Effective Date: May 27, 2026
Last Updated: May 27, 2026

This Privacy Policy (“Privacy Policy”) together with our Website Terms of Service sets out the basis on which any Personal Information we collect from you (“you”, “your”, or “client”), or that you provide to us, will be processed by us. By “Personal Information”, we mean any information which, either alone or in combination with other data, enables you to be directly or indirectly identified, for example your name, email address, username, contact details or any unique identifier such as an IP address, device ID or other online identifier.

Please read the following carefully to understand what data we collect, how that data is used and the ways it can be shared by us. If you do not wish for your Personal Information to be used in the ways described within this Privacy Policy, then you should not access or use our website, platform, products, services, functions, features, or related offerings (collectively, the “Services”).

In this Privacy Policy, “Aquanow”, “we”, “us”, and “our” refer to the applicable Aquanow entity providing the Services. Depending on the Services you use and your jurisdiction, the applicable Aquanow entity may act as a “business”, ‘processor’’, “controller”, “organization”, or equivalent term under applicable privacy laws.

Some Aquanow subsidiaries may have different privacy policies to provide notice to you about how your Personal Information is used and disclosed in the context of your use of particular services or relationship to that subsidiary. 

To the extent that our subsidiaries post or reference different privacy policies, the Privacy Policy issued and posted by each subsidiary, not this Privacy Policy, will apply to your Personal Information collected in the context of those services or by that subsidiary.

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How we Collect and use your Personal Information:

“Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, such as your name, email address, IP address, telephone number, and broader categories of information such as your professional information and internet activity.

We may collect Personal Information:

Directly from you: such as any information about you that you provide us when registering for an Aquanow account or corresponding with us by phone, e-mail or other communication channels.. The information may include but is not limited to your name, address, telephone number, certain financial information, your email address and transaction history.

Automatically through our use of cookies and other data collection technologies on our website.

From publicly available sources such as company websites, blogs, news articles, press releases, and corporate records or reports; and

From other third-party sources, such as social media platforms, background check providers, data brokers and third parties to whom you direct us to collect your Personal Information. We will treat Personal Information collected from third-party sources in accordance with this Privacy Policy but we are not responsible or liable for the accuracy of the information provided by third parties or for the third-party policies or practices.

Certain information we collect may be considered sensitive personal information under applicable law, including government-issued identification, financial account information, identity verification information, sanctions screening information, and transaction monitoring information. We process such information only where necessary to provide the Services, comply with legal obligations, prevent fraud, maintain security, or where otherwise permitted by applicable law. We may use automated tools and monitoring systems to support fraud prevention, sanctions screening, transaction monitoring, cybersecurity, and regulatory compliance activities.

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Purposes for which we collect your Personal Information:

We generally use your Personal Information for the following purposes:

to properly identify you;

to deliver products and services to you;

to understand your needs and your eligibility for products and services;

to establish and maintain a responsible commercial relationship with you;

to develop, enhance, market and provide products and services to you;

to process billing and collection of any fees;

to conduct surveys and get feedback from you. You may opt-out of receiving certain promotional e-mail messages from us as described in the “Marketing Opt-Out” section below;

to meet our legal and regulatory requirements;

to process your inquiries or respond to questions, comments or concerns regarding Aquanow;

to recruit for positions at Aquanow; and

to prevent fraud, monitor transactions, maintain cybersecurity, and support risk management and compliance activities.

Where required under applicable privacy laws, we collect, use, and disclose Personal Information with your consent or as otherwise permitted or required by law, including where necessary to provide the Services, comply with legal obligations, protect against fraud or security risks, or pursue legitimate business purposes.

Transactions involving digital assets and public blockchains may be publicly visible and immutable by design. Certain blockchain transaction information, including wallet addresses and transaction hashes, may remain publicly accessible even where associated Personal Information is deleted from our systems.

We may use automated tools and monitoring systems to support fraud prevention, sanctions screening, transaction monitoring, cybersecurity, and regulatory compliance activities. Where such automated tools constitute “automated decision-making technology” (“ADMT”) under applicable law, including the California Consumer Privacy Act as amended, individuals may have the right to: (i) receive a pre-use notice before their Personal Information is used in ADMT; (ii) access information about the logic of the ADMT and how its outputs are used; (iii) opt out of certain uses of ADMT; and (iv) appeal significant decisions made using ADMT. Where Aquanow uses ADMT to make or substantially inform significant decisions, we will provide applicable notices and honor opt-out and access requests as required by law. To exercise these rights, please contact us at legal@aquanow.io.

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.

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How we Disclose Your Personal Information

We may share your Personal Information in the following circumstances:

Service Providers: We may share your Personal Information with companies or individuals that we contract with in order to receive services (our “Service Providers”). These services may include, among other things, providing products or services to you on our behalf, creating or maintaining our databases, payment processing, researching and analyzing the people who request information from us, preparing distribution communications or responding to inquiries. We do not allow our Service Providers to use or disclose your Personal Information for any purpose other than for providing services to us.

Affiliates and Subsidiaries: We may share your Personal Information with companies that we own or control, or that own or control us, or that are under common ownership or control with us.

Third Parties: We may share your Personal Information with companies or individuals outside of the Aquanow group who may use your Personal Information for their own purposes (a “Third Party”). For example:

We may be required to provide Personal Information to a Third Party in response to a court order, subpoena, government investigation, regulatory inquiry, or as otherwise required by law.

We may share your Personal Information with Third Parties, such as law enforcement agencies, when we, in good faith, believe: (i) you or others are acting unlawfully, (ii) it is necessary or appropriate to satisfy any law, regulation or other governmental request, (iii) it is necessary to operate our business and Services properly, or (iv) it is necessary to protect or defend our rights or the rights or well-being of our users, even without a subpoena, warrant or court order.

We do not sell Personal Information for monetary compensation. However, certain disclosures involving analytics or advertising technologies may be considered a “sale”, “sharing”, or targeted advertising disclosure under certain U.S. privacy laws. Where required by applicable law, you may opt out of such disclosures by using available consent management tools or by contacting us at legal@aquanow.io. We provide a “Do Not Sell or Share My Personal Information” link on our website for California residents.

A Reorganization Event: We may, as a result of a sale, merger, consolidation, change in control, transfer of assets, reorganization or liquidation of our company (a “Reorganization Event”), transfer, sell or assign your Personal Information to parties involved in the Reorganization Event. You acknowledge that such transfers may occur and are permitted by and subject to this Privacy Policy.

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Security and Confidentiality:

Your Personal Information may be transferred to, stored in, or processed in jurisdictions outside your country of residence. Where required by applicable law and regulation, we ensure appropriate safeguards for international transfers of Personal Information, including contractual protections or other legally recognized transfer mechanisms.

Aquanow is committed to protecting your privacy. Internally, only people with a business need-to-know Personal Information, or whose duties reasonably require access to it, are granted access to Personal Information. Such individuals will only process your Personal Information on our instructions and are subject to a duty of confidentiality.

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Cookies Data and other Technologies:

We use cookies and similar tracking technologies such as web beacons, pixels, analytics tools, and similar technologies to operate, secure, improve, and market the Services. We and certain third parties may use these technologies for analytics, advertising, remarketing, and measuring the effectiveness of communications and campaigns.

Where required by applicable law, we will obtain your consent before using non-essential cookies or similar tracking technologies. You may manage cookie preferences through your browser settings or available consent management tools. We honor the Global Privacy Control (GPC) opt-out preference signal for California residents as required under applicable California law. When we detect a GPC signal from a California resident’s browser, we will treat it as a valid request to opt out of the sale or sharing of that individual’s personal information.

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Examples of Cookies we use:

Necessary cookies - these are used for technical reasons and are necessary to enable the Services to operate efficiently so that you can navigate the Services with ease and use specific features. These include, for example, cookies that help us to debug any errors. If these cookies are blocked or disabled, some of the Services may not operate effectively.

Preference cookies - these are used to improve the functionality of the Services and make it easier to use. They help us to identify you as a repeat user of the Services and help us remember your preferences (for example, your choice of language or region).

Analytical cookies - these record your visit to our Services, the pages you have visited and the links you have followed. We may use this information to improve the Services and to better understand how users interact with our website. Where required by applicable law, users may reject or manage non-essential cookies through available consent management tools.

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Marketing Opt-Out

You may unsubscribe from receiving promotional emails from us by following the unsubscribe instructions included in those communications or by contacting us at legal@aquanow.io. Please note that even if you opt out of receiving promotional communications, we may continue to send you non-promotional communications relating to your relationship with us, including service-related or legally required notices.

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Canadian and United States Privacy Rights

Aquanow is headquartered in Canada. We are subject to applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (“PIPEDA”), substantially similar provincial privacy laws where applicable, Quebec privacy legislation (including Quebec’s Act respecting the protection of personal information in the private sector, as amended by Law 25), and Canada’s Anti-Spam Legislation (CASL), as applicable. In accordance with PIPEDA’s accountability principle, Aquanow has designated a Privacy Officer who is responsible for our organization’s compliance with applicable Canadian privacy laws.

Quebec residents have the right to receive, in a structured, commonly used technological format, Personal Information collected from them, to the extent required under applicable Quebec law, and to request that such information be communicated to a person or organization designated by the individual, where technically feasible. Where we carry out cross-border transfers of Personal Information, we conduct privacy impact assessments as required by applicable Quebec law. Quebec residents also have the right to request the de-indexation of Personal Information that has been disseminated online where its retention is no longer justified by the original collection purpose, or where its dissemination causes injury (the “right to de-indexation”). Quebec residents further have the right to object to certain uses of their Personal Information in automated decision-making and to request human review of any decision based exclusively on automated processing. Aquanow has designated a Privacy Officer who is responsible for our compliance with applicable privacy laws; to contact our Privacy Officer or exercise any of these rights, please contact us at legal@aquanow.io.

Depending on your jurisdiction, including if you are a resident of California or another U.S. state with applicable privacy laws, you may have additional rights relating to access, correction, deletion, portability, restriction, objection to certain processing, withdrawal of consent, and certain automated decision-making activities. Nevada residents may also have the right to opt out of the sale of certain Personal Information under Nevada law. To exercise this right, please contact us at legal@aquanow.io.

California residents may have rights under applicable California privacy laws, including the right to know or access Personal Information, the right to delete Personal Information, the right to correct inaccurate Personal Information”, the right to opt out of certain sales or sharing of Personal Information”, the right to limit certain uses or disclosures of sensitive Personal Information where applicable, and the right not to be discriminated against for exercising applicable privacy rights. California residents also have the right to opt out of, access information about, and appeal significant decisions made using automated decision-making technology (ADMT) as further described in the “Automated Decision-Making” section above. Where required by applicable California law, we provide a separate “Opt-Out of Automated Decision-Making Technology” link or mechanism on our website.

We may request information necessary to verify your identity before responding to privacy rights requests. Where permitted by applicable law, you may designate an authorized agent to make a request on your behalf. We will respond to privacy rights requests in accordance with applicable law, generally within 30 days under PIPEDA and 45 days under applicable U.S. state privacy laws (with an extension of up to an additional 45 days where reasonably necessary).

Depending on your jurisdiction, you may also have the right to lodge a complaint with an applicable privacy or data protection regulator.

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Security

We maintain appropriate technical and organizational safeguards designed to help protect Personal Information from unauthorized disclosure or access and accidental or unlawful destruction, loss, or alteration. For example, we limit access of your Personal Information to authorized parties and have systems in place designed to monitor and prevent data leakage, and to ensure that we can restore availability and access to Personal Information. Although we use reasonable efforts to safeguard Personal Information, we cannot guarantee the security of Personal Information obtained or stored electronically.

Where required by applicable law, we will notify affected individuals and/or applicable regulators of certain data breaches in accordance with our legal obligations.

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Data Retention

We retain Personal Information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including to comply with legal, regulatory, tax, accounting, reporting, anti-money laundering, and recordkeeping obligations. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure; the purposes for which we process the Personal Information and whether we can achieve those purposes through other means; and applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period we will remove Personal Information from our systems and records or take appropriate steps to properly anonymize it.

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Children’s Privacy

Our Services are not directed to children, and we do not knowingly collect Personal Information from individuals under the age permitted by applicable law.

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Changes to Our Privacy Policy

We may occasionally update this Privacy Policy to reflect changes in our practices. When we post modifications to this Privacy Policy, we will revise the “Last Updated” date at the top of this web page.

We encourage you to periodically review this page for the latest information on our privacy practices.

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Contact Us:

If you should have any questions, concerns, or requests regarding this Privacy Policy, please contact us via legal@aquanow.io.

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