Open Management Privacy Policy
Last Updated: 03/13/2026
Effective Date: 03/16/2026
Introduction
This Privacy Policy describes how Open Management, a New York limited liability company, and its subsidiaries and affiliates (collectively, “Company,” “we,” “our” or “us”) collect, use, and disclose information about visitors and users (collectively, “users”) of our websites, online features, products, and services that link to this Privacy Policy (each a “Site,” or collectively, “our Sites”). For the purposes of this Privacy Policy, Company is the controller (i.e., responsible party) for the Personal Information addressed in this Privacy Policy.
If you have any questions or concerns about our use of your Personal Information, please contact us using the information provided in the “Contact Us” section of this Privacy Policy.
Collection and Use of Your Personal Information
Company recognizes and respects the privacy of our customers, suppliers, and web visitors. “Personal Information” generally refers to any information that can be linked to an identified or identifiable person. The Personal Information that we collect about you varies depending on the context of our interactions with you. The following describes the type of Personal Information that we collect from you for our purposes and how we use that information. We also provide information regarding the legal basis of processing such Personal Information, as required by certain privacy laws.
| Context | Types of Data | Primary Purpose for Collection and Use of Data |
|---|---|---|
| Customer Relationship Management | We collect certain contact and related business information about you (name, email address, professional and/or personal contact information) and order history when you or your organization obtains products or services from us. We also use such information to administer and maintain our relationship with your organization and/or you. In some instances, we may collect certain background or screening information to the extent needed and in accordance with applicable law. | We may use this information to provide services to our customers and perform our contract with your organization. |
| Supplier Relationship Management | We collect certain contact and related business information (name, email address, professional contact information) when you or your organization provides us with certain services. We also use such information to administer and maintain our relationship with your organization. In some instances, we may collect certain background or screening information to the extent needed and in accordance with applicable law. | We may use this information to administer our relationship with our suppliers and perform our contract with your organization. |
| Site Analytics/Cookies | We use cookies and other methods to track Site activity. For more information relating to the use of such tools, review the “Cookies and Similar Technologies” section below. | We may use this information to make our Site operate efficiently, to provide account-related functionalities, to improve our platform, services and product offerings, and to maintain security standards. |
| Email Interconnectivity | If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains, and make purchases. For more information relating to the use of such tools, review the “Cookies and Similar Technologies” section below. | We may use this information to understand how you interact with our communications to you. |
| Feedback/Support | If you provide us feedback or contact us for support, we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply. | We may use this information in order to receive, and act upon, your feedback or issues. |
| Mobile Devices | We collect information from your mobile device such as unique identifying information broadcast from your device. For more information relating to the use of such tools, review the “Cookies and Similar Technologies” section below. | We may use this information to identify unique visitors and understand how users interact with us on their mobile devices. |
| Social Media Information | We may collect certain information related to your social media usage as it relates to us. | We may use this information to understand your usage of and interactions with our social media sites as it relates to us and to generate related content. We may also use such information to offer you information related to our promotional material, as detailed below. |
| Website Interactions | We use technology to monitor how you access and interact with our Site. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser. For more information relating to the use of such tools, review the “Cookies and Similar Technologies” section below. | We may use this information to understand how you interact with our Site to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also may use this information to detect and prevent fraud. |
| Web Logs | We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors. For more information relating to the use of such tools, review the “Cookies and Similar Technologies” section below. | We may use this information to monitor our networks, provide and maintain the functionality of our Site, such as by identifying and repairing errors or problems, security incidents, and investigating, preventing, or taking action regarding possible malicious, deceptive, fraudulent, or illegal activity (including attempts to manipulate or violate our policies, procedures, and terms and conditions). |
| Promotional Material | We may process your Personal Information, such as contact information and name, in order to send you promotional information about our services, special promotions (including with partners), and initiatives such as events, sweepstakes, and contests organized by Company. | We may use this information to share information about our products or services with you and otherwise provide you with marketing or promotional materials. |
| Geolocation Information | We may collect information about the location from which you are accessing our Services. For more information relating to the use of such tools, review our Cookie Policy. | We may use this information to provide our Site to you with Services and information specific to those available in your location. |
| Other | We may collect audio or video information via video conference or other online collaboration tools (in accordance with and to the extent permitted by applicable law). | We may use this information to administer our business and provide appropriate workplace tools to our employees, customers and other third parties. |
We collect Personal Information from you directly, and we may also receive Personal Information about you from other sources, including third parties (including from companies that also provide marketing lead information and/or your employer to the extent your organization is acting as our customer), business partners, our affiliates, or publicly available sources.
If you do not provide us with certain Personal Information, we may not be able to fulfill the requested purpose of collection, such as to respond to your queries or request for customer service or provide our Site to you. However, unless otherwise specified, not providing your Personal Information will not result in legal consequences for you. Although the table above describes our primary purpose in collecting your information, in many situations we have more than one purpose. As a result, our collection and processing of your information may be based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our general interest in conducting our business.
Disclosure of Your Personal Information
We may disclose the following categories of your Personal Information for business or commercial purposes to the categories of recipients listed below. Please note that because this list is comprehensive it may refer to types of information that we disclose about individuals other than yourself.
- We disclose Identifying Information, including online identifiers, to third parties that help administer, manage and analyze our programs and services, provide marketing and data analytics services, and payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention.
- We disclose Financial Information to payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention.
- We disclose Commercial Information to third parties that help administer, manage and analyze our programs and services, provide marketing and data analytics services, and payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention
- We disclose Network Activity Data to third parties that help administer, manage and analyze our programs and services, provide marketing and data analytics services, and others as needed to complete transactions and for authentication, security, and fraud prevention.
- We disclose Social Media Information to third parties that provide marketing and data analytics services.
- We disclose Geolocation Data to third parties that help administer, manage and analyze our programs and services, and provide marketing and data analytics services.
In addition to the specific situations discussed above, we may disclose your Personal Information identified above in the following situations:
- Service Providers. We may disclose such information to service providers who assist us in providing services, information technology support and customer service support.
- Affiliated Companies. We may disclose such information with subsidiaries, affiliates or joint ventures as needed to provide our services and generally as necessary in the administration of a global organization.
- Other Disclosures with Your Consent. We may ask if you would like us to disclose your information with other unaffiliated third parties who are not described elsewhere in this Privacy Policy.
- Corporate Transaction. We may disclose your Personal Information in the context of merger, consolidation or other corporate reorganization, to a purchaser of all or a portion of our assets, or pursuant to a financing arrangement or co-promotional agreement. Such recipient will be bound by terms and conditions reasonably similar to those set out in this Privacy Policy.
- Other Parties. We may disclose Personal Information in response to subpoenas, warrants, court orders, or in connection with a legal process, to comply with relevant laws, or to comply with a government request. We may also disclose such information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, risk to the safety of a person or property, or a violation of our policies.
We do not share or sell your Personal Information with third parties for their own marketing purposes.
SMS/Text Messaging Communications
If you choose to provide your mobile phone number to Company, you may receive text (SMS) messages from us related to our services, your account, your residency, or other communications relevant to your relationship with us. These messages may include service notifications, maintenance updates, billing reminders, community announcements, or other informational communications. With your consent where required by applicable law, we may also send marketing or promotional messages regarding services, offers, or initiatives provided by Company.
Consent to Receive Messages
By voluntarily providing your mobile phone number to Company, you consent to receive SMS communications from us consistent with this Privacy Policy. Your consent to receive text messages is not a condition of purchasing, renting, or obtaining services from Company.
Message Frequency
Message frequency may vary depending on your interactions with Company and the services you request or receive.
Message and Data Rates
Standard message and data rates may apply to SMS messages sent to or from your mobile device, depending on your wireless carrier and service plan.
Opt-Out
You may opt out of receiving SMS communications from us at any time by replying STOP to any text message you receive from us. After you send the message STOP, we will send a confirmation message and you will no longer receive SMS communications unless you subsequently provide consent again.
Use of SMS Data
Information collected through SMS communications, including your mobile phone number and message content, will be used solely for communication and service purposes in accordance with this Privacy Policy. We do not sell or share SMS opt-in data or phone numbers with third parties for their own marketing purposes.
Third-Party Messaging Providers
Company may use third-party service providers to facilitate SMS communications. These providers may process limited information necessary to deliver messages on our behalf and are contractually required to protect such information.
Carrier Disclaimer
Wireless carriers are not responsible for delayed or undelivered messages.
Cookies and Similar Technologies
In accordance with applicable law, we may use cookies, web beacons or other tracking technologies (collectively, “Cookies”) on our site. A cookie is a small amount of data that is transferred to visitors’ web browsers and/or stored on your device as you are browsing; they are processed and stored by your web browser.
We may use the following types of cookies on our Site:
| Cookie Type | Description |
|---|---|
| Behavioral Advertising Cookies | Advertising cookies may be placed by us or third parties to enable third party ad networks to recognize a unique cookie on your computer or mobile device. The information that is collected and shared by these types of cookies may also be linked to the device identifier of the device you are using to allow us to keep track of all the websites you have visited that are associated with the ad network. This information may be used for the purpose of targeting advertisements on our Site and third party sites based on those interests. |
| Analytics Cookies | Analytics cookies allow us to understand more about how many visitors we have to our Online Services, how many times they visit us and how many times a user viewed specific pages within our Site. Although analytics cookies allow us to gather specific information about the Site that you visit and whether you have visited our Site multiple times, we cannot use them to find out details such as your name or address. |
| Essential Cookies | These are cookies that our Site needs in order to function, and that enable you to move around and use the Site and features. Without these essential cookies, the Site will not perform as smoothly for you as we would like it to and we may not be able to provide the Site or certain services or features you request. Examples of where these cookies are used include: to determine when you are signed in, to determine when your account has been inactive, and for other troubleshooting and security purposes. |
We may use the information collected through tracking technologies for several reasons, including:
- To make our Site easier to use.
- To gather metrics about how users interact with our Site.
- For security reasons.
Do Not Track: At this time, our Site is not configured to honor browsers’ “Do Not Track” or equivalent signals.
Security of Your Personal Information
We take the privacy of your Personal Information seriously. We use commercially reasonable technical, administrative and physical security measures to protect your Personal Information, including generally accepted industry standards to protect the Personal Information submitted to us during transmission and once we receive it. However, no method of transmission over the Internet or method of electronic storage is 100 percent secure, so we unfortunately cannot guarantee absolute security. In the event of a breach that we are required by law to inform you of, we may notify you electronically, in writing, or by telephone, if permitted to do so by law. If you have reason to believe that your interaction with us is no longer secure (e.g., if you feel that the security of any account you might have with us has been compromised), please contact us immediately as detailed under the “Contact Us” heading below.
Retention of Your Personal Information
How long we retain your Personal Information depends on the context in which, and purpose for which, we collected it. We generally retain Personal Information for as long as necessary for achieving the purpose for which it was collected, unless a different retention period is required by applicable law.
Links to External Websites
This Site provides links to other websites that are not owned or controlled by Company. Please note that these websites’ privacy policies may differ from those of Company and that this Privacy Policy only applies to Personal Information collected on this Site. We have no control over third-party websites and are not responsible or liable for the privacy or business practices of any third-party websites linked on our Site. We encourage you to read the privacy policy of any website you may visit, as we are not responsible for such websites’ content and policies.
Children’s Privacy
Company does not knowingly collect Personal Information from children under the age of 13, and users under the age of 13 should not submit any Personal Information to Company. If you learn that your child has provided us with Personal Information without your consent and he/she is under the age of 13, please alert us at the contact information detailed in the “Contact Us” section below. We will take prompt steps to remove the Personal Information from our systems.
Artificial Intelligence
We use Artificial Intelligence (AI) tools and models to help provide, secure, and improve our products and services. This section explains how we use AI to process Personal Data, what we collect in connection with AI features, and how we comply with applicable privacy requirements.
| How We Use AI | We may use AI to: (a) personalize content, recommendations, and user experiences; (b) analyze usage trends, detect anomalies, and prevent fraud or abuse; (c) enhance customer support, including through chat and email assistance; (d) automate or assist internal operations such as quality assurance, analytics, and product development; and (e) enable user-facing features that transform, summarize, generate, or classify content. Where AI outputs are provided to you, they are generated based on patterns in data and may not always be accurate. You should evaluate outputs for your use case and avoid sharing sensitive Personal Data where not necessary. |
| Personal Data Processed by AI | Depending on your interactions with us, the categories of Personal Data processed by AI may include: (a) account identifiers and contact information; (b) device and usage data; (c) content you submit (such as messages, files, or prompts); and (d) in limited cases, demographic or preference information you provide. We do not intentionally use AI to create profiles that produce legal or similarly significant effects without your consent or another lawful basis. We do not sell Personal Data to third parties or share it for cross-context behavioral advertising without providing required notices and choices. |
| Data Collection Related to AI Features |
|
| Sources, Disclosures and Service Providers | We may use service providers and processors to host, operate, or assist AI features. These parties are bound by written contracts that limit their processing to our documented instructions, require confidentiality and appropriate security, and prohibit retaining, using, or disclosing Personal Data for purposes other than providing services to us. We may also use third-party AI application programming interfaces (APIs) or platforms; when we do, we evaluate their privacy and security practices and apply safeguards such as encryption in transit and data minimization. We do not allow service providers to use AI outputs or your Personal Data to build or improve their generalized models, except as expressly permitted by our contract and applicable law. |
| Automated Decision-Making | We do not rely solely on automated decision-making that produces legal or similarly significant effects about individuals without meaningful human involvement, unless permitted by law and supported by appropriate safeguards. Where such processing occurs, we will provide you with additional information about the logic involved, the significance and potential consequences, and your available rights, and we will obtain consent where required. |
| Legal Bases, Notices and Choices | We process Personal Data for AI features based on one or more of the following: your consent; performance of a contract; our legitimate interests in providing, improving, and securing our services; or compliance with legal obligations. Where consent is the applicable basis, you may withdraw it at any time. You may opt out of certain personalization or targeted advertising by using settings within your account, device, or browser, or by contacting us at the contact information provided below. |
| Data Retention | We retain AI-related inputs, outputs, logs, and feedback for as long as necessary to fulfill the purposes described above, comply with our legal obligations, resolve disputes, and enforce our agreements, after which we delete or de-identify the data. Specific retention periods are set forth in our internal retention schedule and are available upon request at the contact information provided below. |
| Data Security | We implement administrative, technical, and physical safeguards appropriate to the sensitivity of the Personal Data processed by AI, including access controls, encryption in transit, secure development and testing environments, data segregation, and vendor oversight. We regularly assess AI systems for privacy, security, and fairness risks and apply risk-based controls. |
| Privacy Rights | Depending on your jurisdiction and subject to legal limitations, you may have rights to access, correct, delete, or obtain a copy of your Personal Data, to opt out of certain processing (including targeted advertising or profiling), and to limit the use and disclosure of sensitive Personal Data. Texas residents may have additional choices regarding targeted advertising and profiling. You can exercise your rights by contacting us as indicated below. We will verify requests and respond within applicable timeframes. |
| Cross-Border Transfers | If Personal Data processed by AI is transferred outside of your jurisdiction, we will implement appropriate transfer mechanisms and safeguards, such as contractual protections and assessments of recipient protections, consistent with applicable requirements. |
| Children | Our AI features are not directed to children, and we do not knowingly use AI to profile or target children. If we learn we have collected Personal Data from a child contrary to this policy, we will take appropriate steps to delete it. |
| Changes and Contact | We may update this AI section from time to time to reflect changes in our practices or legal requirements. Material changes will be communicated as required. |
Your Rights
Depending on where you are located, you may have additional rights, as detailed below.
- Right to request access to your Personal Information: You may have the right to obtain from us confirmation as to whether or not Personal Information concerning you is being processed, and, where that is the case, to request access to the Personal Information. This access information includes the purposes of the processing, the categories of Personal Information concerned, and the recipients or categories of recipient to whom the Personal Information have been or will be disclosed. However, this is not an absolute right and the interests of other individuals may restrict your right of access. We may charge a reasonable fee based on administrative costs.
- Right to request modification: You may have the right to request correction of inaccurate Personal Information we may have about you.
- Right to request deletion: Under certain circumstances, you may have the right to obtain from us the deletion of Personal Information concerning you, and we may be obliged to delete such Personal Information.
- Right to request data portability: Under certain circumstances, you may have the right to receive the Personal Information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, and you may have the right to transmit those data to another entity without hindrance from us.
- Right to object: Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your Personal Information by us, and we can be required to no longer process your Personal Information. Such right to object may especially apply if we collect and process your Personal Information for profiling purposes in order to better understand your interests in our services or for direct marketing. If you have a right to object and you exercise this right, your Personal Information will no longer be processed for such purposes by us. You may exercise this right by contacting us as stated in the “Contact Us” section of this Privacy Policy. Such a right to object may, in particular, not exist if the processing of your Personal Information is necessary to take steps prior to entering into a contract or to perform a contract already concluded.
- Right to Know what Personal Information is Sold or Shared and to Whom. At the current time, Company does not sell or share your Personal Information with third parties for their marketing purposes.
- Right to Opt-Out of the Sale or Sharing of Personal Information. At the current time, Company does not sell or share your Personal Information with third parties for their marketing purposes.
- Right to Limit the Use and Disclosure of Sensitive Personal Information. We will only use sensitive or special Personal Information as needed for the purposes for which it was collected. If this changes, we will notify you, and you may have the right to restrict such additional uses.
- Right to Non-Discrimination. We do not discriminate against individuals who exercise any of their rights described in this Privacy Policy. However, Company may require use of your Personal Information to provide access to the Services. Therefore, when you exercise your deletion right, in particular, you may lose access to certain aspects of the services that require your Personal Information.
If you choose to assert any of these rights under applicable law, we will respond within the time period prescribed by applicable law. Please note that many of the above rights are subject to exceptions and limitations. Your rights and our responses will vary based on your country or territory of residency.
To exercise your rights, please contact us as stated in the “Contact Us” section of this Privacy Policy. You also have the right to lodge a complaint with the competent data protection supervisory authority if we have not addressed your questions or concerns about Personal Information.
Authorized Agent
In certain jurisdictions, a person authorized to act on your behalf may make a verifiable consumer request related to your Personal Information. If you designate an authorized person to submit requests to exercise certain privacy rights on your behalf, we will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us. Your verifiable request must: (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Changes to this Privacy Policy Except to the extent limited by applicable law, we reserve the right to update this Privacy Policy to reflect changes to our practices by prominently posting notice of the update on our Site. Any updates will become effective 30 days after posting the updates to this Privacy Policy and apply to all information collected about you. If we make any changes to this Privacy Policy that materially impact previously collected Personal Information about you, we will, to the extent that we have your email address, notify you by email and/or obtain consent where required by applicable law.Contact Us
If you have any questions about this Privacy Policy, please contact us by email at compliance@openmgmt.com or by postal mail at: Open Management Attn: Compliance 169 Madison Ave #38115 New York, NY 10016
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