Privacy Policy

1. Who We Are and How to Contact Us

This Privacy Policy is issued by Digital Marine, LLC, doing business as "Moor" and "Moor Yacht Crew" ("Moor," "we," "us," or "our"), a company incorporated in Washington State, USA.

Moor is the data controller for personal data processed through the MoorCrew.com website, mobile application, matching and messaging tools, crew profiles, employer postings, Moor Ads Portal, and all related systems and services (collectively, the "Platform").

Contact for all privacy matters, data subject requests, and regulatory correspondence:
Email: hello@moorcrew.com
Post: Digital Marine, LLC — Privacy, c/o moorcrew.com

By accessing or using Moor, you acknowledge that you have read and understood this Privacy Policy. If you do not agree, you must discontinue use of the Platform.

2. Overview of Our Privacy Approach

Moor is a global digital platform connecting yacht crew with employers, and allowing advertisers to promote services to the maritime community. We operate across multiple jurisdictions and are committed to compliance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR), the UK GDPR, the California Consumer Privacy Act (CCPA), Canada's PIPEDA, and other applicable frameworks.

Our core privacy principles:

• We do not sell personal data to third parties.
• We collect only what is necessary to operate the Platform and provide services.
• We do not use user data to train artificial intelligence or machine learning models.
• We maintain appropriate technical and organizational safeguards to protect data.
• We respect data subject rights and respond to requests promptly.

3. Information We Collect

3.1 Information You Provide Directly

• Crew profile details including name, photograph, experience, and skills
• CVs, sea service records, certifications, and credentials
• Account information: name, email address, phone number
• Employer and vessel details
• Job descriptions and posting details
• Messages sent through in-app messaging
• Advertising content and creative submissions

3.2 Payment Information

All payments are processed through Stripe or another secure third-party payment provider. Moor does not collect or store full credit card numbers. Limited billing metadata may be received, such as the last four digits of a card number, transaction ID, subscription status, and payment success or failure indicators.

3.3 Automatically Collected Information

When you use the Platform, we may automatically collect device information, browser type, IP address, usage patterns, pages viewed, session duration, and general location (city or region level only). This information is used to maintain Platform performance, improve features, and detect security risks.

3.4 Information from Third Parties

We may receive limited information from the following sources:

• Crewdentials: verification status signals only — not underlying documents
• Social login providers: basic profile information if you choose to sign in via a third-party service
• Payment processors: transaction and billing status information
• Advertising partners: campaign performance and interaction data
• Security and fraud prevention tools: risk signals and device reputation data

4. Lawful Basis for Processing (GDPR and UK GDPR)

For users in the European Union, European Economic Area, and United Kingdom, Moor processes personal data only where we have a valid lawful basis under Article 6 of the GDPR. The table below sets out the primary lawful basis for each category of processing activity.

Where we rely on legitimate interests as our lawful basis, we have assessed that our interests are not overridden by the rights and freedoms of the individuals whose data we process, taking into account the nature of the data, the reasonable expectations of users, and the safeguards we have in place. Users have the right to object to processing based on legitimate interests — see Section 10.

5. How We Use Your Information

We use personal data for the following purposes:

• creating and managing your account and profile
• displaying crew profiles and employer job posts to relevant users
• facilitating matching, search results, and recommendations
• delivering and managing advertisements on the Platform
• enabling in-app messaging between users
• processing payments and managing subscriptions
• maintaining Platform security, integrity, and fraud prevention
• providing customer support
• improving the Platform and understanding usage patterns
• complying with legal obligations and protecting our rights

Automated Decision-Making and Profiling

The Platform uses automated systems to assist with matching, ranking, and surfacing relevant crew profiles and job opportunities. These systems process profile attributes, search criteria, and usage signals to generate recommendations.

These automated tools are assistive only. They do not make final hiring or engagement decisions, and all such decisions remain the sole responsibility of the Employer or Crew member involved. No automated decision produces legal or similarly significant effects on users without human review.

EU/EEA/UK users have the right to request human review of any automated output that has materially affected them, to express their point of view, and to contest the result. To exercise this right, contact hello@moorcrew.com.

AI Training

Moor does not use personal data collected through the Platform to train, fine-tune, or develop artificial intelligence or machine learning models. User data is used exclusively for the operational purposes described in this Policy.

6. Sharing of Information

6.1 With Other Users

• Crew profile information is visible to Employers on the Platform
• Job posts are visible to Crew
• Messages you send are visible to the intended recipient only
• Spotlight or promoted content may be visible more broadly within the Platform
• Advertisements are displayed across browsing areas of the Platform

6.2 With Service Providers

We share personal data with the following categories of service providers who process data on our behalf under appropriate data processing agreements:

• Go High Level (GHL) — CRM and marketing communication platform
• Stripe — payment processing
• Supabase, Vercel, and AWS — hosting and Platform infrastructure
• Crewdentials — third-party verification integration
• Email and SMS delivery providers
• Security, analytics, and fraud prevention providers

We require all service providers to maintain appropriate security standards and to process personal data only in accordance with our instructions.

6.3 With Legal Authorities

We may disclose personal data to law enforcement, regulatory bodies, or courts where required by applicable law, court order, or where necessary to protect the Platform, our users, or our rights.

6.4 Business Transfers

In the event of a merger, acquisition, or sale of all or part of our business, personal data may be transferred as part of that transaction. We will notify users of any such change and the applicable privacy protections.

7. International Data Transfers

Moor is based in the United States, and Platform data is stored primarily on infrastructure located in the United States. Verification data processed through Crewdentials may be stored in the United Kingdom.

For users in the European Union, European Economic Area, and United Kingdom, personal data is transferred to and processed in the United States, which is not subject to an EU adequacy decision for all processing activities. We rely on the following transfer mechanisms to ensure appropriate safeguards:

• EU Standard Contractual Clauses (SCCs) — incorporated into our data processing agreements with US-based service providers where required
• EU-US Data Privacy Framework — where applicable to specific processors that have self-certified under the framework
• UK International Data Transfer Agreements (IDTAs) — for transfers from the UK where SCCs are not applicable

You may request a copy of the relevant transfer safeguards applicable to your data by contacting hello@moorcrew.com.

8. Cookies and Tracking Technologies

We use cookies and similar technologies for the following purposes:

• maintaining login sessions and account authentication
• understanding usage patterns and improving Platform performance
• supporting advertising placements and measuring ad performance
• detecting fraud and security risks

Users may disable cookies through their browser settings. Disabling certain cookies may affect the functionality of the Platform, including login persistence and some features. Where required by law, we will seek your consent before placing non-essential cookies.

For detailed information about the specific cookies we use, their purposes, and how to manage your preferences, please refer to our Cookie Policy at moorcrew.com/cookies.

9. Data Storage and Retention

9.1 Storage

All Platform data is stored primarily in the United States on infrastructure provided by Supabase, Vercel, and AWS. Reasonable administrative, technical, and physical safeguards are maintained to protect data against unauthorized access, loss, or alteration.

9.2 Retention Periods

We retain personal data only as long as necessary for the purposes for which it was collected, or as required by applicable law. The following criteria determine how long we retain different categories of data:

• Active account data — retained for the duration of your account and for up to 2 years following account closure to comply with legal obligations and resolve disputes
• Job postings and employer listings — retained for 90 days after expiry or closure, unless subject to a legal hold
• Payment and transaction records — retained for 7 years to comply with applicable tax and financial record-keeping requirements
• Security and access logs — retained for up to 12 months for fraud detection and incident response
• Communications and support records — retained for up to 3 years from the date of last interaction

You may request deletion of your account and associated data at any time. See Section 10 for how to exercise this right.

10. Verification Data (Crewdentials)

Moor integrates with Crewdentials, an independent third-party verification provider. Moor does not collect, access, or store verification documents. Crewdentials controls its own verification process, data handling, and storage. Moor receives only a verification status signal — not the underlying documents.

For questions about how Crewdentials handles your data, please refer to Crewdentials' own privacy policy. Moor does not guarantee verification outcomes.

11. In-App Messaging Privacy

Messages sent between users through the Platform are user-to-user communications. Moor does not routinely monitor or review message content. We may access messages where required by law, for the investigation of reported abuse, or to resolve a formal complaint.

We strongly advise users not to share sensitive personal information through messaging, including passport numbers, financial account details, home addresses, or other sensitive data.

12. Advertising Data

If you use the Moor Ads Portal, we collect advertising creative, business information, billing information (excluding full card numbers), campaign settings, and performance metrics. Advertiser content is user-submitted. Moor does not verify claims or representations made in advertisements. For full details, see our Advertising Policy.

13. Your Privacy Rights

Depending on your location, you may have the following rights in relation to your personal data. To exercise any of these rights, contact hello@moorcrew.com. We will respond within 30 days and may request verification of your identity before processing your request.

Rights available to all users:

• Access — request a copy of the personal data we hold about you
• Correction — request that we correct inaccurate or incomplete data
• Deletion — request that we delete your personal data, subject to legal retention obligations
• Withdraw consent — where processing is based on consent, withdraw it at any time without affecting prior processing

Additional rights for EU/EEA and UK users (GDPR and UK GDPR):

• Restriction — request that we limit processing of your data in certain circumstances
• Portability — receive your data in a structured, machine-readable format and request transfer to another controller
• Object — object to processing based on legitimate interests; we will cease unless we have compelling legitimate grounds that override your rights
• Human review — request human review of any automated decision that has materially affected you
• Lodge a complaint — you have the right to lodge a complaint with your local supervisory authority. In the EU, this is your national data protection authority. In the UK, this is the Information Commissioner's Office (ICO) at ico.org.uk.

Rights for California residents (CCPA/CPRA):

• Know — request disclosure of the categories and specific pieces of personal information we have collected about you
• Delete — request deletion of personal information, subject to certain exceptions
• Opt out of sale — we do not sell personal data; this right is therefore not applicable
• Non-discrimination — you will not be penalized for exercising your privacy rights

14. Children's Privacy

The Platform is not intended for individuals under 18 years of age. We do not knowingly collect personal data from minors. If we become aware that we have collected data from a minor, we will delete it promptly. If you believe a minor has submitted data to the Platform, please contact hello@moorcrew.com.

15. Third-Party Links and Services

The Platform may contain links to external websites or services not operated by Moor. We are not responsible for the privacy practices of third-party sites and encourage users to review the privacy policies of any site they visit.

16. Data Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, disclosure, alteration, and destruction. These include access controls, encryption in transit, secure infrastructure, and monitoring for security incidents.

No system is completely secure. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, we will notify affected users and relevant supervisory authorities as required by applicable law.

17. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or applicable law. The updated version will be posted with a revised "Last Updated" date. For material changes, we will provide notice via the Platform or by email. Continued use of the Platform following notice of changes constitutes acceptance of the updated Policy.

18. Contact Information

Digital Marine, LLC
Email: hello@moorcrew.com
Mailing Address: 3330 N Narrows Dr, Tacoma, Washington, USA