Privacy Policy

01 Overview

1.1 A Note About Children

The Services are not intended for use by any individual under the age of majority in their jurisdiction (“Minors”). The use of the Services by Minors is subject to the consent and supervision of their parent or guardian. We do not gather Personal Information from Minors. If a Minor submits Personal Information to Blue Water and we learn that the Personal Information is the Personal Information of a Minor, we will attempt to delete the Personal Information as soon as possible. If you believe that we might have any Personal Information from a Minor, please contact us at .

1.2 International Users

If you are a non-U.S. or non-Canadian user of the Services, by visiting the Services and providing us with data, you acknowledge and agree that your Personal Information may be processed for the purposes identified in this Privacy Policy. In addition, your Personal Information may be processed in the country in which it was collected and in other countries, including the United States and Canada, where laws regarding processing of Personal Information may be less stringent than the laws in your country. By providing your data, you consent to such transfer. If you are in the UK or European Economic Area (“EEA”), please see specific terms which apply to you further below.

1.3 Lawful Processing

We process your Personal Information only to the extent necessary for the purposes described in this Privacy Policy. We set out below the type of Personal Information we collect and how we use such Personal Information. Except as set forth in this Privacy Policy, your Personal Information will not be used for any other purpose without your consent. Where we rely on your consent to process your Personal Information, you may withdraw that consent at any time. We may continue to process Personal Information on other lawful bases, such as to perform our contract with you, comply with legal obligations, or pursue our legitimate business interests. However, withdrawing consent may result in your inability to continue using the Services.

1.4 Scope

This Privacy Policy covers the activities of Blue Water but does not apply to the practices of companies that we do not own or control, including our customers and third parties that may integrate with Blue Water Services and any services offered by other companies or other sites linked from our Website or Services. This Privacy Policy does not govern any external websites or services, even if such websites or services are linked on Blue Water’s Website or through the Services. Blue Water is not responsible for the protection of your privacy and/or any information you may provide while visiting any websites or services offered by our customers or other companies. You should exercise caution when leaving our Website and read any privacy policies that may apply to external websites or services. You are responsible for ensuring that you have obtained the necessary authorizations and consents for any Personal Information you make available to us for use in accordance with this Privacy Policy, in particular, our customers represent and warrant to Blue Water that they have the necessary rights under applicable law or have obtained the necessary consents from each end user whose Personal Information is provided by that customer to Blue Water in order to allow Blue Water to use, disclose and otherwise process such Personal Information for the purposes described in this Privacy Policy in the manner described in this Privacy Policy.

02 Information We Collect

2.1 Information You Provide to Us

Set out below are some of the types of Personal Information we may collect:

• Personal Information we may Collect from Consumers. Name, email address, search queries, time zone, the date on which you access the Services, and details you provide about your own marine vessel(s) which we will identify throughout the Services as “owner-supplied”.
• Personal Information we may Collect from Customers. Name, email address, password, phone number, company name, business address, industry, details of your intended use of the Services, time zone, the date on which you access the Services, and search queries. We may also securely collect billing details, payment information, or other related information in order to allow Customers to pay for the Services they have procured from Blue Water.
• De-Identified Data. We may also collect and use De-Identified Data, including aggregated and de-identified statistical datasets and analysis, from your interaction with and use of the Services and from publicly available brokerage listing data, which may include Personal Information. De-Identified Data may be derived from Personal Information but is treated as de-identified or anonymized data in accordance with applicable law, meaning that it is not used to directly or indirectly reveal the identity of any individual or legal entity. Where we de-identify data, we maintain it in de-identified form and do not attempt to re-identify it except as permitted by law. For example, we may anonymize and aggregate your usage data to calculate the percentage of users accessing a specific feature of the Services.
• Employee and Contractor Candidate Information. When we seek candidates for potential jobs or contracting engagements with Blue Water, we collect information that those candidates choose to provide to us when applying, which may include contact information, education and employment history, credentials, place of residence and other information the candidate believes to be relevant. For people who become our employees or contractors, we will typically retain the information provided by those candidates in the application process along with additional information to manage their employment or contractor relationship with us, including, without limitation, information related to income tax reporting and withholding and enrollment in Blue Water benefit plans (in each case, to the extent applicable for the relevant relationship).

2.2 Information We Collect Automatically

Set out below are some of the types of information that we may collect automatically from Consumers and Customers during the course of providing the Services:

• Consent Record. For each User, Blue Water maintains an append-only record of events that modify User consent to the collection or uses of Personal Information (the “Consent Record”). Any time that a User provides or revokes consent to the collection or any use of certain Personal Information, that event and the date and time that it occurred are logged in that User’s Consent Record.
• Device Information. We may collect information about devices you use to access the Services and information about how you use the Services, such as your IP address and which websites you visited before accessing our Services.
• Usage Data. Our servers automatically record information created by your use of our Services to help us diagnose and fix technical issues, and to improve the overall quality and user experience of our Services. Usage Data may include information such as your IP address, browser type, operating system, details of how you used our Services (such as the functions you asked our Services to perform), diagnostic information related to the Services (such as crash activity reports), the referring web page, pages visited and time spent on such pages, location, your mobile carrier, device and application IDs, search terms, cookie information, and interaction patterns.
• Cookies and Similar Technologies. We use cookies and similar technologies, including pixels, tags and other tracking technologies, to operate the Website, understand how visitors interact with it, measure the effectiveness of our communications and advertising, and, where you have provided the required consent, support advertising and remarketing activities.

  These technologies may collect or generate information such as your IP address, browser and device type, operating system, referring website, pages viewed, interactions with the Website, advertising or campaign identifiers, approximate geographic location and information about whether an advertisement or campaign resulted in a visit or other action on the Website.

  Some cookies and similar technologies are necessary for the operation and security of the Website. Other technologies, including certain analytics and advertising technologies, are optional. Where required by applicable law, including for visitors in the EEA and UK, we will obtain your consent before using non-essential cookies or similar technologies. You may withdraw or change your consent at any time through our cookie preference controls.

• Marketing Information. From time to time, we may conduct surveys or hold contests or other events and in connection with such surveys, contests, or events, we may collect information you elect to provide about yourself, such as your name, email address, telephone number, organization name and address; and general information about the company for whom you work. In addition, we may use third-party service providers to collect business-related information about your employer such as its name, size, and publicly available revenue in connection with potentially offering the Services to your employer.

2.3 Analytics and Advertising Technologies

We may use third-party analytics and advertising services to understand Website traffic, evaluate the effectiveness of advertising campaigns, measure conversions, prevent advertising fraud, limit advertising frequency and, where permitted and with the required consent, create audiences or provide advertising based on previous interactions with our Website.

We use Google Tag Manager to manage certain technologies deployed through our Website. Depending on your consent choices and the technologies enabled from time to time, these may include services provided by Google, such as Google Analytics and Google Ads, and other advertising or analytics providers identified in our cookie preference tool.

These providers may receive information from your browser or device when their technologies are enabled. For example, Google states that websites using its advertising or analytics services may transmit information including the page URL and IP address and may use cookies or similar identifiers for advertising measurement and related purposes.

We do not use these technologies to obtain your device’s precise GPS location unless we specifically disclose that practice and obtain any consent required by applicable law.

03 How We Use Your Information

We may use the information we collect from you in a manner consistent with this Privacy Policy and the context of our relationship with you. We may use the information that we collect through the Services for the following purposes:

• provide, operate, maintain, improve, and personalize the Services;
• send technical notices, updates, security alerts, and support and administrative messages;
• respond to comments, questions, and requests and provide User service and support;
• process and manage Customer accounts and subscriptions related to the Services;
• process Customer’s authorized payments for our Services;
• monitor and analyze trends, usage patterns, activities, and performance metrics in connection with the Services, including generating aggregated and de-identified statistics;
• process communications using automated systems, including artificial intelligence, to understand intent, generate responses, create estimates, and assist with service delivery;
• investigate and prevent unauthorized access to the Services, fraud, and other illegal activities;
• internal record keeping;
• creating and maintaining your Consent Record;
• communicate with you and provide news or information about us or new products, services, special offers, or other information we think you may find useful or interesting;
• conduct business and contractual relationships that we have with various persons and companies (such as customers, suppliers, partners and employees);
• from time to time, to contact you for market research purposes;
• comply with our legal obligations and enforce our Terms of Use;
• measure and understand the effectiveness of our advertising and marketing campaigns, including determining whether an advertisement resulted in a visit, registration, enquiry or other interaction with our Services;
• where permitted by applicable law and subject to applicable consent requirements, create advertising audiences, conduct remarketing and deliver or measure advertisements that may be relevant to users of our Services;
• for other purposes which we will notify you about and seek your consent; and
• as otherwise specifically described in this Privacy Policy.

04 Information Sharing and Third Parties

We do not actively collect Personal Information for the purpose of selling or marketing that Personal Information to third parties.

4.1 Service Providers and Business Partners

We may from time to time employ third parties to perform tasks for us (“Sub-Processors”) and we may need to share Personal Information (including account information) with them to perform those tasks. The Sub-Processors currently employed by Blue Water are listed below. Unless we tell you differently, such Sub-Processors process your Personal Information only in accordance with our instructions and applicable law, and they do not have any right to use the Personal Information we share with them beyond what is necessary for them to perform the relevant tasks for us. The Sub-Processors we currently engage include third-party companies and individuals employed or contracted by us to provide certain capabilities within the Services and for certain general business functions, including handling emails, web forms, and notifications; database management; user authentication; payment processing; web hosting and analytics (including advertising analytics); data security; the provision of AI models for processing; and customer relationship management tools.

Blue Water’s Current Sub-Processors and Services Provided:

• Cloudflare, Inc.: Web hosting, content delivery networking, access control, and cookie-free aggregate visit and campaign statistics.
• Resend (Plus Five Five, Inc.): Transactional email services.
• Google Workspace: Blue Water’s email account service.
• Anthropic PBC: AI model and associated AI processing services.

4.2 Advertising and Analytics Partners

We may work with advertising and analytics providers, including Google, to provide Website analytics, advertising measurement, conversion tracking and, where permitted, audience and remarketing services. Depending on the particular service, these providers may process information on our behalf or under their own privacy terms. Further information about the providers currently in use is available through our cookie preference tool.

4.3 Sharing with Brokers

We may disclose information that you provide, including your Personal Information, to Brokers. Such Brokers may also be Customers of Blue Water. We will only disclose your information to Brokers in accordance with your consent and according to your explicit instructions.

4.4 Legal Requirements

We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. Further, we may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law.

We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to:

• Satisfy any applicable law, regulation, legal process or governmental request (including pursuant to subpoenas, civil investigative demands, or similar processes); enforce our contracts or user agreements, including investigation of potential violations hereof; and
• Detect, prevent, or otherwise address fraud, security, or technical issues.

The above may include exchanging information with other companies and organizations for fraud protection, spam/malware prevention, and know-your-customer purposes. Notwithstanding the general terms of this policy, the collection, use, and disclosure of Personal Information may be made outside of the terms of this Privacy Policy to the extent provided for in any applicable privacy or other legislation in effect from time to time, or pursuant to court orders (including with respect to depositions, interrogatories, subpoenas, civil investigative demands, and other court or regulatory-mandated discovery processes).

4.5 Business Transfers

If Blue Water is involved in a merger, acquisition, sale of all or substantially all of its assets, or if Blue Water goes out of business, enters bankruptcy, or goes through some other change of control, Personal Information may be transferred as part of that transaction. Your Personal Information may also be transferred in connection with due diligence for any such transactions. In all cases, if any such transactions occur, your Personal Information will remain subject to the restrictions and protections set forth in this Privacy Policy.

4.6 With Your Consent

If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will notify you and/or obtain consent as required under applicable privacy laws.

05 Data Storage and International Transfers

Blue Water stores its data, including Personal Information, on servers located in Canada. Blue Water also transfers data to third-party service providers, including Sub-Processors, located in the United States. You agree to this transfer, storing or processing of your Personal Information in Canada and the United States. Where we transfer Personal Information of individuals in the EEA or the UK to a country that has not been recognized as providing an adequate level of protection, we rely on an approved transfer mechanism, such as the European Commission's Standard Contractual Clauses (together with the UK International Data Transfer Agreement or Addendum), and implement any supplementary measures required by applicable law. We take steps to ensure appropriate safeguards are in place in accordance with applicable law; however, you acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in Canada and the United States under lawful access regimes or court order.

06 Data Retention

We retain your Personal Information and Consent Record for as long as it remains necessary for the identified purpose or as required by law, to resolve disputes, and to enforce agreements, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy.

After User has requested data for deletion, or User deletes their account, we delete or de-identify the relevant personal information without undue delay after a verified deletion request, and in any event within 30 days, except where retention is required by law or legitimate business needs. Requests for deletion are to be made by emailing us at .

07 Data Security

We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure of your information, we implement appropriate physical, technical, and organizational safeguards to protect Personal Information and other data that we collect. These safeguards include:

• Encryption in transit: Data is encrypted while transiting throughout the Services using the TLS standard.
• Data isolation: Personal Information is held in a database separate from market data.
• Consent Record architecture: The Consent Record is append-only and cannot be overwritten, meaning that the entire history of a User’s consent events is preserved.
• Network isolation: Blue Water's servers accept no inbound connections from the internet. The Services are accessed through an outbound-only Cloudflare Tunnel, so no network ports are exposed and the server's address is never published.
• Shared valuation pages: Pages that a User chooses to share are redacted on Blue Water's servers to remove personal information before publication. Those pages stop being accessible 90 days after their creation and publication can be revoked by the User at any time.

No method of transmission or storage is completely secure, and we cannot guarantee the absolute security of your data.

08 Your Rights: Access, Correction, and Accuracy

Blue Water provides Users with the following rights regarding their Personal Information:

• Access: You may request access to Personal Information we hold about you in order to verify the Personal Information we have collected in respect of you and to have a general account of our uses of that Personal Information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant Personal Information available to you, such as where that Personal Information also pertains to another individual. In such circumstances, we will provide reasons for the denial to you upon your written request.
• Correction: We will make every reasonable effort to keep your Personal Information accurate and up to date, and you may request updates, corrections, or additions to your Personal Information as appropriate.
• Deletion: You may also request deletion of your Personal Information. Deletion of Personal Information is subject to exceptions and may affect our ability to provide you with services and/or require you to discontinue your use of certain Blue Water Services. Deletion of your Personal Information will be undertaken in accordance with Section 6 of this Privacy Policy (Data Retention).
• Withdrawal of Consent: Subject to certain exceptions, you may withdraw your consent to our collection or use of your Personal Information. Withdrawal of your consent may affect our ability to provide you with services and/or require you to discontinue your use of certain Blue Water Services. Any withdrawal of consent will be logged in your Consent Record.
• Opt-Out of Marketing Communications: You may opt-out of marketing communications at any time by clicking the “unsubscribe" button included in such communications or by submitting a written request. Such actions will be logged in your Consent Record.
• Data Portability: You may request a copy of your data in a structured, machine-readable format.

All requests pertaining to Personal Information should be submitted in writing to . Blue Water will use commercially reasonable efforts to respond to requests within 30 days of receipt. As appropriate, amended Personal Information will be transmitted to those parties to which we are permitted to disclose your Personal Information. Having accurate Personal Information about you enables us to give you the best possible service.

09 Residents of the European Economic Area (“EEA”) and the United Kingdom (“UK”)

If you are a resident of the EEA or the UK, you have certain data protection rights. Blue Water takes reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information (known as “Personal Data” under the EU General Data Protection Regulation and under the UK Data Protection Act 2018).

If you wish to be informed about what Personal Data we hold about you and if you want that Personal Data to be removed from our systems, please contact us using the contact information set out below. Note that where we act as a data processor on behalf of our customers, you will be required to contact the data controller directly to exercise your rights.

In certain circumstances, where we act as data controller, you have the following data protection rights:

• Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you where we are the data controller and to check that we are lawfully processing it.
• Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
• Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your Personal Data. Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the information's accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local Data Protection Authority. If you wish to exercise any of the rights set out above, please contact us using the contact details below.

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

We may also contact you to ask you for further information in relation to your request to speed up our response.

Cookies and Advertising Technologies. Where applicable law requires consent for the storage of or access to information on your device, including through advertising, analytics or similar tracking technologies, we will request your consent before those technologies are activated. You may refuse non-essential technologies without losing access to the core Website and may withdraw or modify your consent at any time using the cookie preference controls available on the Website.

10 California Privacy Rights

This section provides additional details about the Personal Information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act (the “CCPA”).

For more details about the Personal Information Blue Water has collected over the last 12 months, please see Section 2.1 (Information You Provide to Us) above. We collect this Personal Information for commercial purposes described above. Blue Water does not sell your Personal Information for monetary consideration. To the extent our use of analytics or advertising technologies constitutes a “sale” or “share” for cross-context behavioral advertising (as those terms are defined in the CCPA, as amended by the CPRA), you may opt out as described in this section. California consumers also have the right to correct inaccurate Personal Information, to limit the use and disclosure of sensitive Personal Information, and to opt out of the “sharing” of Personal Information for cross-context behavioral advertising, in each case as provided under applicable California law.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of Personal Information we collect about them (including how we use and disclose this Personal Information), to delete their Personal Information, to opt out of any “sales” of Personal Information that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at the contact information below. We will verify your request using the information (including Personal Information) associated with your account, if available, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

11 Canadian Privacy Compliance

Blue Water is committed to complying with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and applicable provincial privacy legislation, including the personal information protection legislation of British Columbia and Alberta. Where required by such legislation, this includes maintaining a designated person responsible for the protection of personal information, notifying affected individuals and the relevant regulator of confidentiality incidents that present a risk of serious injury, and providing transparency about decisions based solely on automated processing of Personal Information.

We adhere to the principles of accountability, identifying purposes, consent, limiting collection, limiting use and retention, accuracy, safeguards, openness, individual access, and challenging compliance.

Concerns regarding compliance with PIPEDA or provincial privacy legislation may be directed to our Privacy Officer.

12 Additional Rights for Quebec Residents

If you reside in Quebec, additional rights and protections may apply to your personal information under Quebec privacy laws, including the Act respecting the Protection of Personal Information in the Private Sector. To the extent applicable, you may have rights in addition to those described in this Privacy Policy, including rights relating to access, correction, withdrawal of consent, portability, and the deletion or de-indexing of personal information, subject to applicable legal requirements and exceptions. Nothing in this Privacy Policy is intended to restrict, exclude or waive any right or protection available to you under applicable Quebec law. Where Quebec law provides a higher or additional level of protection, that law will apply. We intend to update this Privacy Policy from time to time to reflect applicable Quebec-specific requirements.

13 Anti-Spam Compliance

We comply with applicable anti-spam laws, including Canada's Anti-Spam Legislation (“CASL”) and the United States’ CAN-SPAM Act of 2003. We do not sell or transfer email addresses for marketing purposes and honor unsubscribe requests promptly.

14 Changes to This Privacy Policy

This Privacy Policy is effective as of the Effective Date stated above. We may update this Privacy Policy periodically and at our sole discretion to reflect changes in our practices or legal requirements. Processing of Personal Information we collect is subject to the Privacy Policy in effect at the time such Personal Information is collected, used or disclosed as this Privacy Policy may subsequently be updated in accordance with this Section. Material changes to this Privacy Policy will be posted on our Website, via the Services, or by sending you an email prior to the change becoming effective, which will be evidenced by updating the Effective Date above. Continued use of the Services after we make any changes to the Privacy Policy constitutes acceptance of the updated Privacy Policy and agreement to be bound by such changes. Please refer back to this Privacy Policy regularly to remain informed about our practices in relation to Personal Information.

15 Contact Us