Privacy Policy
Effective date: 14 May 2026 · Version 3.0
- We collect what we need to run the Service: your account info, vessel telemetry (including precise GPS), AI chat messages, billing info, and usage logs.
- We do not sellor “share” (in the cross-context behavioural-advertising sense) your personal information.
- We honour the Global Privacy Control (GPC) signal as an opt-out request.
- You can access, correct, delete, port, and limit the use of your data — see Section 8.
- Precise vessel GPS coordinates are sensitive personal information. We use them only to provide the Service.
1. Who We Are
True Blue Horizon respects your privacy. This Policy explains what we collect, how we use it, who we share it with, and your rights. References to “we”, “us”, and “our” mean the contracting entity identified in our Terms of Service (True Blue Horizon, Inc. for US customers; True Blue Horizon Pty Ltd otherwise).
For privacy enquiries: privacy@truebluehorizon.com.
2. Information We Collect
We collect personal information directly from you, automatically when you use the Service, and from limited third-party sources (e.g., Google when you sign in via OAuth, Stripe when you pay).
2.1 Categories of Personal Information (CCPA / CPRA disclosure)
| Category (Cal. Civ. Code § 1798.140(o)) | Examples | Collected | Sold / Shared |
|---|---|---|---|
| A. Identifiers | Name, email, account ID, IP, device ID, Gateway serial | Yes | No |
| B. § 1798.80(e) records | Billing address, phone (optional) | Yes | No |
| C. Protected classifications | Age (18+ confirmation only) | No | No |
| D. Commercial information | Subscription, purchase history, hardware order | Yes | No |
| E. Biometric | — | No | No |
| F. Internet / network activity | Pages visited, feature usage, AI queries | Yes | No |
| G. Geolocation | Precise Vessel GPS and track history (sensitive PI) | Yes | No |
| H. Sensory | — | No | No |
| I. Professional / employment | — | No | No |
| J. Education | — | No | No |
| K. Inferences | AI-derived insights about Vessel condition and usage | Yes | No |
| Sensitive PI (CPRA) | Precise geolocation; account credentials | Yes | No |
We do not use or disclose sensitive personal information beyond what is reasonably necessary to provide the Service requested by you, as permitted by CCPA Regulation § 7027. You may still submit a request to limit use of sensitive PI; if you do, we will evaluate the request, but limiting use of precise geolocation will likely make the core Service unusable.
2.2 Telemetry Data
Our Gateway hardware collects real-time telemetry from your Vessel's onboard systems via Signal K-compatible interfaces: engine performance (RPM, temperature, pressure, fuel consumption), navigation (GPS position, speed, heading, depth), environmental (wind, water temperature, barometric pressure), and electrical (battery voltage, alternator output). Telemetry data is treated as personal information when associated with your account.
2.3 AI Chat Interactions
We store your prompts and AI responses to provide chat history, debug issues, and improve the Service. Prompts and Vessel context are transmitted to our AI sub-processor (currently Google Vertex AI) for processing. We use enterprise tiers configured to not use your prompts to train foundation models.
2.4 Automatically Collected Information
We collect device, browser, and log information (IP address, user agent, request timestamps, error events). Cookie and similar technology use is described in our Cookie Policy.
2.5 Information from Third Parties
If you sign in with Google, we receive your name, email, and profile image. Stripe provides payment status, last-four card digits, and country of issuance. We do not buy personal information from data brokers.
3. How & Why We Use Your Information
- Provide and operate the Service (contract performance — Art. 6(1)(b) GDPR; reasonably necessary for the Service under CCPA / state laws).
- Process subscription billing, taxes, and chargebacks (contract; legal obligation).
- Send transactional communications (account, billing, security alerts) (contract; legitimate interest).
- Detect, prevent, and investigate fraud, abuse, and security incidents (legitimate interest; legal obligation).
- Improve the Service, including AI features — using aggregated and de-identified data and limited diagnostic logging. We do not use Customer Data to train foundation models.
- Comply with law, respond to lawful requests, and enforce our Terms (legal obligation; legitimate interest).
- Marketing emails to existing customers about closely related features (legitimate interest, opt-out at any time).
4. How We Share Information
We share personal information only with the categories of recipients below, and only for the purposes described:
- Sub-processors— cloud hosting, authentication, payments, AI inference, mapping, communications, error monitoring, and analytics. See our Sub-Processor List.
- Authorized Users you invite to your Vessel (e.g., crew, co-owners) can access Vessel data per the roles you assign.
- Professional advisors (lawyers, accountants, auditors) under confidentiality obligations.
- Authorities and litigants when required by law or to protect rights, property, or safety.
- Successors in a merger, acquisition, or asset sale, under terms at least as protective as this Policy.
We do not “sell” personal information, and we do not “share” it for cross-context behavioural advertising, as those terms are defined under California law.
5. Storage & Security
Account data and real-time telemetry are stored in Supabase (PostgreSQL) with row-level security policies enforcing multi-tenant isolation. Historical telemetry is stored in Google BigQuery with encryption at rest. All data in transit is encrypted using TLS 1.2 or higher. We employ administrative, technical, and physical safeguards consistent with the New York SHIELD Act, Massachusetts 201 CMR 17.00, California AB 1950, and our industry.
Primary data hosting is in the United States. If you access the Service from outside the US, your information will be transferred to the US. For transfers from the EU, UK, or Switzerland to the US, we rely on Standard Contractual Clauses and the UK International Data Transfer Addendum as set out in our Data Processing Addendum.
Breach notification.In the event of a security breach affecting your personal information, we will notify you and applicable regulators as required by law — generally without unreasonable delay and no later than the timeline required by the laws of your state or country.
6. Retention
| Data category | Retention |
|---|---|
| Account data | For the life of the account + 30 days after deletion |
| Historical telemetry — Entry tier | 3 months |
| Historical telemetry — Pro tier | 12 months |
| Historical telemetry — Custom | As specified in Order Form |
| AI chat history | Until you delete or close the account |
| Billing records (legal) | 7 years |
| Security & audit logs | 365 days |
| Backups | 90 days rolling |
| Aggregated / de-identified data | Indefinitely |
7. AI Output & Automated Processing
The Service uses AI to summarise, suggest, and alert. Our AI output is advisory only and does not produce legal, financial, or other consequential decisions about you. AI features are not substitutes for professional judgment, marine instruments, or safety procedures. See our Marine Safety & AI Disclaimer.
8. Your Privacy Rights
Depending on where you live, you may have the rights to access, correct, delete, port, and limit our use of your personal information; to opt out of “sales” and “sharing”; and to limit our use of sensitive personal information.
How to exercise. Email privacy@truebluehorizon.com or use the web form in your account settings. We will verify your identity and respond within 45 days (extendable by 45 with notice). There is no charge for good-faith requests.
Authorized agent. California consumers may use an authorized agent. The agent must provide written authorization; we may also verify the request with you.
Right to appeal.If we deny your request, reply to our denial with “Appeal” in the subject line. We will respond within 60 days. If you are not satisfied, you may contact your state Attorney General or, for EU/UK residents, your local supervisory authority.
Global Privacy Control.We honour the GPC signal as a valid opt-out request for “sale” and “sharing”. Because we do not sell or share, GPC compliance is effectively automatic.
Non-discrimination. We will not discriminate against you for exercising your privacy rights.
9. State-Specific Notices
California. See our California Privacy Notice for the full CCPA / CPRA disclosure, including categories collected and disclosed in the past 12 months, sources, and retention.
California “Shine the Light”(Cal. Civ. Code § 1798.83). California residents may request a summary of personal information disclosed for direct marketing purposes. We do not disclose personal information to third parties for their direct marketing.
Nevada. Nevada residents may opt out of any future sale of covered information by emailing privacy@truebluehorizon.com.
Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Florida, Iowa, Indiana, Tennessee, Delaware, New Hampshire, New Jersey, Maryland, Minnesota, Kentucky, Rhode Island. Residents have substantially the rights described in Section 8. Several states (e.g., Virginia, Colorado, Connecticut, Minnesota) additionally grant the right to appeal denied requests, which we honour for all customers.
10. Children
The Service is not directed to children under 13, and we do not knowingly collect personal information from children under 13 (COPPA). Account holders must be at least 18. California minors under 16 may request removal of content they have posted by contacting privacy@truebluehorizon.com.
11. International Users
The Service is primarily hosted in the United States. By using the Service from outside the US, you understand that your information will be transferred to and processed in the US. For EU, UK, and Swiss data, we rely on Standard Contractual Clauses and the UK IDTA. EU/UK residents may contact a supervisory authority. We do not currently maintain an Article 27 representative; if required, we will appoint one and update this Policy.
12. Changes
We may update this Policy. Material changes will be notified by email or in-product banner at least 30 days before they take effect. The “Effective date” at the top indicates the current version. Prior versions are available on request.
13. Contact
True Blue Horizon, Inc., Fort Lauderdale, Florida (US customers); True Blue Horizon Pty Ltd, New South Wales, Australia (others). Privacy contact: privacy@truebluehorizon.com.