Privacy Policy

Introduction

This Privacy Policy explains what personal information Superyacht Holdings LLC (“Superyacht Holdings,” “SYH,” “we,” “us,” or “our”) collects when you access investment.syhclub.comand related SYH investor subdomains (the “Site”), why we collect it, who we share it with, and the rights you have over it.

We are the controller of this information. The Site is our own; we are not hosting it on behalf of anyone else, and there is no other company whose privacy policy governs what we do with your information here.

1. Information you give us

When you request access, we collect:

• your name;
• your email address;
• the fact that you entered a valid access passcode (we do not retain the passcode you typed); and
• your acceptance of the NDA— recorded as the date and time of acceptance, your IP address, your browser’s user-agent string, and the exact name and cryptographic hash of the NDA version you agreed to.

We keep the NDA acceptance record because it is the evidence that the agreement was formed and of exactly which document was agreed. It is retained as a legal record.

We also collect anything you choose to send us by email or telephone.

2. Information we collect automatically

While you use the Site, we automatically record:

• Network and device data: IP address, browser type and version, operating system, and device type (mobile, tablet, or desktop).
• Approximate location: city, region, and country, derived from your IP address. This is approximate and is not GPS or precise location data.
• Referral data: the page or link that brought you to the Site.
• Reading activity: each page you open, the time you opened it, how long the page was actually in view in a foreground tab, and the furthest point you scrolled on it.
• Visit history: each separate session, and the running total of visits and time across sessions, associated with your email address.

We measure time only while the page is actually in the foreground, so leaving a tab open does not accumulate reading time.

We do not collect precise geolocation, we do not use fingerprinting to track you across other websites, and we do not load third-party advertising or social media trackers.

3. Why we collect it, and our lawful basis

Where we rely on legitimate interests, we have considered your interests and rights and concluded that our interest in controlling the distribution of confidential financial information is not overridden by them, in particular because you are told about the tracking before you agree to it.

4. What we do not do

We do not sell your personal information. We do not share it for cross-context behavioural advertising. We do not use it to build advertising profiles. We have not sold or shared personal information in the preceding twelve months.

5. Who we share it with

• Service providers who host and operate the Site, acting on our instructions and bound to protect it: Vercel Inc. (website hosting and delivery), Supabase Inc. (database storage), and Resend (Plus Five Five, Inc.) (transactional email notifications to us).
• Our professional advisers— legal counsel, accountants, and auditors, where needed.
• A counterparty in a transaction— if SYH is involved in a financing, merger, acquisition, or sale of assets, information may be disclosed as part of that process, subject to confidentiality.
• Where the law requires it— to comply with law, regulation, subpoena, or court order, or to establish or defend legal claims.

We do not otherwise disclose your information to third parties.

6. Retention

• NDA acceptance records: retained for the life of the confidentiality obligation and the applicable limitation period, and in any event no less than seven years.
• Reading and visit analytics: retained for as long as the financing is active and for two years afterwards, then deleted or aggregated.
• Correspondence: retained for as long as needed for the relationship and our records.

7. Security

The Site is served over HTTPS and requires a passcode. Analytics data is held in a database that is not reachable from the browser, is accessed only with a server-side credential, and is exposed only through an administrator-authenticated interface. Access is limited to personnel who need it.

No system is perfectly secure, and we cannot guarantee absolute security.

8. International transfers

SYH is based in the United States and our service providers process data in the United States. If you are in the European Economic Area, the United Kingdom, or Switzerland, your information will be transferred to the United States. Where required, we rely on the European Commission’s Standard Contractual Clauses or another lawful transfer mechanism. You may request a copy of the relevant safeguards using the contact details below.

9. Your rights

Depending on where you live, you may have the right to:

• access the personal information we hold about you, and receive a copy;
• correct information that is inaccurate;
• delete your information, subject to our need to retain the NDA record;
• object to or restrict our processing, including our legitimate-interests processing;
• portability— receive your information in a machine-readable format;
• withdraw consent at any time, without affecting processing already carried out; and
• not be discriminated against for exercising any of these rights.

To exercise any right, email matthew@syhclub.com. We will respond within the period the applicable law requires. We may need to verify your identity first. You may use an authorized agent where the law permits.

If you are in the EEA or UK you also have the right to complain to your local supervisory authority.

Note that we cannot delete the NDA acceptance record while the confidentiality obligation it evidences remains in force, because that record is the evidence of an agreement you entered into.

10. Children

The Site is not directed to anyone under 18 and we do not knowingly collect information from children.

11. Changes

We may update this Privacy Policy. The “last modified” date above shows when. If a change is material, we will make reasonable efforts to tell you.

12. Cookies

The cookies we set, and what each is for, are listed in our Cookie Policy.