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Legal

Privacy Policy

Last updated: August 10, 2026

Attorney review required: This document is professional placeholder legal copy provided as a starting template. It has not been reviewed by an attorney. Have a qualified attorney review and customize it for your business and jurisdiction before publication.

This Privacy Policy explains how Cash’s Inner Circle LLC (“OpenFlow,” “we,” “us,” or “our”) collects, uses, shares, and protects personal information when you visit our website, use our software and services, submit an application, or otherwise interact with us (collectively, the “Services”). By using the Services, you agree to the practices described in this Policy.

1. Information We Collect

Information you provide to us

  • Account information: name, email address, username, password, and billing details when you create an account or purchase a subscription.
  • Application form information: details you submit when applying for access, such as your name, email, trading experience, the platforms and prop firms you use, account size range, goals, and any free-text responses you choose to provide.
  • Communications: the contents of messages you send us by email, contact forms, or community channels, and any support requests.

Information collected automatically

  • Usage data: pages viewed, features used, session timestamps, referring pages, and interactions with the Services.
  • Device and log data: IP address, browser type, operating system, device identifiers, and error logs.
  • Software telemetry: configuration and diagnostic data generated by the automation software, such as connection status and error events.

2. How We Use Information

We use personal information to:

  • provide, operate, maintain, and improve the Services;
  • process applications, payments, and subscription management;
  • provide customer support and respond to your requests;
  • send transactional messages (receipts, service notices, security alerts);
  • send marketing communications where permitted by law, which you can opt out of at any time;
  • monitor, detect, and prevent fraud, abuse, and security incidents;
  • comply with legal obligations and enforce our agreements.

3. Legal Bases for Processing

Where laws such as the EU/UK General Data Protection Regulation apply, we process personal information on the following legal bases: (a) performance of a contract, when processing is necessary to provide the Services you purchased or requested; (b) legitimate interests, such as securing and improving the Services and communicating with prospective customers, balanced against your rights; (c) consent, for certain marketing and non-essential cookies, which you may withdraw at any time; and (d) legal obligation, where processing is required by applicable law.

4. How We Share Information

We do not sell your personal information. We share it only with service providers and in the limited circumstances described below:

  • Hosting and infrastructure providers that host our website, databases, and application services;
  • Payment processors that handle checkout, billing, and subscription management on our behalf (we do not store full card numbers on our systems);
  • Email and communication providers used to send transactional and marketing messages;
  • Analytics providers as described in Section 5;
  • Professional advisers and authorities where disclosure is reasonably necessary to comply with law, respond to legal process, enforce our agreements, or protect the rights, safety, or property of OpenFlow, our users, or others; and
  • Business transfers, if we are involved in a merger, acquisition, financing, or sale of assets, in which case personal information may be transferred as part of that transaction subject to this Policy.

Service providers are contractually required to process personal information only on our instructions and to protect it appropriately. Our current core providers include our website hosting provider (Vercel), our checkout and membership platform (Whop), and our community platform (Discord).

5. Cookies and Analytics

The website itself uses only the cookies and similar technologies needed for it to function, and does not set marketing or advertising cookies. Third-party services you interact with through the Services — such as our checkout platform or community platform — may set their own cookies, which are governed by those providers’ own policies. You can control cookies through your browser settings; disabling certain cookies may limit functionality.

6. Data Retention

We retain personal information for as long as needed to provide the Services and for legitimate business purposes, such as maintaining records of transactions, complying with legal, tax, and accounting obligations, resolving disputes, and enforcing agreements. When personal information is no longer needed, we delete or anonymize it. Billing records are retained for the period required by applicable tax law.

7. Security

We use administrative, technical, and organizational safeguards designed to protect personal information, including encryption in transit, access controls, and least-privilege practices. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your account credentials confidential.

8. Your Rights

Depending on your jurisdiction, you may have the right to: access the personal information we hold about you; request correction of inaccurate information; request deletion of your information; object to or restrict certain processing; request portability of your information; and withdraw consent where processing is based on consent. You may also have the right to lodge a complaint with a supervisory authority.

To exercise any of these rights, contact us through the official OpenFlow Discord community. We will verify your identity before acting on a request and will respond within the timeframe required by applicable law. We will not discriminate against you for exercising your rights.

9. International Transfers

The service providers we use may store or process information in other countries. Where personal information is transferred out of a jurisdiction that restricts international transfers, we rely on appropriate safeguards such as standard contractual clauses or other lawful transfer mechanisms.

10. Children

The Services are intended for adults and are not directed at anyone under 18 years of age. We do not knowingly collect personal information from anyone under 18. If you believe a person under 18 has provided us personal information, contact us through the official OpenFlow Discord community and we will delete it.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the updated Policy on this page and revise the “Last updated” date. For material changes, we will provide additional notice where required (such as email notice). Your continued use of the Services after changes take effect constitutes acceptance of the updated Policy.

Contact

Privacy questions and requests can be directed to Cash’s Inner Circle LLC through the official OpenFlow Discord community.