

All content published on the Portal — including but not limited to reports, documents, analyses, data visualisations, graphics, the Carbotura name and logo, and the underlying HTML, CSS, and JavaScript of Portal documents — is the intellectual property of Carbotura Inc. or its licensors and is protected by applicable copyright, trademark, and other intellectual property laws.

14.1 Limited Licence

Subject to these Terms, Carbotura grants you a non-exclusive, non-transferable, revocable licence to access and use Portal content for the permitted purposes set out in Section 13.1. This licence does not include the right to sublicense, commercially exploit, create derivative works from, or redistribute Portal content in bulk.

14.2 Open Public Interest Content

EIR and Community Briefing documents are made available for public transparency purposes. Journalists, researchers, and civic advocates are encouraged to reference and quote from these documents in the public interest, with attribution. This encouragement does not waive Carbotura's copyright in the underlying works.

14.3 Trade Marks

"Carbotura", the Carbotura logo, "ACM" (in the context of Carbotura's Advanced Circular Management programme), and associated trade marks are the property of Carbotura Inc. They may not be used without prior written consent in any way that implies endorsement, partnership, or affiliation not expressly authorised.

The Portal may provide mechanisms through which members of the public can submit information, intelligence, documents, or commentary for consideration by Carbotura's analysts ("Submissions").

15.1 Your Representations

By making a Submission you represent that:

• The information is, to the best of your knowledge, true and accurate
• You have the right to share the information without breaching any obligation of confidentiality, any third-party intellectual property rights, or any applicable law
• The Submission does not contain malicious code, spam, or content that is defamatory, harassing, or unlawful

15.2 Licence Grant

By submitting content, you grant Carbotura a non-exclusive, worldwide, royalty-free licence to use, process, analyse, and (where appropriate and in the public interest) publish information derived from your Submission, subject to our source protection obligations described in Section 4.5 of the Privacy Statement.

15.3 No Obligation to Publish

Carbotura is under no obligation to act upon, publish, or respond to any Submission. We reserve editorial discretion over all published Portal content.

16.1 Financial Projections

All financial projections, modelled revenue figures, cost estimates, and economic analyses published on the Portal are expressly illustrative. They are produced for the purpose of community transparency and informed public debate. They are based on stated assumptions, are subject to material uncertainty, and do not constitute financial forecasts or guarantees of any kind. Carbotura accepts no liability for decisions made in reliance on illustrative financial content.

16.2 As-Is Provision

The Portal and all content are provided on an "as is" and "as available" basis without warranty of any kind, express or implied, including but not limited to warranties of merchantability, fitness for a particular purpose, accuracy, completeness, or non-infringement. Carbotura makes reasonable efforts to ensure content accuracy but does not warrant that Portal content is free from error.

16.3 Third-Party Links

Portal documents may reference or link to third-party sources. Carbotura does not endorse and accepts no responsibility for the content, accuracy, or practices of any third-party website or publication.

To the fullest extent permitted by applicable law, Carbotura Inc., its directors, officers, employees, agents, and affiliates shall not be liable for any indirect, incidental, special, consequential, exemplary, or punitive damages arising out of or in connection with:

• Your access to or use of, or inability to access or use, the Portal
• Any reliance placed on Portal content, including illustrative financial projections
• Unauthorised access to, or alteration of, your transmissions or data
• Any other matter relating to the Portal

Where liability cannot be excluded by law, Carbotura's total aggregate liability to you for all claims arising out of or related to these Terms or the Portal shall not exceed £100 GBP (or local currency equivalent).

You agree to indemnify, defend, and hold harmless Carbotura Inc. and its officers, directors, employees, and agents from and against any claims, liabilities, damages, losses, and expenses (including reasonable legal fees) arising out of or in any way connected with:

• Your violation of these Terms
• Your violation of any applicable law or regulation
• Any Submission you provide that is inaccurate, unlawful, or infringes any third-party right
• Your misuse of Portal content

Carbotura reserves the right to suspend or terminate your access to any part of the Portal, without notice or liability, if we reasonably believe you have violated these Terms or applicable law, or if continued access poses a risk to the Portal, other users, or third parties.

Sections 14 (Intellectual Property), 16 (Disclaimers), 17 (Limitation of Liability), 18 (Indemnification), and 20 (Governing Law) survive any termination of these Terms.

20.1 Governing Law

These Terms and any dispute or claim arising out of or in connection with them (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws of England and Wales, without regard to conflict-of-law principles.

20.2 Jurisdiction

Subject to clause 20.3, the courts of England and Wales shall have exclusive jurisdiction to settle any dispute or claim arising out of or in connection with these Terms or their subject matter or formation.

20.3 Dispute Resolution — Good Faith

Before commencing formal legal proceedings, the parties agree to endeavour in good faith to resolve any dispute through direct negotiation. Either party may initiate this process by providing written notice of the dispute to the other. If the dispute is not resolved within 30 days of such notice, either party may proceed to litigation.

20.4 Jurisdiction-Specific Addenda

Where Carbotura operates in jurisdictions with mandatory consumer or data protection laws that override these Terms, those laws apply. Specific addenda for Wales (UK GDPR), European Union (EU GDPR), and other jurisdictions are available upon request from legal@carbotura.com.

Future versions will be logged here with a summary of material changes. Subscribers will be notified of material changes by email prior to the effective date.