The BluWater Group, BluWater Capital, Bluwater Development and their subsidiaries and project websites (collectively, “BluWater”) are a privately-owned group of companies engaged in proprietary activities for select affiliates like you and take their and your identities, protection and privacy seriously.

Our commitment to privacy includes being transparent about the nature and extent of information we gather and use, and the rights that may be available to you with respect thereto.

In the course of providing services, BluWater may obtain personal information. Obtaining this information is important to our ability to deliver the highest level of service possible and in some cases is required by law. As part of this process, we also recognize that you expect us to treat this information appropriately.

This cookie and privacy policy (the “Policy”) describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy.

BluWater endeavors to maintain the highest standards of confidentiality and to respect the privacy of those we serve and their associated persons, our employees, and other individuals whose personal information we collect and process.

This Policy only applies to nonpublic information concerning those that we serve that are individuals, not entities.

Use of Cookies and Tracking Technology

When you interact with our websites (and those we may run through DocSend, DropBox, or other secure data delivery vendors and service providers), we automatically receive and record information on our server logs from your browser, including your IP address, “cookie” information, search inquiry data, data on content you choose to view, the pages you request, where you click, how much time you spend on a given page, and if you attempt to download or otherwise capture our web pages or data on or embedded within them. Most browsers are initially set to accept cookies, but you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please note that by blocking any or all cookies, you may not have access to certain features, content or personalization available to you through our websites and vendors. We also utilize comprehensive email and document delivery tracking systems that provide us with data such as who opens or forwards an email or attachment, to whom it was sent or forwarded, the time it was opened, and whether the reader clicks or forwards certain links within the email or other delivered material.

Collection of Information

BluWater collects personal information about those it serves in part through invitation-only delivered investment-related materials, including subscription documents, questionnaires, joinders, other written documents provided to you, personal meetings, telephone calls, electronic delivery portals, and through transactions both with and within BluWater. This information may include but is not limited to names, addresses, nationalities, tax identification numbers, financial and investment qualifications and values, tax returns, account balances, investments, and personal family, status and withdrawal information (Nonpublic Personal Information).

Disclosure of Nonpublic Personal Information

BluWater does not sell or rent Nonpublic Personal Information.

BluWater does not disclose Nonpublic Personal Information to nonaffiliated third parties, except as permitted by law.

BluWater may share Nonpublic Personal Information in the following situations:

1. To service providers in connection with the administration of BluWater, which may include attorneys, accountants, auditors, and other professionals. BluWater may also share information in connection with the servicing or processing of BluWater transactions;
2. To respond to a subpoena or court order, Congressional inquiry, judicial process or state, federal, or local regulatory authorities;
3. To protect against fraud, unauthorized transactions (such as money laundering), claims or other liabilities; and
4. Upon your consent to release such information, including authorization to disclose such information to persons acting in a legal, fiduciary or other representative capacity on your behalf.

We may also disclose your Nonpublic Personal Information to fulfill your instructions, to protect our rights and interests and those of our business partners or pursuant to your express request.

BluWater may also use your Nonpublic Personal Information to:

1. Administer, operate, facilitate and manage your relationship with BluWater. This may include sharing such information internally as well as disclosing it to third parties, as described above.
2. Contact you or, if applicable, your designated representative(s) by mail, telephone, etc., in connection with your relationship and/or expressed desires and needs;
3. Provide you with information (such as investment information) or advice concerning services offered by BluWater; and
4. Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.

This Policy may be changed from time to time to reflect changes in our practices concerning the collection and use of Nonpublic Personal Information. The revised policy will be effective immediately upon posting to our private website. This version of the Policy is effective June 1, 2020.

Please contact us at any time with questions or concerns.