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Orange County Investment Group, Inc., DBA Blue Water Ads and Subsidiaries Privacy Statement:

Effective Date: January 1st, 2018

This Privacy Policy described the process of how Bluewater Ads collect, use, and disclose user information, and your choices available for managing your information preferences.

What This Policy Covers

Blue Water Ads (“BlueWaterAds”) is committed to protecting the privacy of Internet users. Accordingly, we strictly adhere to all industry guidelines, and will continue to review and improve our privacy policy and procedures to ensure the safety and protection of consumer information. This Privacy Policy describes Bluewater Ads’ data practices related with our corporate website (www.bluewaterads.com) and Bluewater Ads managed services (“Services”), and the choices that are provided in association with our collection and use of your information. This intended audience of this Privacy Policy are publisher partners (“Publishers”) as well as users of websites and apps.

Publishers: this Policy describes how Bluewater Ads may collect, use and disclose information related with your company and with your company’s web properties and apps that use Bluewater Ads Services.

Individual Website and App Users: this Privacy Policy describes how Bluewater Ads may collect, use, and disclose information when you visit the Bluewater Ads website or when you use any website or app that uses Bluewater Ads Services.

Bluewater Ads Services include our Supply Side Platform, a Web-based technology marketplace that allows publisher partners, advertiser partners, and ad networks to conveniently market, buy and sell digital, mobile advertising, as well as ad inventory. Bluewater Ads also delivers services, such as our proprietary ad serving platform, through which we act as a service provider who enables Bluewater Ads publisher partners, advertisers partners, ad networks, and other clients to manage their advertising/marketing inventory and to collect and use data to provide advertising on their digital web and mobile properties and across the Internet. As a result, publishers may use our services to process data, which they collect or source. Publishers and other clients/partners may also have their own policies that govern how they collect, use, and share data. These policies may differ from Bluewater Ads’ policies described in this Privacy Policy. Please refer to the privacy policies of the websites visited and apps used to familiarize yourself with their privacy policies and procedures and learn about any options these companies may offer with respect to their information collection and management standards.

Lastly, the Bluewater Ads website may contain links to websites or content operated and maintained by third parties, over which we have no control. We encourage you to review the privacy policy of any third-party website you intend to visit before disclosing any information to the website.

Information Collection and Usage

Bluewater Ads collects contact information through our website when you choose to provide it, such as name, username, or email address. For example, you may be asked to provide us with contact details when you register with the Bluewater Ads website and when you want to obtain our  Services. Providing this information is optional; however, if you decide not to register or provide the necessary information, you may be prevented from accessing certain content, features and functionality, or services available on or through the Bluewater Ads website. In order to make payments owed to Publishers, Bluewater Ads may also ask for additional billing and account  information from Publishers.

Bluewater Ads uses your contact and billing details to operate and improve our website and Services, this includes providing notices about your Service, to fulfill your service requests, or to obtain your feedback or to conduct research. Bluewater Ads also uses contact information to send you information about new products, product features or Services; where Bluewater Ads obtains your explicit permission to send you this information.

Bluewater Ads may also collect additional information details through our website and Services, such as the following:

  • ‘Free form’ demographic information (e.g. age, gender, marital status)
  • Web Browser information (e.g. URL, browser type, ‘click through’ data)
  • Advertising reporting or delivery data (e.g. size/type of ad, ad impressions (views), location/format of ad unit, data about interactions with the ad unit)
  • Device-type information (e.g. screen dimensions, device brand and model)
  • Unique identification numbers (e.g. IP address and mobile/cell phone device ID)
  • Location data (as derived from IP address or GPS (for mobile))
  • Interest segments (i.e. inferred information on the behavior or likely interests associated with a device)
  • Information about the possible relationships among different browsers and devices
  • Information about your activities on our website and Services

The  data collected via the Bluewater Ads Platform, may be combined with information that does not directly identify an individual with data collected from other sources and disclose the combined information to participating publisher partners, advertiser partners and ad networks so that they can determine whether to submit a bid on ad inventory and to improve the relevance of the advertising presented to users. We also use the information we collect to host, operate, maintain, secure, and further develop and improve our Services, such as to keep track of advertising delivery and to measure the effectiveness of advertising delivered through our Services, and investigate compliance with Bluewater Ads’ policies and terms and conditions.

Bluewater Ads does not engage in activities that require parental notice or consent under the Children’s Online Privacy Protection Act (COPPA). If you believe that Bluewater Ads has inadvertently collected information from a child under 13 that is subject to parental notice and consent under COPPA, please immediately contact Bluewater Ads using the contact information below to request deletion of the information.

Browser Cookies and Other Similar Technologies. Cookies (a small file containing a series of characters that uniquely identifies your Web browser), Web beacons (an electronic file placed within a Web site that monitors usage), pixels, and similar technologies to operate and improve our website and Services, including for interest-based advertising as described below. Some of our Service Providers (defined below) may also use such similar technology practices in conjunction with the services they perform on our behalf.

We use the following categories of cookies for our website and Services:

Essential Cookies

These cookies are essential in order to allow you to navigate our website and use its features. Without these cookies, Services you have asked for such as remembering your login details cannot be provided.

Fulfillment  Cookies

These cookies collect anonymized information on how users navigate our website. For example, these cookies are used to help us understand how customers land on our site, browse or use our website and expose areas of improvement, such as navigation and marketing campaigns. The data stored by these cookies never collect or show personal details from which your individual identity can be established.

Practical Cookies

These cookies remember the choices you make such as the country of origin from which you visit our website, language and search parameters such as size, color or product line. These cookies can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and relevant to your interests. The information these cookies collect are anonymized and cannot track your browsing activity on other websites.

Advertising & Targeting Cookies

These cookies collect information about your browsing behavior to make advertising more tailored to your interests and needs. Additionally, they are also used to limit the frequency of the ads you see and help measure the effectiveness of an ad campaign. The cookies remember the websites you visit and that information is shared with other parties such as advertisers. Please refer to the Interest-Based Advertising section below for information about your choices regarding our use of these technologies for interest-based advertising.

Publishers, advertisers and third-party ad networks that participate in the Bluewater Ads Supply Side Platform may also use cookies or similar mechanisms to deliver ads and monitor their delivery performance. The collection of information through cookies or similar technologies by such third parties are governed by their own privacy policies and principles, which Bluewater Ads has no control over.

Your web browser may offer tools to enable or disable cookies by modifying the settings within the browser. However, please keep in mind certain features of the Bluewater Ads website may not properly function if you delete or disable cookies. Furthermore, deleting these cookies after previously opting out of Bluewater Ads’ platform practices, you may be required to renew your opt-out choice. To read about your options with regard to Bluewater Ads’ use of cookies in our services, please see below.

Mobile Choice Mechanism

Opting out on a mobile device:

If you are using a mobile device and would like to opt out of interest-based advertising then please follow this link for instructions on how to opt out across multiple mobile operating systems such as iOS and Android. Please note that the opt out process is different for each mobile operating system.

If you reject processing via one of these methods, one of the mobile operating systems will set a cookie on your browser that tells PilotX.tv not to tailor ads to your interests. Opting out does not mean you will not be served an ad by PilotX.tv, but the ads we serve will be less relevant to your interests. EU data subjects receive additional rights as described.

Information Sharing

We will disclose contact and billing information to third parties only as described in this Privacy Policy:

  • upon your expressed consent;
  • with our affiliates, which include entities controlling, controlled by, or under common control with Blue Water Ads;
  • where we have agreements with third party entities to provide certain services, such as advertising, analytics, data management services, web hosting, and web development (“Service Providers”). We ask Service Providers to confirm their privacy and security practices are consistent with Blue Water Ads policies and procedures, we provide our Service Providers with only the information necessary for them to perform the services we request, and Service Providers are prohibited from using such information for purposes other than as intended and specified by Blue Water Ads;
  • in the event that the LLC which owns Blue Water Ads is merged, sold, or in the event of a transfer of some or all of our assets (including in bankruptcy), or in the event of another corporate change, we may disclose or transfer information in connection with such transaction; and
  • where we believe it is necessary to protect Blue Water Ads or our users; to enforce our terms or the legal rights of Blue Water Ads or others; or to comply with a request from governmental authorities, legal process, or other legal obligations.

We may also, with discretion, share and disclose other information that we collect, including aggregate information, as we consider necessary to develop and provide our Services, including in the methods described above.

Blue Water Ads may also be required to disclose information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Legal Basis for Processing Personal Information of European Economic Area (“EEA”)

Individuals: On certain occasions, Bluewater Ads relies on the consent of the individual to process personal information, such as, when the user enters personal information into the Bluewater Ads website. On other instances, Bluewater Ads may process personal information when Bluewater Ads needs to do this to fulfill a contract or where Bluewater Ads is required to do so by law.

Bluewater Ads may also process data when it is in Bluewater Ads’ or its customer’s legitimate interests to do this and when these interests are not overridden by the individual’s data protection rights (which may vary based on an individual’s jurisdiction). Those legitimate interests include improving Bluewater Ads’ Services.

Interest-Based Advertising and Opting Out

Blue Water Ads adheres to the Digital Advertising Alliance (DAA) Self-Regulatory Principles in the US and to the European Digital Advertising Alliance (EDAA) Principles in the European Union (“EU”) and the IAB Europe OBA Framework.

As previously mentioned, the Bluewater Ads platform uses cookies, Web beacons, pixels, and similar technologies to give Publishers the possibility to offer, and platform advertisers the ability to show, targeted ads on the device on which you are viewing this policy or a different device. These ads are more likely to be relevant to you as they are based on interests drawn from location data, web viewing data collected across non-affiliated sites over time, and/or application use data collected across non-affiliated apps over time. This is considered “interest-driven advertising.” In addition, certain third parties may collect information on the Bluewater Ads website and combine this data with information collected from other websites over time for purposes that include interest-driven advertising.

Opting Out for Cookie-Based Services: If you would like to learn more about this type of advertising, or would prefer to opt out of website interest-based advertising enabled by Blue Water Ads’ Supply Side Platform, EEA individuals may opt-out of this form of advertising by companies participating in the EDAA at www.youronlinechoices.com and all other users may visit www.aboutads.info/choices to opt out of this form of advertising by companies participating in the DAA self-regulatory program. Please note that in order for your opt-out choice to be effective using this tool, you must ensure that your browser is set to accept third-party cookies such as the Bluewater Ads opt-out cookie. Some browsers block third-party cookies by default, and you may need to change your browser settings to accept third-party cookies before opting out. To manage Flash cookies, please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

Opting Out for Certain Non-Cookie Services (in applicable countries): To help identify your browser and/or possible relationships between different browsers and devices, Blue Water Ads or our partners may use the local storage or cache in your browser. Using the browser cache or local storage helps Blue Water Ads or our partners deliver interest-based advertising to a browser without the use of third-party cookies. To opt out of Blue Water Ads’ use of local storage or the browser cache to provide its services, please (1) use any tools provided by your browser to clear local storage and the browser cache, and (2) turn on any “Do Not Track” header setting offered by your browser. As long as the two steps are completed and maintained on a browser, Blue Water Ads will not use local storage or the cache on that browser to identify and sync browsers and devices. If you also want to opt out of Blue Water Ads’ use of third-party cookies for interest-based advertising enabled by Blue Water Ads’ Supply Side Platform, please see instructions above.

Opting Out for Mobile Application Data: To opt out of Blue Water Ads’ collection, use, and transfer of data for interest-based advertising on mobile apps, you may download the DAA’s AppChoices application from the Android or iOS app store on your mobile device. Users outside the United States may not have access to this application; instead, you can use “Limit Ad Tracking” in your iOS settings or “Opt out of interest-based ads” in your Android settings to limit Blue Water Ads’ collection of data for interest-based advertising.

Opting Out for Location Data: You may opt out of our collection, use, and transfer of precise location data by using the location services controls in your mobile device’s settings.

Effect of Opting Out: If you use a different device or browser, or erase cookies from your browser, you will need to renew your opt-out choice.

If you opt out of Blue Water Ads’ practices, you may continue to receive interest-based advertising through other companies. Third-party advertisers and ad networks that participate in the Blue Water Ads Supply Side Platform may also use their own cookies and other ad service technologies to display and track their ads. We do not control and are not responsible for such third-party advertisers’ and ad networks’ information practices or their use of cookies and other ad service technologies. To learn more about the practices of these companies, please read their privacy policies.

Even if you opt-out, Blue Water Ads may continue to collect data for other purposes and you still will receive advertising from the Blue Water Ads Supply Side Platform when you visit websites of a Publisher who uses our Services – but such advertising will not be targeted to you.

Reviewing and Updating Information

Bluewater Ads takes reasonable steps to ensure that information is accurate, complete, current, and reliable for its intended use. For contact or billing information submitted through our website, you may review, correct, update, or change your information, request that we deactivate your account, or remove your information from our direct marketing efforts, at any time by emailing us at privacy@bluewaterads.com.

International Information Transfers

Please be aware that the information we collect, including contact and billing information, may be transferred to and maintained on servers or databases located outside your state, province, country, or other jurisdiction, where the privacy laws may not be as protective as those in your location. If you are located outside of the United States, please be advised that we process and store information in the United States and your consent to this Privacy Policy or use of Bluewater Ads Services represents your agreement to this processing.

For EEA and Swiss Individuals.

Bluewater Ads complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from EEA member countries and Switzerland, as that term is defined in the Privacy Shield Framework. Bluewater Ads has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

Bluewater Ads is accountable for information that it receives under the Privacy Shield and subsequently transfers to a third party. Bluewater Ads transfers contact and billing information to third parties as described above in this Privacy Policy. Additionally, Bluewater Ads transfers other information which meets the definition of “personal data” in the Privacy Shield Framework to service providers and to Bluewater Ads’ customers such as publishers, ad networks, and ad agencies including for interest-based advertising as described above. In particular, Bluewater Ads is responsible under the Privacy Shield Principles if third-party controllers to whom it transfers information or third-party agents it engages to process this information on its behalf do so in a manner inconsistent with the Privacy Shield Principles.

In cases of onward transfer to third parties of data of EEA or Swiss individuals received pursuant to the EU-US Privacy Shield or the Swiss-US Privacy Shield, respectively, Bluewater Ads is potentially responsible.

EEA and Swiss individuals have the right to access the personal information that Bluewater Ads maintains about you, as that term is defined in the Privacy Shield Framework, and you may be able to correct or amend that information if it is inaccurate or has been processed in violation of the Privacy Shield Principles, to the extent allowed by law. To exercise this right, please email privacy@bluewaterads.com.

Bluewater Ads commits to resolve complaints about our collection or use of your personal information. EEA or Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact Bluewater Ads at:


Bluewater Ads
Attention: Legal Department
2030 Main Street, Suite 440
Irvine, CA 92614

Bluewater Ads has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles and the Swiss-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

A binding arbitration option may also be made available to you in order to address Privacy Shield complaints not resolved by any other means.

Bluewater Ads is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

Retention of personal information of EEA individuals will be handled in accordance with Bluewater Ads’ data retention policy. Where Bluewater Ads processes personal data of EEA individuals as a data controller, such individuals: (i) may have the right to request access to and rectification or erasure of personal information; (ii) may restrict the processing of personal information, object to processing, and/or exercise the right of data portability; and (iii) may have certain rights to withdraw consent without affecting the lawfulness of processing and the right to lodge a complaint with a supervisory authority. For any requests or information regarding the rights set out above, please contact us by emailing us at dpo@bluewaterads.com.


Information that we collect is stored using procedures and practices reasonably designed to help protect information from unauthorized access, destruction, use, modification, or disclosure.

Contact Us

If you have any questions or concerns regarding this Bluewater Ads Privacy Policy, please contact us by emailing us at dpo@bluewaterads.com.

Additional Information for EEA Individuals

For EEA individuals, the data controller in respect of your personal information is Bluewater Ads.

As set out above, Publishers may use the Services to process data that they collect for their own purposes. In this respect we act as data processor for the Publisher, which may have its own Privacy Policy, which explains how it uses personal information.

Policy Updates

This Statement is effective as of the date set forth above. We encourage you to check this Statement from time to time. We will post changes to this Statement here. If, however, we intend to use personal data in a manner different from that stated at the time of collection we will notify visitors by posting a notice on our Web sites for thirty (30) days in advance of such use and we will give you the opportunity to opt out. Your continued use of our Web sites and the Services constitutes your acceptance of the current posted Statement.