OpenMarket Intelligence Inc., a Delaware corporation ("OpenMarket," "we," "us," or "our"), operates the OpenMarket website and platform located at open-market.io (the "Site"). This Privacy Policy describes how we collect, use, disclose, and protect information about you when you use our Site and services. By using the Site, you agree to the collection and use of information in accordance with this Privacy Policy.

1. Information We Collect

1.1 Information You Provide

We collect information you provide directly to us, including: (a) Account Information: When you create an account, we collect your name, email address, password, professional title, firm affiliation, and other profile information you choose to provide. (b) Professional Information: Information about your professional role, investment focus, fund details (for GPs), investment criteria (for Allocators), and relevant experience. (c) Communications: Information contained in messages, posts, discussions, and other content you submit through the Site. (d) Contact Information: When you contact us for support or inquiries. (e) Survey and Feedback Data: Information you provide in response to surveys or feedback requests.

1.2 Information We Collect Automatically

When you access or use the Site, we automatically collect: (a) Log Information: IP address, browser type, operating system, referring URLs, pages viewed, links clicked, and the date and time of your visit. (b) Device Information: Information about the device you use to access the Site, including device type, operating system, and unique device identifiers. (c) Usage Information: Information about your interactions with the Site, including features used, time spent on pages, and search queries. (d) Cookies and Similar Technologies: We use cookies, web beacons, and similar technologies to collect information about your browsing activities. See Section 6 for more information.

1.3 Information from Third Parties

We may receive information about you from third parties, including: (a) publicly available sources (such as LinkedIn or your firm's website); (b) identity verification services; (c) analytics providers; and (d) other users who may provide information about you.

2. How We Use Your Information

2.1 General Use

We use the information we collect to: (a) provide, maintain, and improve the Site and our services; (b) create and manage your account; (c) facilitate connections and communications between users; (d) personalize your experience and provide content and features relevant to your interests; (e) send you technical notices, updates, security alerts, and support messages; (f) respond to your comments, questions, and customer service requests; (g) monitor and analyze trends, usage, and activities in connection with the Site; (h) detect, investigate, and prevent fraudulent transactions, abuse, and other illegal activities; (i) protect the rights, property, and safety of OpenMarket, our users, and others; (j) comply with legal obligations; and (k) for any other purpose with your consent.

2.2 Artificial Intelligence and Data Analysis

We use artificial intelligence and data analysis to operate and improve the Site. This includes:

(a) Personalization: We may use your profile information, stated preferences, and interactions with the Site to personalize your experience, including search results and content recommendations.

(b) Content Analysis: We may analyze user-generated content, such as discussion posts, to generate and update fund manager profiles, tags, and sentiment indicators. Such analysis is weighted by content quality metrics rather than user identity.

(c) Platform Improvement: We may analyze anonymized usage patterns and session flows to improve Site functionality and user experience.

Any insights derived from user content or activity that are made available to other users or third parties are provided in aggregated or anonymized form and are subject to the safeguards described in Section 3.6.

3. How We Share Your Information

3.1 With Other Users

Your profile information and content you post on the Site will be visible to other users in accordance with your privacy settings and user type. Allocators can view content shared within their communities and may view other allocators' profiles and activity in accordance with platform settings. Fund managers ("GPs") and service providers can view their own profiles and aggregated market insights, but cannot access individual allocator identities, search activity, discussion content, or intent signals, unless explicitly permitted by the allocator.

3.2 With Service Providers

We may share your information with third-party service providers who perform services on our behalf, such as hosting providers, analytics providers, email delivery services, and customer support providers. These service providers are contractually obligated to use your information only for the purposes of providing services to us.

3.3 For Legal Purposes

We may disclose your information if we believe it is necessary to: (a) comply with applicable law, regulation, legal process, or governmental request; (b) enforce our Terms of Service and other agreements; (c) protect our rights, privacy, safety, or property, or that of our users or the public; (d) detect, prevent, or address fraud, security, or technical issues; or (e) protect against legal liability.

3.4 Business Transfers

If OpenMarket is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any change in ownership or uses of your personal information.

3.5 With Your Consent

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

3.6 Aggregated or De-Identified Information

We may share aggregated or de-identified information that cannot reasonably be used to identify you.

4. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements. When determining the retention period, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your information, and whether we can achieve those purposes through other means. When we no longer need your information, we will delete or anonymize it.

5. Data Security

We implement appropriate technical and organizational measures designed to protect your personal information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for any activities that occur under your account. In the event of a data breach that affects your personal information, we will notify you in accordance with applicable law. Depending on the nature and scope of the breach and legal requirements, we may notify you by email, by posting a notice on the Site, or through other appropriate means.

6. Cookies and Tracking Technologies

6.1 Types of Cookies We Use

We use the following types of cookies: (a) Essential Cookies: Necessary for the Site to function properly and cannot be disabled. (b) Analytics Cookies: Help us understand how visitors interact with the Site by collecting and reporting information anonymously. (c) Functionality Cookies: Enable enhanced functionality and personalization, such as remembering your preferences. (d) Marketing Cookies: Used to track visitors across websites to display relevant advertisements.

6.2 Your Cookie Choices

Most web browsers are set to accept cookies by default. You can usually choose to set your browser to remove or reject cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Site.

6.3 Do Not Track

Some browsers have a "Do Not Track" feature that lets you tell websites that you do not want to have your online activities tracked. We currently do not respond to "Do Not Track" signals.

7. Your Privacy Rights

7.1 Access and Correction

You may access, update, or correct your account information at any time by logging into your account settings. You may also contact us to request access to or correction of your personal information.

7.2 Deletion

You may request deletion of your account and personal information by contacting us at support@open-market.io. Please note that we may retain certain information as required by law or for legitimate business purposes.

7.3 Marketing Communications

You may opt out of receiving marketing communications from us by following the unsubscribe instructions in those communications or by contacting us. Even if you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.

8. California Privacy Rights

If you are a California resident, you have certain rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including: (a) the right to know what personal information we collect, use, disclose, and sell; (b) the right to delete your personal information; (c) the right to opt out of the sale or sharing of your personal information; (d) the right to correct inaccurate personal information; and (e) the right to non-discrimination for exercising your privacy rights. To exercise these rights, please contact us at support@open-market.io. We do not sell personal information as defined under the CCPA/CPRA. In the past 12 months, we have collected the following categories of personal information: identifiers (name, email address, IP address); commercial information (subscription information, payment history); internet or other electronic network activity information (usage data, device information, log data); and professional or employment-related information (professional role, firm affiliation, investment experience) if you provide it in the context of using the Site.

9. International Data Transfers

Your information may be transferred to, and processed in, countries other than your country of residence. These countries may have data protection laws that are different from the laws of your country. By using the Site, you consent to the transfer of your information to the United States and other jurisdictions where we or our service providers operate.

10. Children's Privacy

The Site is not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under 18, we will take steps to delete such information promptly.

11. Third-Party Links

The Site may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to read the privacy policies of any third-party websites or services you visit.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by email (sent to the email address specified in your account) or by posting a notice on the Site prior to the change becoming effective. We encourage you to review this Privacy Policy periodically. Your continued use of the Site after any changes indicates your acceptance of the updated Privacy Policy.

13. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at:

OpenMarket Intelligence Inc.
Attn: Privacy
Email: support@open-market.io