Introduction
The Operating System Company LLC (“Chapter OS,” “Company,” “we,” “us,” or “our”) respects the privacy of individuals and organizations that use our websites, applications, and services.
This Privacy Policy explains how we collect, use, maintain, disclose, retain, and protect personal information in connection with Chapter OS and its related products and services.
Chapter OS is a cloud-based software-as-a-service (“SaaS”) platform designed to help entrepreneurial membership organizations, chapters, administrators, volunteer leaders, and members manage chapter operations, membership activities, peer forums, engagement, and organizational planning.
Information You Provide to Us:
Forum OS: Forum management, member participation, meetings, assessments, reflections, and accountability activities.
Membership OS: Member profiles, prospective member information, membership administration, compatibility assessments, and placement activities.
Member Engagement OS: Engagement monitoring, member outreach, participation records, and related activities.
Trifecta OS: Chapter budgeting and supported cross-functional administrative activities.
Other applications, integrations, functionality, and services that Chapter OS may introduce.
References to Chapter OS include associated websites, authorized legacy domains such as forumos.co, and related services operated by the Company.
This Privacy Policy applies to personal information processed through our Services, except where a separate agreement or privacy notice governs.
Our processing of information may also be governed by contractual agreements with subscribing organizations, including applicable Data Processing Agreements (“DPAs”).
This Privacy Policy is intended to describe our practices. It is not a substitute for any consent required by applicable law, nor does it eliminate any statutory privacy rights.
2. Our Role in Processing Personal Information
Chapter OS operates primarily as a technology service provider to subscribing organizations (“Customers” or “Chapters”).
Depending on the circumstances, we may act in different capacities.
2.1 Chapter-Controlled Information
For personal information entered, uploaded, or otherwise made available by a Chapter or its authorized users to administer its membership, forums, engagement activities, and other organizational operations, the Chapter generally determines the purposes and means of processing.
In these circumstances
The Chapter ordinarily acts as the data controller or business.
Chapter OS ordinarily acts as the data processor or service provider.
Chapter OS processes such information to provide the Services, follow the Chapter's lawful instructions, and fulfill applicable contractual and legal obligations.
Each Chapter is responsible for providing appropriate notices, establishing lawful grounds for collecting information, obtaining required consents, and determining which authorized users may access its information.
2.2 Chapter OS-Controlled Information
Chapter OS generally acts as an independent controller or business for information collected and used for its own legitimate business purposes, including:
Customer account administration.
Billing and subscription management.
Customer communications.
Website operations.
Platform security and fraud prevention.
Internal business analytics.
Legal and regulatory compliance.
2.3 Requests Concerning Chapter-Controlled Data
Individuals seeking to exercise privacy rights regarding information controlled by a Chapter should ordinarily contact that Chapter directly.
When Chapter OS receives such a request, we may refer the individual to the appropriate Chapter or assist the Chapter in responding, as required by applicable law and our contractual obligations.
Chapter OS will not independently alter or delete Chapter-controlled information contrary to a Chapter's lawful instructions unless required by law.
3. Information We Collect
The categories of personal information we collect depend on how individuals interact with the Services and which features a Chapter uses.
3.1 Chapter and Organization Information
Chapter OS generally acts as an independent controller or business for information collected and used for its own legitimate business purposes, including:
Customer account administration.
Organization website and contact information.
Authorized account representative information.
Billing address and billing country.
Subscription and account information
Chapter settings and administrative configurations.
Chapter-specific workspace identifiers.
3.2 Administrator and Authorized User Information
We may collect:
First and last name.
Business email address.
Telephone number, when provided.
Organizational role and administrative permissions.
Account credentials and authentication information.
Login records and account activity.
User preferences and configuration settings
3.3 Member and Prospective Member Information
Information submitted by Chapters or authorized users may include:
Member and prospective member names.
Email addresses and telephone numbers
Residential addresses, where provided for authorized mapping or membership purposes.
Business names, websites, and professional profiles.
Business descriptions and industry classifications.
Revenue ranges and employee counts
Business ownership information.
Entrepreneurial and professional backgrounds.
Business ownership information.
Membership application and eligibility information.
Member goals, interests, preferences, and professional connections.
Membership status, participation, and placement information.
The specific information collected may vary by Chapter, membership program, and available features.
3.4 Forum, Reflection, and Engagement Information
The Services may process information associated with peer-group participation, including:
Forum meeting agendas and attendance.
Meeting notes and accountability records
Personal and professional goals.
Forum DNA questionnaires.
Forum preferences and compatibility responses.
Engagement surveys and check-ins
Forum health assessments.
Parking lot topics and discussion records.
5% Reflections and related summaries.
Member feedback and participation history.
Important: Certain forum activities may involve highly personal or confidential information voluntarily disclosed by members.
Depending on the information submitted, this may include details about personal relationships, financial circumstances, physical or mental health, family matters, or other sensitive subjects
Chapter OS does not require individuals to disclose sensitive personal information unless such information is necessary for a specific feature and is collected through an authorized process.
Chapters and users should avoid entering sensitive information that is unnecessary for the intended purpose.
3.5 Billing and Payment Information
Payments are processed through Stripe or another authorized payment processor.
Chapter OS may receive payment-related information such as:
Billing contact information.
Subscription status.
Payment transaction identifiers.
Invoice records.
Payment confirmation and failure notifications.
Limited payment-method details made available by the payment processor.
Chapter OS does not intentionally store complete payment card numbers or card security codes on its application servers.
Payment processors may process additional information under their own privacy policies and contractual obligations.
3.6 Technical and Usage Information
We may automatically collect:
Internet Protocol (IP) addresses
Browser and operating system information.
Device characteristics.
Login timestamps.
Session identifiers
Pages and features accessed.
Platform activity and administrative actions.
Error reports and diagnostic information.
Security and authentication logs.
Important: Certain forum activities may involve highly personal or confidential information voluntarily disclosed by members.
Depending on the information submitted, this may include details about personal relationships, financial circumstances, physical or mental health, family matters, or other sensitive subjects
Chapter OS does not require individuals to disclose sensitive personal information unless such information is necessary for a specific feature and is collected through an authorized process.
Chapters and users should avoid entering sensitive information that is unnecessary for the intended purpose.
3.7 Communications
When individuals contact us, we may collect their names, email addresses, contact information, and the contents of their communications.
We use this information to respond to inquiries, provide support, and maintain appropriate business records.
4. Sources of Personal Information
We may obtain personal information:
Directly from individuals who register, communicate with us, or use the Services.
From Chapters and authorized administrators who submit member or organizational information.
Automatically through interactions with our websites and applications.
From payment processors and other service providers.
From authorized integrations and publicly available professional information, where permitted by applicable law.
We do not require Chapters to provide information that is unrelated to the legitimate purposes of the Services.
5. How We Use Personal Information
Directly from individuals who register, communicate with us, or use the Services.
From Chapters and authorized administrators who submit member or organizational information.
Automatically through interactions with our websites and applications.
From payment processors and other service providers.
From authorized integrations and publicly available professional information, where permitted by applicable law.
Service delivery: To create and manage Chapter workspaces, administer membership information, support forums, track engagement, manage budgets, and provide subscribed functionality.
Account administration: To authenticate users, administer permissions, manage invitations, and maintain user accounts.
Billing: To process subscription payments, manage invoices, administer account changes, and address billing issues
Communications: To provide onboarding messages, account notices, service updates, security notifications, and responses to inquiries.
Product improvement: To troubleshoot issues, analyze operational performance, improve usability, and develop functionality using information we are authorized to process.
Security: To detect unauthorized access, investigate suspicious activity, maintain logs, and protect the integrity of the Services.
Legal compliance: To comply with applicable laws, enforce contractual rights, respond to lawful requests, and protect our legal interests.
AI-assisted functionality: To provide authorized assessments, summaries, scoring, and other AI-supported features as described below.
We do not use Chapter-controlled personal information for unrelated purposes without an appropriate legal basis, authorization, or other lawful permission.
6. Artificial Intelligence and Automated Processing
Certain Chapter OS features may use artificial intelligence (“AI”), statistical methods, or automated processing.
Membership compatibility scoring.
Forum compatibility assessments.
Forum health scoring.
Summaries of authorized 5% Reflections.
Forum overviews and operational insights.
Other administrative recommendations or analytics.
6.1 AI Service Providers
Chapter OS may use authorized third-party AI service providers, including OpenAI and Anthropic, to support these functions.
Only information reasonably necessary for an authorized feature should be transmitted to the applicable provider.
AI providers process information subject to their applicable agreements, service terms, and data protection commitments.
6.2 Sensitive Information
Chapter OS's current policy states that sensitive health survey answers are excluded from AI processing.
Chapter OS will maintain safeguards intended to prevent designated sensitive health survey fields from being transmitted to third-party AI models.
However, free-text fields may contain sensitive information supplied by users. Chapters and users should exercise care when entering such information.
Additional sensitive-data filtering and restrictions may apply depending on the feature and applicable law.
6.3 AI Outputs and Human Review
AI-generated assessments, summaries, scores, and recommendations may contain inaccuracies or reflect limitations in the underlying information or models.
Such outputs are intended to assist authorized human decision-makers.
They should not be treated as definitive determinations of a person's character, eligibility, suitability, or personal circumstances.
Chapters remain responsible for reviewing outputs and making membership, forum placement, and other organizational decisions.
Where required by applicable law, individuals may have rights concerning qualifying automated decision-making, profiling, or decisions producing legal or similarly significant effects.
6.4 AI Training and Secondary Uses
Chapter OS will not authorize third-party AI providers to use Chapter-controlled personal information to train general-purpose AI models except where expressly authorized by the applicable Chapter and permitted by law.
Chapter OS will not independently use identifiable, confidential forum information to train its own general-purpose AI models without appropriate authorization and a lawful basis
Implementation requirement: These commitments must be confirmed against actual AI provider agreements, API settings, logging practices, and product architecture before publication.
7. How We Disclose Personal Information
We may disclose personal information to the following categories of recipients, as appropriate.
7.1 Authorized Chapter Users
Information may be accessible to Chapter administrators, forum leaders, authorized members, and other individuals granted appropriate permissions.
Access depends on the applicable feature, user role, and Chapter configuration.
7.2 Service Providers
We may use third-party service providers to support:
Cloud hosting and data storage.
Payment processing.
Transactional email delivery.
Artificial intelligence services.
Geocoding and mapping.
Security, diagnostics, and technical operations.
Our currently identified providers include Stripe, Cloudflare R2, OpenAI, Anthropic, and OpenStreetMap/Nominatim-related services.
Not every provider receives every category of information.
Service providers are expected to process information only as authorized and subject to applicable contractual and legal protections.
7.3 Legal Requirements
We may disclose information when reasonably necessary to comply with applicable law, valid legal process, or enforceable governmental requests.
Where legally permissible and appropriate, we may notify affected Customers before disclosing Chapter-controlled information.
7.4 Protection of Rights and Safety
We may disclose information when reasonably necessary to investigate fraud, prevent security incidents, enforce agreements, or protect the rights and safety of users, the Company, and others.
7.5 Corporate Transactions
We may disclose information when reasonably necessary to investigate fraud, prevent security incidents, enforce agreements, or protect the rights and safety of users, the Company, and others.
8. Sale of Personal Information and Advertising
Chapter OS does not sell personal information for monetary consideration.
Our existing application privacy practices do not include third-party behavioral advertising trackers.
We do not intentionally disclose Chapter-controlled member information to third parties for their independent targeted advertising purposes.
Some state privacy laws define “sale” and “sharing” more broadly than transactions involving money. If Chapter OS introduces advertising technologies, cross-context behavioral advertising, or other activities constituting a sale or sharing under applicable law, we will update our disclosures and provide required opt-out mechanisms before engaging in those activities.
We do not knowingly sell or share personal information belonging to children under 16.
9. Cookies and Similar Technologies
Chapter OS uses cookies and related technologies necessary to provide secure application functionality.
These may include:
Authentication and session cookies.
Security-related cookies.
Cookies required to maintain authorized account sessions.
Other strictly necessary technologies.
The platform currently uses secure, HTTP-only authentication cookies, with sessions generally lasting seven days, subject to authentication and security controls.
Users may configure their browsers to restrict cookies. However, disabling essential cookies may prevent the Services from functioning properly.
If nonessential analytics, advertising, or other tracking technologies are introduced, Chapter OS will provide additional disclosures and consent or opt-out controls where required by law.
10. Information Security
Chapter OS maintains administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction.
These safeguards may include:
Role-based access controls.
Tenant-level data isolation.
Restricted administrative privileges.
Secure authentication and session management.
Logging and auditing of administrative activity.
Controlled access to stored files.
Encryption and secure communications where implemented.
Security monitoring and incident response procedures.
Chapter OS uses database-level access restrictions and tenant isolation mechanisms to help segregate Chapter information.
Uploaded files are maintained in private storage with controlled access mechanisms.
No information system or transmission method can be guaranteed to be completely secure.
Chapter OS does not warrant that unauthorized access, data loss, or security incidents can never occur.
Customers and users are responsible for protecting their credentials, maintaining appropriate access permissions, and promptly reporting suspected unauthorized account activity.
11. Data Breaches and Security Incidents
Chapter OS maintains procedures intended to identify, investigate, contain, and respond to suspected or confirmed security incidents.
When an incident affects personal information, Chapter OS will evaluate its legal and contractual notification obligations.
Where Chapter OS acts as a processor or service provider, it will notify the affected Chapter as required by applicable law and the governing agreement.
Where Chapter OS acts as an independent controller or business, it will provide legally required notifications to affected individuals or authorities.
The timing and content of notifications will depend on the circumstances, applicable law, and contractual requirements.
12. Data Retention
Chapter OS retains personal information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, comply with applicable law, resolve disputes, enforce agreements, and meet legitimate security and business needs.
Retention periods depend on the information category, the applicable Chapter's instructions, and contractual obligations.
12.1 Active Subscriptions
Chapter-controlled information is generally maintained while the applicable subscription remains active and as necessary to provide the Services.
12.2 Suspended Accounts
If a Chapter's subscription becomes delinquent or is temporarily suspended, information may be retained during the suspension period to support account restoration and applicable contractual obligations.
12.3 Canceled Accounts
Following cancellation or termination, Chapter-controlled information will be retained for the period established in the applicable customer agreement and data retention schedule, unless a longer period is legally required.
After the applicable period, information will be deleted or de-identified in accordance with established procedures, subject to lawful exceptions.
12.4 Backups and Legal Records
Residual copies may remain in backups for a limited period under established backup-retention schedules.
Certain billing records, security logs, contractual records, or information subject to legal preservation obligations may be retained for longer periods.
12.5 Retention Criteria
In determining retention periods, we consider:
The duration of the customer relationship
The nature and sensitivity of the information.
Contractual requirements.
Applicable legal obligations.
Security and fraud prevention needs
The feasibility and necessity of continued retention
Before publication, Chapter OS must adopt a documented retention schedule identifying actual retention periods for active records, canceled accounts, backups, logs, billing records, and support communications.
13. Data Deletion and Account Termination
Authorized Chapter representatives may request deletion of Chapter-controlled information in accordance with their subscription agreement and applicable law.
Chapter OS may require identity and authority verification before fulfilling deletion requests.
Deletion of an entire Chapter workspace may affect all associated member records, forum information, documents, and other organizational data.
Accordingly, Chapter OS may require confirmation from an authorized Chapter representative before permanently deleting a workspace.
Deletion requests may be subject to applicable legal holds, recordkeeping requirements, backup-retention processes, and other lawful exceptions.
Where technically feasible and contractually required, Chapter OS will provide reasonable assistance with data export or return before deletion.
14. Individual Privacy Rights
Depending on an individual's state of residence and applicable law, the individual may have rights concerning personal information.
These may include the right to:
Confirm whether personal information is being processed.
Access personal information.
Obtain a copy of personal information.
Correct inaccurate personal information.
Request deletion.
Obtain portable information where required.
Opt out of qualifying sales, targeted advertising, or certain profiling activities.
Limit certain uses of sensitive personal information where applicable.
Appeal certain denied privacy requests.
Exercise privacy rights without unlawful discrimination or retaliation.
These rights are subject to applicable exemptions, verification requirements, and legal limitations.
14.1 Submitting a Request
Requests concerning Chapter OS-controlled information may be submitted to theoscompanyapps@gmail.com
Certain billing recordsRequests concerning Chapter-controlled membership or forum information should ordinarily be directed to the relevant Chapter., security logs, contractual records, or information subject to legal preservation obligations may be retained for longer periods.
Chapter OS may assist Chapters with verified requests as required by law or agreement.
14.2 Verification
We may request information reasonably necessary to verify identity or authority before fulfilling a privacy request.
We will not require unnecessary sensitive information solely to process a request.
14.3 Response Timeframes
We will respond within the timeframe required by applicable law.
Where permitted, we may extend a response period when reasonably necessary and will provide any required explanation.
14.4 Appeals
Where applicable law provides an appeal right, individuals may appeal a denied privacy request by replying to the decision or contacting our privacy address with the subject line “Privacy Rights Appeal.”
We will review and respond to appeals in accordance with applicable law.
Where required, we will provide information about the individual's ability to contact the relevant state regulator.
15. Additional Notice for California Residents
This section applies to California residents to the extent Chapter OS is subject to the California Consumer Privacy Act, as amended (“CCPA”).
15.1 Categories of Information
Depending on the individual's relationship with Chapter OS, the Company may collect the following categories of personal information:
Category
Identifiers
information
Commercial information
Internet or network activity
Professional information
Geolocation information
Inferences
Sensitive personalinformation
Examples
Names, email addresses, IP addresses, account identifiers
Contact information, billing details, and related records
Subscriptions, invoices, and transaction history
Login records, usage activity, device information
Business affiliations, roles, industry, and professional profiles
Residential address information used for authorized membership mapping
Compatibility scores, engagement insights, and assessments
Certain health-related or personal information voluntarily submitted through authorized Chapter features
Not every category is collected from every individual.
The sources, purposes, and recipient categories are described throughout this Privacy Policy.
15.2 Business Purposes and Disclosures
We use personal information to provide the Services, administer accounts, process payments, maintain security, fulfill authorized Chapter instructions, and meet legal obligations.
We may disclose the categories described above to service providers, contractors, authorized Chapter users, and other recipients identified in Section 7, as applicable.
15.3 Sale and Sharing
Chapter OS does not currently represent that it engages in the sale or sharing of personal information for cross-context behavioral advertising.
This statement must be validated against actual website tracking technologies, vendor agreements, and data flows.
If activities constituting a sale or sharing occur, Chapter OS will implement legally required disclosures, links, and opt-out preference signal handling.
15.4 California Privacy Rights
Subject to applicable law, eligible California residents may have rights to know, access, delete, correct, opt out of sale or sharing, limit certain uses of sensitive personal information, and receive equal treatment when exercising privacy rights.
California residents may also use authorized agents where permitted.
15.5 Retention
Retention periods or the criteria used to determine them are described in Section 12.
15.6 Notice at Collection
The information in Sections 3 through 9 and Section 12 is intended to support Chapter OS's disclosures concerning information collection.
Where the CCPA applies, Chapter OS will provide a compliant Notice at Collection at or before the point of collection, including the information required by applicable regulations.
16. Other U.S. State Privacy Laws
Residents of states with applicable comprehensive consumer privacy laws may have additional rights concerning personal information.
These rights may include access, correction, deletion, portability, opt-out rights, and appeals, depending on the applicable law.
Chapter OS will honor qualifying requests where required and will apply any relevant statutory exemptions.
Certain information processed in a commercial or employment context may be treated differently under particular state laws.
Where required, Chapter OS will provide additional notices or mechanisms for qualifying sensitive-data processing or automated profiling.
17. Sensitive Personal Information
Chapter OS recognizes that peer forums and membership organizations may process information that is sensitive or confidential.
We encourage Chapters to collect only information necessary for legitimate organizational purposes.
Chapters are responsible for determining whether particular information requires consent, additional notices, or other protections.
Chapter OS will process sensitive personal information only as authorized and subject to applicable law and contractual restrictions.
We do not intentionally require individuals to disclose sensitive health information, financial account credentials, government identification numbers, or similarly sensitive information unless an authorized feature specifically requires such collection.
Sensitive information should not be submitted through general-purpose text fields unless appropriate.
18. Confidentiality of Forum Information
Forum discussions, reflections, and peer-group communications may be subject to confidentiality expectations or agreements established by the applicable Chapter or membership organization.
Chapter OS provides technical access controls intended to support authorized information access
However, Chapter OS does not independently guarantee that every forum participant or Chapter administrator will maintain confidentiality.
Chapters are responsible for establishing and enforcing their own membership confidentiality requirements.
Authorized Chapter personnel may have access to certain information according to their assigned permissions.
Chapter OS personnel may access information when reasonably necessary for authorized support, security, maintenance, legal compliance, or other permitted purposes, subject to applicable safeguards.
Sensitive information should not be submitted through general-purpose text fields unless appropriate.
Chapter OS will not intentionally disclose confidential forum information for unrelated marketing or commercial exploitation.
19. Children's Privacy
Chapter OS is designed for adult business professionals, entrepreneurs, organizational administrators, and members.
The Services are not directed to children under 13 years of age.
Chapter OS does not knowingly collect personal information directly from children under 13 through its general account registration processes.
If we become aware that personal information has been collected from a child in violation of applicable law, we will take appropriate steps to address the information, including deletion where required.
Parents or guardians may contact us regarding concerns about information involving children.
20. International Users and Data Transfers
Chapter OS is operated by a U.S.-based company.
Personal information may be processed or stored in the United States or other jurisdictions where authorized service providers operate.
Where personal information is transferred across national borders, we will implement appropriate safeguards when required by applicable law.
Individuals outside the United States may have additional rights under applicable local privacy laws.
Chapter OS does not represent that the Services are compliant with every international privacy framework solely because they are accessible internationally.
Any international deployment may require additional contractual, operational, and legal safeguards.
21. Third-Party Websites and Services
The Services may contain links to third-party websites or integrate with external services.
Chapter OS is not responsible for the independent privacy practices of third parties that operate outside our control.
Users should review applicable third-party privacy notices before providing personal information to those services.
22. Business Communications
Chapter OS may send communications reasonably necessary to administer accounts, deliver subscribed services, provide security notices, and respond to customer inquiries.
Chapter OS is not responsible for the independent privacy practices of third parties that operate outside our control.If Chapter OS introduces promotional email campaigns or other marketing communications, it will comply with applicable marketing and electronic communications laws, including legally required opt-out mechanisms.
Unsubscribing from optional promotional communications will not necessarily prevent delivery of essential service or security notices.
23. Changes to This Privacy Policy
We may update this Privacy Policy to reflect changes in our Services, data practices, technology, legal requirements, or business operations.
When changes are made, we will update the effective date or last-updated date.
If changes materially affect how personal information is processed, we will provide additional notice or obtain consent where required by applicable law.
Updated versions will be made available through our website.
Changes will not eliminate rights granted by applicable law.
24. Contact Information
Questions, privacy requests, and concerns regarding this Privacy Policy may be directed to:
