ALLBOATS CLUB

Privacy Policy

Effective Date: April 2nd, 2026

1. Introduction and Scope

This Privacy Policy describes how Sealma corp., doing business as Allboats Club ("Allboats Club," "we," "us," or "our"), collects, uses, discloses, stores, and otherwise processes Personal Information through Allboatsclub.com, related websites, applications, communications, and services (collectively, the "Services").

Please read this Privacy Policy together with our Terms of Service. By using the Services or otherwise providing Personal Information to us, you acknowledge this Privacy Policy. If you do not agree, do not use the Services.

This Privacy Policy may change from time to time. We may post updates on the Services and, where required by law, provide additional notice.

Defined Terms

For purposes of this Privacy Policy:

• "Creator" or "Curator" means a user who promotes yachts, charter offers, destination content, or related travel products through referral links, curated collections, editorial content, social media, or similar placements on or in connection with the Services.

• "Charter Provider" means a yacht charter company, fleet operator, broker, supplier, or other third-party business offering charter products or services through or in connection with the Services.

• "Client" means a user who browses, inquires about, books, or pays for a charter or related service through the Services.

• "Visitor" means any person who visits the Services, including a user who lands on the Services through a Creator or Curator referral link.

• "Merchant" means, where applicable, any third-party partner, travel supplier, retailer, advertiser, or service provider whose products or services may be promoted or sold through the Services.

• "Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. Where applicable, this also includes "Personal Data" under relevant privacy laws.

2. What Personal Information We Collect

The categories of Personal Information we collect depend on how you interact with the Services.

A. Information You Provide Directly

• Account and profile information, such as name, email address, phone number, username, password, billing country, account type, and social profile links.

• Creator or Curator application information, such as social handles, audience information, niche or vertical, payout details, tax information, and content preferences.

• Client inquiry and booking information, such as destination, dates, group size, budget, yacht preferences, special requests, contact details, emergency contacts, and booking history.

• Charter Provider information, such as business name, contact information, fleet details, pricing, availability, tax/VAT information, banking details, and account credentials.

• Payment and payout information, such as partial payment card data, payout destination details, invoices, and transaction records. Payment card details may be collected directly by third-party processors rather than stored by us.

• Communications and support information, such as messages sent through the Services, email communications, reviews, feedback, survey responses, and customer service records.

B. Information We Collect Automatically

• Device and usage data, such as IP address, approximate location derived from IP, browser type, operating system, device identifiers, pages viewed, links clicked, session duration, time zone, referring URL, and diagnostic data.

• Referral and attribution data, such as referral parameters, UTM tags, campaign identifiers, creator IDs, cookies, session IDs, click timestamps, attributed booking events, and other data used to attribute traffic and commissions.

• Transaction and commercial data, such as inquiry history, booking status, payment status, refunds, chargebacks, cancellations, applied discounts, and commission-related information.

• Marketing and advertising data, such as whether you open emails, click marketing links, interact with ads, or respond to campaigns.

C. Information From Third Parties

• Social media or third-party account information if you connect an account or apply as a Creator or Curator using such account.

• Information from payment processors, fraud prevention providers, analytics providers, advertising partners, and identity verification vendors.

• Information from Charter Providers, Merchants, or business partners regarding bookings, cancellations, inventory, eligibility, and commission reconciliation.

3. Why We Collect and Use Personal Information

We may collect and use Personal Information for the following business and commercial purposes:

• To provide, operate, maintain, personalize, and improve the Services.

• To create and administer accounts and profiles.

• To process inquiries, bookings, payments, refunds, chargebacks, payouts, and commissions.

• To track referral traffic, attribute bookings, calculate Creator or Curator commissions, and administer affiliate or partner programs.

• To verify identity, prevent fraud, detect suspicious activity, enforce our Terms, and protect the Services.

• To communicate with you about your account, bookings, payments, service updates, support matters, legal notices, and policy changes.

• To send marketing communications, offers, destination content, or platform updates, subject to applicable law and your preferences.

• To analyze platform usage, campaign performance, conversion events, booking funnels, and operational performance.

• To comply with legal obligations, tax obligations, accounting requirements, and law enforcement requests.

• To establish, exercise, or defend legal claims and protect our rights, users, and partners.

4. Referral Tracking, Cookies, and Attribution

A core part of Allboats Club’s model is referral-based discovery and commission attribution. When a Visitor reaches the Services through a Creator or Curator link, campaign, collection, or similar referral source, we may use cookies and similar technologies to remember that referral and attribute later activity.

How referral tracking may work

• We may store referral parameters, creator identifiers, timestamps, device or browser identifiers, and session information.

• We may connect those signals to later inquiries, sign-ups, bookings, or purchases on the Services.

• We may use this information to determine whether a Creator, Curator, or partner is eligible for commission or other compensation.

• Attribution may apply across different pages or areas of the Services and may remain active for a limited period after the initial visit.

Attribution window

Unless otherwise disclosed in a campaign, creator agreement, or platform notice, referral attribution may remain active for up to 40 days from the initial qualifying click or visit. Attribution rules may be updated from time to time to address fraud, technical limitations, duplicate attribution claims, or operational needs.

Cookies and similar technologies

We and our partners may use strictly necessary cookies, analytics cookies, functional cookies, advertising cookies, pixels, tags, SDKs, and similar technologies for authentication, security, measurement, personalization, advertising, referral attribution, and performance reporting.

You can often manage cookies through your browser settings and, where available, through our consent or cookie settings tools. Disabling some cookies may reduce functionality of the Services.

5. Legal Bases for Processing

Where required by applicable law, we rely on one or more of the following legal bases for processing Personal Information:

• Performance of a contract or pre-contractual steps, such as operating accounts, processing bookings, and handling payments or payouts.

• Legitimate interests, such as operating and improving the Services, preventing fraud, measuring marketing performance, and administering referral attribution and commissions.

• Consent, where required, such as for certain marketing, cookie, or optional account connection features.

• Compliance with legal obligations, such as tax, accounting, sanctions, consumer protection, and law enforcement obligations.

6. How We Collect Personal Information

• Directly from you when you create an account, submit forms, make inquiries, complete a booking, apply as a Creator or Curator, list as a Charter Provider, communicate with us, or otherwise use the Services.

• Automatically through cookies, logs, analytics tools, SDKs, pixels, and similar technologies when you browse or interact with the Services.

• From third parties, such as social networks, payment processors, Charter Providers, Merchants, analytics vendors, advertising partners, identity verification providers, and fraud prevention providers.

7. How We Disclose Personal Information

We may disclose Personal Information to the following categories of recipients, as permitted by law:

• Service providers that host, operate, secure, analyze, support, or improve the Services.

• Payment processors and payout providers that facilitate payments, refunds, and distributions.

• Charter Providers, Merchants, and business partners where necessary to process a booking, inquiry, transaction, payout, or commission event.

• Advertising, analytics, and attribution partners that help us understand traffic, conversions, campaign performance, and remarketing effectiveness.

• Professional advisors, such as lawyers, auditors, insurers, accountants, and tax advisors.

• Government authorities, regulators, courts, or law enforcement where required by law or to protect rights and safety.

• Acquirers, investors, successors, or counterparties in connection with a merger, financing, acquisition, restructuring, or sale of assets.

We may also disclose information in deidentified, aggregated, or anonymized form where permitted by law.

8. Payments and Payment Processors

If you make a payment through the Services, payment information may be collected and processed by one or more third-party payment processors. We may receive limited transaction details, billing metadata, payment status information, and fraud signals, but we may not store full payment card data ourselves.

Before publication, update this section to reflect your actual providers, such as Stripe and any additional processor, wallet, or payout partner you use.

• Primary payment processor(s): Stripe |stripe.com

• Primary payout provider(s): Stripe | stripe.com

9. Sensitive Data and Special Categories

We do not seek to collect sensitive Personal Information unless reasonably necessary for a lawful business purpose or unless you choose to provide it. Please do not provide sensitive information that is not requested.

If we process sensitive Personal Information, we will do so in accordance with applicable law and any additional notices provided at the point of collection.

10. Children’s Privacy

The Services are not intended for children under 13, and children under 13 may not use the Services. If you are under 18 but at least 13 years old, you may only use the Services with the involvement and permission of a parent or legal guardian, to the extent permitted by applicable law.

If we learn that we have collected Personal Information from a child in violation of applicable law, we will take commercially reasonable steps to delete that information.

11. Marketing Communications

We may send you service-related communications and, where permitted, marketing communications regarding bookings, yachts, destinations, creator opportunities, platform features, promotions, and partner offers.

You can opt out of marketing emails by using the unsubscribe link in the message or by contacting us. Even if you opt out of marketing, we may still send non-promotional transactional or legal notices.

12. Analytics, Advertising, Sale, and Sharing

We may use third-party analytics and advertising tools to measure usage, understand conversions, personalize experiences, and deliver or measure advertising.

Depending on applicable law, certain disclosures involving cookies, pixels, identifiers, or audience matching may be considered a 'sale,' 'sharing,' or targeted advertising. We may disclose identifiers, internet activity, approximate geolocation, commercial information, and inferences to analytics or advertising partners for these purposes.

Where required, we provide choices to opt out of such activities, including through cookie settings, opt-out mechanisms, or recognized browser signals such as Global Privacy Control where legally required.

13. Retention

We retain Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, maintain business records, resolve disputes, enforce agreements, prevent fraud, comply with legal obligations, and support tax and accounting requirements.

Retention periods may vary depending on the type of information, the sensitivity of the information, the nature of the relationship, and applicable legal obligations.

14. Security

We use commercially reasonable technical, administrative, and organizational safeguards designed to protect Personal Information against unauthorized access, loss, misuse, alteration, or disclosure.

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

15. International Transfers

We are based in USA, WA state, and we and our service providers may process Personal Information in the United States, Canada, the European Economic Area, the United Kingdom, and other countries. These countries may have data protection laws that differ from those in your jurisdiction.

Where required by law, we will use appropriate safeguards for international transfers, such as contractual protections, adequacy mechanisms, or other lawful transfer tools.

16. Third-Party Links and Services

The Services may contain links to third-party sites, shops, social media pages, Charter Provider sites, booking engines, or merchant pages. We are not responsible for the privacy practices of those third parties. We encourage you to review their privacy policies before interacting with them.

17. Your Privacy Rights

Depending on your location and subject to applicable law, you may have certain rights regarding your Personal Information, including rights to:

• Know or access the Personal Information we hold about you;

• Correct inaccurate Personal Information;

• Delete Personal Information;

• Receive a portable copy of certain data;

• Object to or restrict certain processing;

• Withdraw consent where processing is based on consent;

• Opt out of targeted advertising, sale, or sharing where applicable;

• Not be discriminated against for exercising applicable privacy rights.

We may need to verify your identity before processing certain requests. You may also have the right to designate an authorized agent, subject to applicable verification requirements.

18. Region-Specific Notices

United States

If you reside in a U.S. state that provides privacy rights, you may submit a request using the contact details below and, where available, exercise certain choices through our cookie or privacy settings tools.

EEA, UK, and Switzerland

If you are located in the EEA, UK, or Switzerland, you may have the right to lodge a complaint with your local data protection authority.

Canada and Other Jurisdictions

If you are located in Canada or another jurisdiction with applicable privacy rights, you may also have rights under local law. Contact us using the details below to exercise your rights or ask questions.

19. Do Not Track and Browser Signals

Some browsers offer a 'Do Not Track' setting. Because there is not yet a uniform industry standard for Do Not Track, the Services may not respond to those signals unless required by law. Where legally required, we may honor certain opt-out preference signals, such as Global Privacy Control, for relevant processing activities.

20. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the effective date above and post the updated version on the Services. Where required by law, we will provide additional notice.

21. Contact Us

If you have questions about this Privacy Policy, your Personal Information, or your privacy rights, contact:

• Sealma corp. Allboats Club

• [email protected]

A separate Cookie Policy may be published in addition to this Privacy Policy if desired for operational or jurisdiction-specific compliance purposes.