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OpenWater Group

Privacy Policy

Last Updated: April 9, 2026

1. Introduction

OpenWater Group Inc., a Delaware corporation (“OpenWater Group,” “we,” “us,” or “our”), operates OpenWater, a curated professional community for experienced business professionals. This Privacy Policy (“Policy”) explains how we collect, use, share, and protect your personal information when you:

  • Visit our website at openwater.group (the “Site”)

  • Use our members-only community platform hosted on Circle, including through the Circle mobile app (together, the “Platform”)

  • Register for or attend OpenWater events through Luma, Eventbrite, or other registration services

  • Participate in OpenWater programs, including AI Bootcamps, Mastermind Forums, AI Office Hours, workshops, and local chapter gatherings

  • Communicate with us by email, phone, or through the Platform

  • Apply for or hold a Membership in OpenWater

We do not sell your personal information.

This Policy is incorporated into the OpenWater Membership Agreement by reference. By using the Site, the Platform, or participating in OpenWater, you acknowledge that you have read and understood this Policy and consent to the practices described in it.

If you have questions about this Policy, contact us at help@openwater.group.

2. Information We Collect

2.1 Information You Provide to Us

We collect personal information you voluntarily provide when you interact with OpenWater. The specific information we collect depends on how you engage with us, the features you use, and the programs you participate in. The categories of information we may collect include:

Membership application and profile information: name, email address, phone number, LinkedIn profile URL, job title, company name, professional background, industry, geographic location, and any other information you include in your application or member profile. Not all of these data points are collected from every Member; what we collect depends on the information you choose to provide and what is requested at the time.

Account credentials: username and password for your Platform account on Circle.

Member Contributions: content you post, share, or upload on the Platform, including text, comments, photos, videos, profile information, and other materials. (See Section 13 of the Membership Agreement for the license you grant us regarding Member Contributions.)

Event registration information: name, email, dietary preferences, accessibility requirements, and other information collected when you register for Events through Luma, Eventbrite, or directly through OpenWater.

Payment information: when you pay an Annual Fee, Event registration fee, or other charge, your payment may be processed by one of several providers depending on the transaction. Annual Fees and payments made directly through the Site or Platform are processed by Stripe. Event registration payments may be processed by Luma, Eventbrite, or Stripe (through Circle), depending on where the Event is listed. In all cases, OpenWater Group does not store your full credit card number, bank account number, or other sensitive payment details on our servers. Each payment processor receives and processes your payment information under its own privacy policy and terms.

Communications: information you provide when you contact us, respond to surveys, submit feedback, or participate in community programs. This includes messages sent through the Platform (Circle). OpenWater Group does not routinely access or monitor direct messages between Members on the Platform. However, we may request access from Circle in connection with a Code of Conduct investigation, safety concern, or legal requirement, to the extent Circle’s terms permit.

Event media: photographs, audio recordings, video recordings, and livestreams captured at Events, which may include your image, voice, likeness, and statements. (See Section 10 of the Membership Agreement for the media release you grant us.)

2.2 Information Collected Automatically

When you visit the Site or use the Platform (including through the Circle mobile app), we and our service providers may automatically collect:

Device and browser information: IP address, browser type and version, operating system, device type, device identifiers, mobile advertising identifiers, and language preferences. If you access the Platform through the Circle mobile app, additional device-specific data may be collected by Circle, including push notification tokens and app usage data, subject to Circle’s privacy policy and your device settings.

Usage information: pages viewed, features used, links clicked, search queries, referring URLs, date and time of visits, session duration, and other interaction data.

Location information: approximate geographic location based on your IP address.

Cookies and similar technologies: we use cookies, web beacons, pixels, and similar tracking technologies to collect information about your browsing activity, remember your preferences, and analyze Site and Platform usage. See Section 8 (Cookies and Tracking Technologies) for more detail.

2.3 Information from Third Parties

We may receive information about you from:

  • Circle (our community platform provider), including your profile activity, engagement data, and content interactions on the Platform.

  • Luma and Eventbrite, including your Event registration details and attendance records.

  • Stripe, including transaction confirmations and payment status (but not your full payment card details).

  • LinkedIn or other social platforms, if you link your account or if we verify your professional profile as part of the curation process.

  • Other Members, if they refer you or provide information about you in connection with the nomination and curation process.

3. How We Use Your Information

We use the information we collect for the following purposes:

To provide and manage your Membership: processing your application, setting up your account, providing access to the Platform and Events, communicating about your Membership, and processing payments.

To operate and improve OpenWater: administering programs, facilitating networking, managing local chapters, organizing Events, improving the Platform, developing new features, and analyzing community engagement and growth.

To communicate with you: sending service-related communications (account updates, billing, renewal notices, security alerts), newsletters, event announcements, program updates, and promotional materials as described in Section 15 of the Membership Agreement.

To curate the community: reviewing applications, verifying professional backgrounds, maintaining membership standards, and ensuring the quality and integrity of the community.

To create anonymized and aggregated data: as described in Section 14 of the Membership Agreement, we may anonymize, de-identify, and aggregate Member Data for research, reports, marketing, presentations to corporate partners and investors, benchmarking, and other business purposes. Once anonymized, this data is no longer personal information and may be used without restriction.

To enforce our agreements and policies: investigating potential violations of the Membership Agreement, Code of Conduct, or Terms of Service, and taking enforcement action as appropriate.

To protect our rights and safety: detecting, preventing, and addressing fraud, security incidents, technical issues, and other harmful or unauthorized activity.

To comply with legal obligations: responding to legal process, cooperating with government investigations, and fulfilling regulatory requirements.

To support corporate partnerships: sharing anonymized and aggregated community data (never individual personal information without your consent) with current or prospective corporate sponsors, partners, and collaborators to demonstrate the value and composition of the OpenWater community.

4. How We Share Your Information

We do not sell your personal information. We share your information only in the following circumstances:

4.1 With Other Members

Your profile information (name, professional title, company, location, and other details you include in your Platform profile) is visible to other Members on the Platform. Your Member Contributions are visible to other Members and, depending on the context, may be visible to guests or the public. You control what you post, and you should only share information on the Platform that you are comfortable making available to other Members.

4.2 With Service Providers

We share your information with third-party service providers who help us operate OpenWater, including:

  • Circle (community platform): hosts the Platform, stores your profile and content, and processes your Platform interactions.

  • Stripe (payment processing): processes Annual Fee and Event registration payments.

  • Luma and Eventbrite (event management): manages Event registration, ticketing, and attendee communications.

  • HubSpot (email and CRM): manages our contact database, sends newsletters, event announcements, and other email communications, and helps us track engagement with our communications.

  • Google Analytics 4 (website analytics): helps us understand Site and Platform usage through anonymized, aggregate usage data. Google Analytics 4 does not log IP addresses.

Our service providers are authorized to use your information only as necessary to provide services to us and are contractually required to protect your information.

Our service providers may change from time to time as we adopt new tools or replace existing ones. A current list of our key service providers is available upon request by emailing help@openwater.group. Changes to our service providers do not require an update to this Policy, provided the new provider is subject to equivalent or greater data protection obligations.

4.3 For Legal Reasons

We may disclose your information if we believe in good faith that disclosure is necessary to: comply with applicable law, regulation, legal process, or government request; enforce our Membership Agreement, Terms of Service, Code of Conduct, or other agreements; protect the rights, property, or safety of OpenWater Group, our Members, or others; or detect, prevent, or address fraud, security, or technical issues.

4.4 Business Transfers

If OpenWater Group is involved in a merger, acquisition, financing, reorganization, asset sale, or other corporate transaction, your information may be transferred as part of that transaction. We will notify you of any such transfer if required by applicable law.

4.5 With Your Consent

We may share your information with third parties when you give us explicit consent to do so.

4.6 Anonymized and Aggregated Data

We may share anonymized, de-identified, or aggregated data with corporate partners, sponsors, investors, researchers, and the public. This data does not identify you personally. For example, we may share statistics about the professional composition of the OpenWater community or insights about career transition trends among experienced professionals.

5. Data Retention

We retain your personal information for as long as your Membership is active and for a reasonable period afterward, as follows:

Active Membership: we retain your account data, profile information, Member Contributions, and associated records throughout your Membership.

After Membership ends: when your Membership terminates or expires, we deactivate your account and may retain your data for the following purposes and periods:

  • Legal compliance, tax, and accounting obligations: as required by applicable law (typically 3–7 years depending on jurisdiction and record type).

  • Dispute resolution and enforcement: for as long as reasonably necessary to resolve any pending disputes, enforce the Membership Agreement, or protect our legal rights.

  • Internal record-keeping: we may retain basic records of your Membership (name, dates of Membership, reason for termination) indefinitely for internal administrative purposes.

  • Member Contributions: content you posted on the Platform may be retained on the Platform or in our records as permitted by the Member Contribution License in Section 13 of the Membership Agreement.

  • Anonymized and aggregated data: data that has been anonymized or aggregated is no longer personal information and may be retained and used indefinitely.

If you request deletion of your personal information (see Section 7), we will delete or anonymize it to the extent required by applicable law, subject to the retention exceptions described above.

6. Data Security

We implement reasonable technical and organizational measures to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. These measures include encryption, access controls, secure data storage, and regular review of our security practices.

However, no method of electronic transmission or storage is completely secure. We cannot guarantee the absolute security of your information. You are responsible for maintaining the confidentiality of your account credentials and for notifying us promptly if you suspect unauthorized access to your account.

7. Your Rights and Choices

7.1 All Members

Regardless of where you are located, you may:

  • Access and update your profile information through the Platform at any time.

  • Opt out of marketing communications by following the unsubscribe instructions in any marketing email. You cannot opt out of service-related communications (account updates, billing, renewal notices, security alerts, and legal notices).

  • Request a copy of the personal information we hold about you by emailing help@openwater.group.

  • Request deletion of your personal information by emailing help@openwater.group. We will process your request in accordance with applicable law, subject to the retention exceptions in Section 5.

  • Close your account by canceling your Membership as described in Section 7 of the Membership Agreement.

7.2 California Residents

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):

  • Right to know what personal information we collect, use, disclose, and sell (we do not sell personal information).

  • Right to delete your personal information, subject to certain exceptions.

  • Right to correct inaccurate personal information.

  • Right to opt out of the sale or sharing of personal information. We do not sell or share personal information for cross-context behavioral advertising.

  • Right to non-discrimination for exercising your privacy rights.

  • Right to limit use of sensitive personal information. We do not process sensitive personal information for purposes beyond what is necessary to provide our services.

To exercise these rights, email help@openwater.group or submit a request through our website. We will verify your identity before processing your request. You may designate an authorized agent to submit a request on your behalf, provided the agent submits proof of written authorization or a valid power of attorney.

California “Shine the Light” Law: California Civil Code Section 1798.83 permits California residents to request information about our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes.

7.3 Residents of Colorado, Connecticut, Virginia, Utah, and Other States with Privacy Laws

If you reside in a state with a comprehensive consumer privacy law, you may have the following rights (subject to applicable exemptions):

  • Right to confirm whether we are processing your personal data.

  • Right to access your personal data.

  • Right to correct inaccuracies in your personal data.

  • Right to delete your personal data.

  • Right to obtain a portable copy of your personal data.

  • Right to opt out of targeted advertising, sale of personal data, or profiling that produces legal or similarly significant effects. We do not engage in any of these activities.

To exercise these rights, email help@openwater.group. If we decline your request, you may appeal by emailing the same address. We will respond to appeals within the timeframe required by your state’s law.

7.4 International Members

OpenWater is based in the United States. If you access the Site or Platform from outside the United States, you understand and consent to the transfer, storage, and processing of your personal information in the United States, where data protection laws may differ from those in your country. If you are located in the European Economic Area, United Kingdom, or Switzerland and believe you have rights under the General Data Protection Regulation (GDPR) or equivalent law, please contact us at help@openwater.group and we will work with you to address your request.

8. Cookies and Tracking Technologies

We use cookies and similar technologies on the Site and Platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze usage patterns.

For a detailed list of the specific cookies we use, their purposes, and their durations, please see our Cookie Policy at openwater.group/cookie-policy/.

Types of cookies we use:

  • Essential and functional cookies: required for the Site and Platform to function properly. These include HubSpot cookies for form tracking and visitor identification, and Google reCAPTCHA cookies for spam protection on application forms. You cannot opt out of essential cookies.

  • Analytics cookies: help us understand how visitors use the Site and Platform, including page views, traffic sources, and engagement metrics. We plan to use Google Analytics 4 for this purpose. Google Analytics 4 collects anonymized, aggregate usage data and does not log IP addresses. We will update our Cookie Policy when analytics cookies are activated.

We do not use advertising or retargeting cookies. We do not serve targeted advertisements on the Site or Platform.

Managing cookies: you can control cookies through your browser settings. Most browsers allow you to block or delete cookies. However, blocking essential cookies may prevent you from using certain features of the Site or Platform. For more information about the specific cookies we use and how to manage them, see our Cookie Policy at openwater.group/cookie-policy/ or your browser’s help documentation.

9. Children

OpenWater is designed for professionals aged 18 and older. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected information from a person under 18, we will take steps to delete it promptly. If you believe we have collected information from a minor, contact us at help@openwater.group.

10. Third-Party Links and Services

The Site and Platform may contain links to third-party websites, services, or resources. This Policy does not apply to those third-party services. We are not responsible for the privacy practices of any third party. We encourage you to review the privacy policies of any third-party service before providing your information. Key third-party services used by OpenWater include:

  • Circle (Platform and mobile app): https://circle.so/privacy. The Circle mobile app is also subject to the terms of the applicable app store (Apple App Store or Google Play).

  • Stripe: https://stripe.com/privacy

  • Luma: https://luma.com/privacy-policy

  • Eventbrite: https://www.eventbrite.com/privacypolicy

  • HubSpot: https://legal.hubspot.com/privacy-policy

These service providers may change from time to time. Contact us at help@openwater.group for a current list.

11. Do Not Track

Some browsers send a “Do Not Track” (DNT) signal. There is no uniform standard for responding to DNT signals. At this time, we do not respond to DNT signals. If a standard is adopted in the future, we will update this Policy accordingly.

12. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, services, or legal requirements. When we make changes, we will update the “Last Updated” date at the top of this Policy. If we make material changes, we may notify you by email or through the Platform. Your continued use of the Site, Platform, or participation in OpenWater after the effective date of any update constitutes your acceptance of the updated Policy.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, contact us at:

OpenWater Group Inc.

131 Continental Dr. Suite 305, Newark, DE 19713

Email: help@openwater.group

Web: https://openwater.group

This Privacy Policy is part of the OpenWater Membership Agreement. Please review both documents to understand your rights and obligations as a Member.

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