Version 1.1 — effective Sep 26, 2026 · Version history
Document version: 1.1 · Effective date: 2026-09-26 · Last updated: 2026-09-26
This Privacy Policy explains how True Wind Solutions, LLC ("True Wind," "we," "us") handles personal information in connection with:
Two roles, two different sets of data. We act in two different capacities depending on whose data it is:
We collect the following categories of Account Data:
We use Account Data to:
We do not sell Account Data. We share it only as follows:
The Site uses cookies and similar technologies to operate, remember preferences, and understand how visitors use the Site. If we use a third-party web analytics tool for this purpose (for example, Google Analytics or a similar service), it processes aggregate usage data — such as pages visited, time on page, and general location — under its own privacy terms; our current analytics provider, if any, is listed in Section 9. We use only essential and analytics cookies on the Site — we do not use the Site to serve targeted third-party advertising. You can control cookies through your browser settings; disabling some cookies may affect Site functionality. If we later adopt a tool that shares Site usage data across other websites or apps for behavioral advertising, or if applicable law otherwise requires it, we will implement a cookie-consent mechanism (such as a banner with a clear opt-out option) before that use begins.
Depending on where you live, you may have rights to access, correct, delete, or receive a copy of your Account Data, and to opt out of certain processing (for example, sale or "sharing" of personal information, or targeted advertising, and profiling with legal or similarly significant effects). We do not sell Account Data and do not use it for cross-context behavioral advertising.
As of this Policy's effective date, twenty U.S. states have comprehensive consumer privacy laws in effect or scheduled to take effect (including California, Colorado, Connecticut, Virginia, Utah, and, as of 2026, newly including Indiana, Kentucky, and Rhode Island, among others). We review and update this list periodically as additional state privacy laws take effect.
To exercise a privacy right, contact us at privacy@truewindsolutions.com. We will verify your request and respond within the time required by applicable law. You may designate an authorized agent to submit a request on your behalf where permitted by law. We will not discriminate against you for exercising these rights.
If you are located outside the United States, additional rights may apply under local law (e.g., GDPR data subject rights for EU/UK individuals); contact us at the address above.
We retain Account Data for as long as needed to provide the Service, comply with legal obligations, resolve disputes, and enforce our agreements, after which we delete or de-identify it.
Customer Data retention is set primarily by our agreement with the applicable club customer and, ultimately, by that customer's own instructions and retention policies — see Section 8 and our DPA.
Membership Pipeline Manager specifically: personal data associated with an individual Membership Pipeline Manager candidacy (including candidate and spouse/children information) is redacted from active production systems at the earlier of (a) the retention period the club customer has configured for its own account (in days, up to a five-year maximum), or (b) five years — in each case measured from the date the candidacy reaches a final outcome (the candidate is admitted to membership, the candidacy is withdrawn by the candidate or the club, or the club's process concludes without admission). Redaction removes identifying details (name, contact information, and family/spouse/children information); a non-identifying record of the candidacy's process history (stage progression, dates, and outcome) is retained for the club's own recordkeeping and reporting. A club may place an individual candidacy on a retention hold to exempt it from this schedule. Full technical detail is in our Data Processing Agreement, Annex A.
When a club customer uses Navigator, its staff may submit personal data about club members, prospective members ("candidates"), sponsors, endorsers, membership committee members, and — specifically within Membership Pipeline Manager's candidate intake forms — spouse and children information, to the extent the club's own membership process collects it.
We process this Customer Data solely as a service provider/processor, on the customer's documented instructions, to provide the Service. We do not use Customer Data for our own marketing, do not sell it, and do not combine it with data from other customers except in aggregated or de-identified form for product analytics and improvement.
Key points:
Full detail on our obligations as a processor — including subprocessors, security measures, breach notification, and data return/deletion upon termination — is in our Data Processing Agreement, made available to customers directly.
As of this Policy's effective date, we use the following categories of infrastructure and service providers to operate the Service.
| Provider (category) | Purpose |
|---|---|
| Microsoft Corporation (Microsoft Azure, including Azure Communication Services) | Application hosting, database, authentication infrastructure, transactional email delivery, file storage (e.g., photo uploads), diagnostic monitoring and logging |
| Netlify | Marketing website and sales-demo hosting |
| None currently in use (see Section 6) | Website analytics |
True Wind does not currently use a third-party payment processor; billing is handled directly.
A current subprocessor list for Customer Data specifically is maintained as Annex C to the DPA and updated per the notice process described there.
We maintain administrative, technical, and organizational measures designed to protect Account Data and Customer Data, including encryption in transit and at rest, role-based access controls, tenant isolation between customers, and audit logging of sensitive data changes. No system is completely secure, and we cannot guarantee absolute security. See the DPA's security annex for more detail on measures applicable to Customer Data.
The Site and Service are intended for business use by adults and are not directed to children. We do not knowingly collect Account Data directly from anyone under 16. Membership Pipeline Manager may store limited information about a candidate's children (e.g., names, ages) only because a club customer's own membership process asks for it — this is Customer Data, submitted by the customer about its own members' families, not information we collect from children directly. This information is subject to the same club-configurable, five-year-maximum redaction schedule described in Section 7.
The Service is currently operated primarily for and hosted within the United States. If we process personal data originating outside the United States, we will use appropriate safeguards required by applicable law (e.g., Standard Contractual Clauses) as described in the DPA.
We will update the version number and effective date above whenever we revise this Policy. The current version is always available at a stable URL; prior versions are maintained by True Wind and available on request, consistent with our Terms of Service. For material changes, we will provide notice as described in our Terms of Service before the change takes effect.
Questions or requests regarding this Policy: privacy@truewindsolutions.com General inquiries: sales@truewindsolutions.com Mailing address: True Wind Solutions, LLC, c/o Northwest Registered Agent Service, Inc., 8735 Dunwoody Place, Ste N, Atlanta, GA 30350