Privacy Policy

Effective May 7, 2026 · Prow Equity LLC, operating as KEEL Works · Wilmington, Delaware

This Privacy Policy describes how Prow Equity LLC, operating as KEEL Works ("Company", "we", "us", or "our") collects, uses, and shares information in connection with your use of our website at www.keel-works.com and the KEEL Works application (collectively, the "Site"). Please read this policy carefully. By using the Site, you agree to the collection and use of information in accordance with this Privacy Policy.

1. Information We Collect.

1.1 Information You Provide.

We collect information you provide directly to us, including:

Account information: name, email address, phone number, and password; Vessel information: vessel name, make, model, year, HIN, registration number, engine configuration, slip location, and known conditions; Service history and KEEL Record data: service events, inspection findings, photographs, health reports, and related documentation; Payment information: billing address and payment method details (processed by third-party payment processors); and Communications: messages, feedback, and other communications you send to us.

1.2 Information Collected Automatically.

When you use the Site, we automatically collect certain information, including: IP address, browser type, operating system, referring URLs, pages visited, time spent on pages, and other usage data. We may use cookies and similar tracking technologies to collect this information.

1.3 Information from Third Parties.

We may receive information about you from third parties, including marina operators, service contractors, and other parties involved in the delivery of services to you through the KEEL Works platform.

2. How We Use Your Information.

We use the information we collect to:

Provide, maintain, and improve the Site and Information Services; Build and maintain the KEEL Record for your vessel; Coordinate and dispatch independent contractors to perform authorized services; Generate and deliver Health Reports and service notifications; Process payments and manage billing; Develop aggregated, de-identified data products and analytics relating to marine vessel maintenance and ownership (in which case individual vessel and owner information is anonymized); Communicate with you about your account and services; and Comply with applicable laws and regulations.

3. KEEL Record Data Ownership and Portability.

3.1 Ownership.

All KEEL Record data, service documentation, photographs, health reports, and related records created by Company in connection with your vessel are the property of Prow Equity LLC. Company grants you a non-exclusive, non-transferable license to access and use your KEEL Record data for your personal vessel management purposes during the term of your membership.

3.2 Data Portability.

Upon termination of your membership for any reason, Company will provide you with a copy of your KEEL Record in PDF format within thirty (30) days of written request. Company will retain a copy of the KEEL Record for a period of three (3) years following termination.

3.3 Aggregated Data.

Company reserves the right to use aggregated, de-identified vessel and service data for product development, research, analytics, and business intelligence purposes. De-identified data does not contain personally identifiable information and cannot be used to identify any individual vessel owner.

4. How We Share Your Information.

We do not sell your personal information. We may share your information in the following circumstances:

Service Contractors: We share vessel information and service schedules with vetted independent contractors solely to facilitate authorized service visits; Service Providers: We may share information with third-party vendors that perform services on our behalf, including payment processors, email service providers, and cloud storage providers; Legal Requirements: We may disclose information if required to do so by law or in response to valid requests by public authorities; Business Transfers: We may share or transfer information in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business; and With Your Consent: We may share information with your consent or at your direction.

Mobile Information and SMS Consent: We will not share or sell your mobile phone number or SMS opt-in or consent data with third parties or affiliates for marketing or promotional purposes. We may share your phone number with the service providers that help us deliver the messaging service (such as our SMS provider) solely to send the account, scheduling, and service messages you have requested. Text-messaging originator opt-in data and consent are not shared with any third parties. Message frequency varies; message and data rates may apply. Reply STOP to opt out or HELP for help.

5. California Privacy Rights (CCPA/CPRA).

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with specific rights regarding your personal information.

5.1 Your Rights.

You have the right to: (a) know what personal information we collect, use, disclose, and sell; (b) delete personal information we have collected about you, subject to certain exceptions; (c) correct inaccurate personal information; (d) opt out of the sale or sharing of personal information (we do not sell personal information); (e) limit the use and disclosure of sensitive personal information; and (f) non-discrimination for exercising your privacy rights.

5.2 Categories of Information Collected.

In the past 12 months, we have collected the following categories of personal information: identifiers (name, email, phone, IP address); personal records (vessel information, service history); commercial information (transaction records, membership history); internet activity (usage data, browsing history on the Site); and inferences drawn from this information.

5.3 How to Exercise Your Rights.

To exercise your California privacy rights, please contact us at jnorthrop@prowequity.com or by mail at 2810 N Church St, PMB 951690, Wilmington, Delaware 19802-4447. We will respond to verifiable consumer requests within 45 days. We may need to verify your identity before processing your request.

6. Data Security and Retention.

We implement reasonable technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or method of electronic storage is 100% secure, and we cannot guarantee absolute security.

We retain your personal information for as long as necessary to provide the Site and Information Services, comply with our legal obligations, resolve disputes, and enforce our agreements. KEEL Record data is retained for a minimum of three (3) years following membership termination.

7. Cookies and Tracking Technologies.

We use cookies and similar tracking technologies to track activity on our Site. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site. We do not respond to Do Not Track signals at this time.

8. Children's Privacy.

Our Site is not directed to children under the age of 18. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at jnorthrop@prowequity.com.

9. Changes to This Privacy Policy.

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last revised" date at the top of this policy. Changes are effective when posted.

10. Contact Us.

Prow Equity LLC, Attn: Privacy

2810 N Church St, PMB 951690

Wilmington, Delaware 19802-4447

Email: jnorthrop@prowequity.com

Telephone: (323) 251-8287

11. Governing Language.

This Privacy Policy may be provided in Spanish as a convenience translation. The English-language version of this Privacy Policy is the sole official and legally binding version and controls in all respects. In the event of any conflict, ambiguity, or difference in interpretation between the English and Spanish versions, the English version governs.