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Privacy Policy

Last updated: June 18, 2026  ·  Effective date: June 18, 2026

Note for attorney review: Highlighted callout boxes like this one mark items requiring legal judgment or confirmation before this policy is published. Placeholders in italic green require substitution of specific facts. This draft is structured for a California LLC operating as a B2B service provider to private clubs, where the club controls member data and Tidemere processes it on the club's behalf.

Contents

  1. About This Policy
  2. Who We Are
  3. Scope: What This Policy Covers
  4. Information We Collect (Club, Household, Staff, Automatic, Payment)
  5. Sensitive Personal Information
  6. How We Use Information
  7. How We Share Information
  8. Children's Privacy
  9. Data Retention
  10. Security
  11. California Privacy Rights (CCPA / CPRA)
  12. Other U.S. State Privacy Laws
  13. Cookies and Tracking Technologies
  14. Links to Third-Party Services
  15. Changes to This Policy
  16. Contact Us

1. About This Policy

This Privacy Policy describes how Tidemere, LLC ("Tidemere," "we," "us," or "our") collects, uses, discloses, and protects information in connection with our member-services application and related website at tidemere.com (collectively, the "Services").

Please read this policy carefully. By using the Services, you acknowledge that you have read and understand the practices described here. If you are a club or organization ("Club") using Tidemere on behalf of your members, you represent that you have the authority to agree to these terms on behalf of your organization and that your use of the Services is subject to a separate agreement with Tidemere.

2. Who We Are

Tidemere, LLC is a California limited liability company with its principal place of business at 300 El Camino Real, Suite 200, Menlo Park, CA 94025. We develop and operate a member-services application designed for private swim and tennis clubs and similar high-trust organizations.

For questions about this policy, contact us at hello@tidemere.com.

Attorney review: Confirm legal entity name, state of formation, and registered address once the LLC is formed in California. Also confirm whether a registered agent address should appear here or a P.O. Box.

3. Scope: What This Policy Covers

Tidemere operates in two capacities, and this distinction matters for understanding how your information is handled:

3.1 Tidemere as a Business (direct relationship)

When a Club subscribes to Tidemere or when any individual visits tidemere.com, Tidemere acts as the data controller for the information collected in that context. This policy governs that data.

3.2 Tidemere as a Service Provider (on behalf of Clubs and Household Subscribers)

When a Club uses Tidemere to manage its members and operations, or when a Household Subscriber uses Tidemere to manage a private residence or estate, the Subscriber is the party that controls the personal data of its members, residents, staff, and guests. Tidemere processes that data solely on the Subscriber's behalf and under the Subscriber's instructions. In this context, Tidemere acts as a "service provider" under California law.

Members of a Club, household residents, and household staff who have questions about how their personal data is handled should contact their Club or Household Subscriber directly. Tidemere does not use Subscriber data for Tidemere's own business purposes beyond providing the Services.

In the Household product, a Household Subscriber may be either the Principal (homeowner) directly or a management entity acting on behalf of a Principal. Where a management entity administers the account, that entity is the Subscriber of record and is responsible for data controller obligations under applicable law.

Attorney review: The service provider distinction is critical for CCPA compliance. Confirm that the agreement between Tidemere and each Club includes a Data Processing Agreement (DPA) or written contract establishing Tidemere's service provider status. Without such a contract, Tidemere may not qualify as a service provider and could be treated as a separate data business with independent CCPA obligations for member data.

4. Information We Collect

4.1 Information from Clubs and Administrators

When a Club subscribes to Tidemere or when an administrator, manager, or staff member creates an account, we collect:

  • Contact information: name, email address, phone number
  • Organization information: club name, club address, and other details needed to configure the Services
  • Account credentials: username and encrypted password
  • Billing and subscription information (see Section 4.4 below)
  • Communications: emails, support requests, and other messages sent to Tidemere

4.2 Member Information (Processed on Behalf of Clubs)

When a Club uses Tidemere to serve its members, the Club provides us with member information to process on the Club's behalf. This may include:

  • Member names, household composition, and member codes
  • Contact information for account holders (the primary member or guardian)
  • Allergy and dietary restriction information (see Section 5, Sensitive Personal Information)
  • Lesson and activity enrollment records
  • Reservation and scheduling history
  • Member requests, communications, and notes submitted through the application
  • Guest registration information submitted by members
  • Financial account information such as payment method details and transaction history (see Section 4.6 below)

This information is controlled by the Club. Members should contact their Club to exercise any rights over this data.

4.3 Household Information (Processed on Behalf of Household Subscribers)

When a Household Subscriber uses Tidemere to manage a private residence or estate, the Household Subscriber provides information about household residents, staff, and guests for processing on the Subscriber's behalf. This may include:

  • Principal and family member information: names, contact information, preferences, household access permissions, and allergy or dietary information for household residents
  • Household staff information: names, job roles, contact information, shift schedules, task assignments, time-off requests and approvals, and work-related communications within the platform (see Section 4.5 below for additional detail on employee data)
  • Guest information: names and any access credentials or permissions granted to invited guests on a temporary or limited basis
  • Household operational data: maintenance requests, service schedules, and other operational records generated through the platform

This information is controlled by the Household Subscriber (whether the Principal directly, or a management entity acting on the Principal's behalf). Household residents, staff, and guests should contact their Household Subscriber to exercise any rights over this data.

4.4 Information Collected Automatically

When you use the Services or visit tidemere.com, we automatically collect certain technical information, including:

  • Device information: device type, operating system, browser type and version
  • Log data: IP address, pages visited, time and date of access, referring URL, and other usage data
  • Cookies and similar technologies (see Section 13)

4.5 Household Staff and Employee Information

Where Tidemere is used by a Household Subscriber to manage household staff, the platform processes personal information about those individuals in an employment context. This may include scheduling data, task and work assignment records, time-off requests and approvals, and work-related communications within the platform. This information is processed on behalf of the Household Subscriber (the employer of record, whether the Principal directly or a management entity) and is used solely to provide the operational features of the Services.

Tidemere does not use household staff employment data for any purpose unrelated to providing the Services. The Household Subscriber, as employer, is responsible for providing any required employment-related privacy notices to staff and for complying with applicable employment and labor laws governing the collection and use of employee data.

California employees and contractors have specific privacy rights under the California Privacy Rights Act (CPRA), effective January 1, 2023. The employer (the Household Subscriber) is responsible for meeting those obligations directly. Tidemere processes staff data as a service provider on the employer's behalf.

4.6 Payment Information

Tidemere's payment processing is designed so that the Club, not Tidemere, is the merchant of record for all transactions with members. Payments for dues, lesson fees, event deposits, and member tabs are processed through a third-party payment processor (Stripe, Inc.). Tidemere does not store full payment card numbers or bank account numbers on its servers.

Tidemere may retain transaction records (amounts, dates, categories) to support the Services. Payment card data is handled directly by the payment processor under its own privacy policy and PCI DSS compliance program.

Attorney review: Confirm the name of the payment processor once selected and verify whether Tidemere's role in the payment flow creates any additional regulatory obligations (e.g., as a payment facilitator). If Stripe is used, Stripe's role as a sub-processor should be reflected in any DPA with Clubs. Also confirm PCI DSS scope for Tidemere as a platform provider.

5. Sensitive Personal Information

Tidemere processes certain information that is classified as "sensitive personal information" under California law. Specifically:

  • Allergy and dietary restriction data. Member profiles may include allergy flags and dietary restrictions. This information is used solely to support the safety features of the Services, including point-of-sale allergy enforcement, on behalf of the Club and its members. Tidemere does not use this information for advertising, profiling, or any purpose unrelated to the safety functions of the Services.

Under the California Privacy Rights Act (CPRA), consumers have the right to direct Tidemere to limit the use of their sensitive personal information. Because Tidemere processes member sensitive data as a service provider on behalf of Clubs, members should contact their Club to exercise this right. Clubs may direct Tidemere to limit or delete sensitive information in accordance with their agreement with Tidemere.

Attorney review: Confirm whether health/allergy data collected through the platform triggers any obligations under HIPAA, HITECH, or state health-data statutes. HIPAA applies to covered entities and business associates in specific healthcare contexts; Tidemere likely does not qualify as a covered entity or business associate, but this should be confirmed. Also confirm whether California's Confidentiality of Medical Information Act (CMIA) applies to allergy/dietary data in this context.

6. How We Use Information

Tidemere uses the information it collects for the following purposes:

  • To provide and operate the Services: including processing reservations, routing requests, managing schedules, processing payments on behalf of Clubs, and enforcing allergy and spending controls.
  • To manage Club subscriptions: including billing, account management, and customer support.
  • To communicate with Clubs and administrators: including responding to inquiries, sending service notifications, and providing updates about the Services.
  • To improve the Services: including analyzing usage patterns (in aggregate, without identifying individual members) to improve reliability, performance, and features.
  • To comply with legal obligations: including responding to valid legal process, enforcing our agreements, and protecting the rights of Tidemere, Clubs, and others.
  • To protect safety and security: including detecting and preventing fraud, abuse, and unauthorized access.

Tidemere does not use member data processed on behalf of Clubs for Tidemere's own commercial purposes, and does not sell, rent, or share member data for advertising or marketing purposes.

7. How We Share Information

Tidemere does not sell personal information. Tidemere does not share personal information for cross-context behavioral advertising.

We share information only in the following circumstances:

7.1 With Clubs

Member information is shared with the applicable Club, as the Club is the controller of that data. For example, a Club's manager and authorized staff may view member profiles, reservation history, and requests within the platform.

7.2 With Service Providers

We share information with third-party service providers who assist us in operating the Services, subject to written agreements that restrict those parties from using the data for any purpose other than providing services to Tidemere. These may include:

  • Cloud hosting and infrastructure providers
  • Payment processors (Stripe, Inc.)
  • Customer support and communication tools
  • Analytics providers (aggregated, non-identifying data only)

7.3 For Legal Reasons

We may disclose information if we believe in good faith that doing so is necessary to: (a) comply with applicable law, regulation, or legal process; (b) enforce our agreements; (c) protect the rights, property, or safety of Tidemere, our Clubs, members, or the public.

7.4 Business Transfers

If Tidemere is involved in a merger, acquisition, financing, or sale of all or a portion of its assets, information may be transferred as part of that transaction. We will notify Clubs of any such transfer and any changes to this policy.

Attorney review: Review all third-party service provider agreements to confirm they contain appropriate data processing terms. If Stripe is used, a Stripe Data Processing Agreement should be in place. Confirm that no sub-processor receives sensitive member data (allergy information) without appropriate contractual protections.

8. Children's Privacy

Tidemere's Services are not directed to children and are not designed to be used directly by individuals under the age of 13. Tidemere does not knowingly collect personal information from children under 13 through independent sign-up or account creation.

Clubs may create household accounts on behalf of member families that include minor children. In these cases, the account is created and controlled by a parent or legal guardian (the adult account holder), who provides any information associated with child profiles. By creating a child profile in Tidemere, the parent or guardian represents that they have the authority to do so and consents to Tidemere's processing of that information on behalf of the Club.

Child profiles may contain: the child's name, a member code, allergy flags, and parent-set weekly spending limits. This information is used solely to enable the safety features of the Services (such as allergy enforcement at the point of sale) and parental controls over spending. It is not used for advertising or profiling.

If you believe that a child under 13 has created an account or provided personal information without parental consent, please contact us at hello@tidemere.com and we will take appropriate steps to remove that information.

Attorney review: Confirm COPPA compliance strategy. The current model (parent creates child profiles; child has no independent account) may provide a basis to argue that Tidemere is not "knowingly collecting" from children directly. However, if minors over 13 are ever given independent app access (e.g., their own login), that creates separate COPPA and state-law considerations. Confirm: (1) whether Tidemere meets any COPPA "operator" threshold; (2) whether the platform should implement an age-gate; (3) whether California's Age-Appropriate Design Code Act (AB 2273) imposes additional obligations given that children's profiles are a foreseeable use case.

9. Data Retention

Tidemere retains Club administrator and organizational data for as long as the Club's subscription is active, plus a reasonable period thereafter to support account closure, dispute resolution, and legal obligations.

Member data processed on behalf of a Club is retained in accordance with the Club's instructions and the terms of Tidemere's agreement with the Club. Clubs may request deletion of member data at any time through the administrative controls in the platform or by contacting hello@tidemere.com.

Automatically collected technical data (logs, analytics) is retained for 12 months, after which it is deleted or de-identified.

Attorney review: Establish a formal data retention schedule and confirm retention periods for each data category. Confirm whether any data must be retained longer for legal or compliance reasons (e.g., financial transaction records may need to be kept 7 years for tax purposes). Formalize the Club data deletion process and SLA.

10. Security

Tidemere implements and maintains reasonable administrative, technical, and physical safeguards designed to protect the information we collect and process against unauthorized access, disclosure, alteration, and destruction. These measures are designed to be appropriate to the nature and sensitivity of the data involved.

No method of transmission over the internet or method of electronic storage is completely secure. While we work to protect your information, we cannot guarantee its absolute security. If you believe your information or account has been compromised, contact us immediately at hello@tidemere.com.

Attorney review: Confirm specific security measures to include here (e.g., encryption in transit and at rest, access controls, SOC 2 compliance, penetration testing). Vague security language is standard in consumer-facing policies, but for B2B contracts with Clubs, more specific commitments will likely be expected. Also confirm whether a data breach notification policy and procedure is in place, as California law (CCPA, Civil Code ยง 1798.82) requires timely notification of breaches involving personal information of California residents.

11. California Privacy Rights (CCPA / CPRA)

If you are a California resident, the California Consumer Privacy Act of 2018 and the California Privacy Rights Act of 2020 (collectively, "CCPA") provide you with specific rights regarding your personal information. This section describes those rights and explains how to exercise them.

Note on scope: The CCPA rights described below apply to personal information that Tidemere controls as a business: primarily information about Club administrators, Tidemere subscribers, and visitors to tidemere.com. For personal information that Tidemere processes as a service provider on behalf of a Club (including Club member profiles), those rights should be exercised with the Club directly. Tidemere will assist Clubs in responding to such requests as required.

11.1 Right to Know

You have the right to request that Tidemere disclose: the categories of personal information we have collected about you; the categories of sources from which it was collected; the business or commercial purpose for collecting it; the categories of third parties with whom we share it; and the specific pieces of personal information we have collected about you.

11.2 Right to Delete

You have the right to request that Tidemere delete personal information we have collected from you, subject to certain exceptions (for example, information we are required to retain by law or that is necessary to complete a transaction or provide a service you requested).

11.3 Right to Correct

You have the right to request that Tidemere correct inaccurate personal information we maintain about you, taking into account the nature of the information and the purposes for which it is processed.

11.4 Right to Opt Out of Sale or Sharing

Tidemere does not sell personal information. Tidemere does not share personal information for cross-context behavioral advertising. Accordingly, there is no sale or sharing to opt out of. If this practice changes in the future, we will update this policy and provide a mechanism for opt-out.

11.5 Right to Limit Use of Sensitive Personal Information

You have the right to direct Tidemere to limit its use of sensitive personal information (such as allergy data) to uses that are necessary to provide the Services. Tidemere already limits the use of sensitive personal information in this manner. If you believe your sensitive information is being used beyond the scope of providing the Services, contact us at hello@tidemere.com.

11.6 Right to Non-Discrimination

Tidemere will not discriminate against you for exercising any of your CCPA rights. We will not deny you the Services, charge you different prices, or provide a different level of service because you exercised a privacy right.

11.7 How to Submit a Request

To submit a request to know, delete, or correct, contact us at:

  • Email: hello@tidemere.com
  • Subject line: "California Privacy Request"

We will verify your identity before processing your request and will respond within 45 days, with up to one 45-day extension if necessary. We will not charge a fee for one request per 12-month period.

11.8 Authorized Agents

California residents may designate an authorized agent to submit privacy requests on their behalf. To use an authorized agent, please provide written authorization from the consumer and verify the agent's identity when contacting us.

Attorney review: Confirm whether Tidemere meets the CCPA applicability thresholds (annual gross revenues over $25 million; buying/selling/receiving/sharing personal information of 100,000+ California consumers or households; or deriving 50%+ of annual revenues from selling/sharing personal information). If Tidemere is below these thresholds at launch, CCPA may not currently apply, though proactive compliance is advisable given California's direction. Also confirm whether a "Do Not Sell or Share My Personal Information" link must appear in the site footer.

12. Other U.S. State Privacy Laws

A number of U.S. states have enacted or are enacting consumer privacy legislation. Tidemere will comply with applicable state privacy laws as they take effect. If you are a resident of a state with applicable privacy rights and would like to submit a request, contact us at hello@tidemere.com with "Privacy Request" in the subject line.

Attorney review: As Tidemere grows and potentially serves clubs in other states, confirm obligations under applicable laws including Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Texas (TDPSA), and others. For an early-stage California-focused company, California compliance is the priority, but a general catch-all statement is advisable.

13. Cookies and Tracking Technologies

Tidemere uses cookies and similar technologies on tidemere.com to enable the website to function, remember your preferences, and understand how visitors use the site. We use the following categories of cookies:

  • Strictly necessary cookies: Required for the website to function. These cannot be disabled.
  • Functional cookies: Remember your preferences and settings.
  • Analytics cookies: Help us understand how visitors use the site (in aggregate, without identifying individuals). Tidemere currently uses basic server-side access logs only. No third-party analytics scripts are loaded on this site.

You can control cookies through your browser settings. Disabling cookies may affect the functionality of some parts of the site.

Tidemere does not use cookies for cross-site behavioral advertising or sell cookie data to third parties.

Attorney review: Confirm the specific analytics and tracking tools used on tidemere.com. If Google Analytics or similar tools are used, confirm whether a cookie consent banner is required under applicable law (CCPA generally has a lower cookie-consent threshold than GDPR, but a banner may be advisable). If Tidemere does not currently use any analytics tools beyond basic server logs, this section can be simplified.

14. Links to Third-Party Services

The Services may contain links to third-party websites or services. Tidemere is not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third-party services you access through our platform.

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the Services, or applicable law. When we make material changes, we will notify Clubs by email and update the "Last updated" date at the top of this page. Your continued use of the Services after the effective date of any update constitutes acceptance of the revised policy.

16. Contact Us

If you have questions about this Privacy Policy, want to submit a privacy request, or believe your information has been handled improperly, contact us:

  • Email: hello@tidemere.com
  • Mail: Tidemere, LLC  ·  300 El Camino Real, Suite 200, Menlo Park, CA 94025

We will respond to privacy inquiries within a reasonable time and no later than required by applicable law.

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