Insider trading laws apply to private companies as well. (No idea about the legal questions on this particular case though)
privately held securities as well as non-equity securities can be involved in insider trading, specifically it is a fraud doctrine instead of a "publicly traded equity" doctrine, so it is quite flexible
for different reasons Carta's solicitation doesn't necessarily trigger that, by mere nature of contacting people
+1
affiliates (insider) have to certify below a certain threshold its a private buyer and a private seller so no biggie