JettyLight LLC & Ops Normal AI Privacy Policy

Effective Date: August 10, 2026
Last Updated: October 9, 2026

§1 Introduction / Scope

This Privacy Policy covers two sister entities and their respective services:

JettyLight LLC ("JettyLight") operates maritime transportation services, including:

• Oxford Bellevue Ferry (OXBF) — oxfordferry.com
• Presque Isle Water Taxi (PIWT) — presqueislewatertaxi.com
• Heart of the Gorge Sailing (HOTGS) — heartofthegorgesailing.com
• Sternwheeler Columbia Gorge (SWCG) — sternwheeler.com
• RiverLink Ferry (DRWC) — riverlinkferry.com

Ops Normal AI ("Ops Normal") is a separate entity that provides the operational technology platform used by JettyLight and other operators, including:

• opsnormal.ai and its subdomains, Wheelhouse App, Management Portal, Point of Sale (POS), booking/reservation, boarding/check-in, tracking, communications, and related operational tools
• Ferry Godmother — ferrygodmother.app, including its mobile application and related membership features

Throughout this Policy, “we,” “us,” or “our” refers to JettyLight and Ops Normal collectively, unless a section specifies one entity.

This Privacy Policy applies across JettyLight operations, Ops Normal platform services, websites, mobile applications, on-site services (including ticketing, boarding, and reservations), and Ferry Godmother. It applies to customers, passengers, crew members, employees, Ferry Godmother app users and members, operators, and members of the public who interact with our systems, including through dock signage or phone calls.

By using our services, websites, apps, or platforms, or by working with JettyLight or Ops Normal, you agree to the practices described in this Policy.

§2 Information We Collect

(a) Customer / Passenger Data

When you book, purchase, check in for, or use a trip or service—online, at a dock ticket window, through a mobile application, or through manual reservation entry—we may collect:

• Name
• Email address
• Phone number, including optional enrichment after card payment
• Zip code, including billing zip code obtained from a card transaction
• Passenger count
• Fare category
• Add-ons, food or beverage selections, special requests, and other booking details
• Sales records, amounts, transaction types, and timestamps

(b) Payment Information

We retain payment-related information needed for receipt and support purposes, including card type (for example, Visa or Mastercard), the last four digits of the card, and billing zip code. We do not store full credit card numbers. Payment processing is further described in §4.

(c) Boarding & Pass Data

We collect and maintain boarding and pass information, which may include:

• QR codes and pass codes
• Boarding status, such as pending or boarded
• Scan timestamps
• Boarding leg, including outbound or return
• Boarding confirmations

(d) Booking / Reservation Data

We collect booking and reservation details, including travel dates and time selections, passenger counts, add-ons, special requests, and related reservation information.

(e) Crew / Employee Data

For crew and staff, we collect and maintain information such as:

• Name, email address, and phone number
• Employment records and active/deactivated employment status
• Payroll information and hourly rates
• Scheduling information, including assigned vessels, shift times, and crew slots
• Certifications, licensing records, credentials, and compliance information
• Text-message verification codes and related login records used for crew authentication
• Crew tip totals; crew members see amounts earned only and never the identity of a tipper

(f) Website / App Usage

We collect standard website analytics and may use cookies and browser localStorage for site and application functionality. We use Google Analytics to understand website and application use, which may involve collection of information such as device and browser details, approximate location derived from IP address, pages viewed, referring pages, interactions, and timestamps. We also use Cloudflare Turnstile to distinguish legitimate users from automated traffic and help prevent abuse. Turnstile may process technical information about a visitor’s browser, device, network, and interaction with the site. We also collect device and app usage data generated during normal use, such as login timestamps and session activity.

(g) SMS Communications

We collect phone numbers, SMS consent status, and message history to send booking confirmations, service alerts, schedule changes, weather cancellations, boarding notifications, safety alerts, and, with consent, promotional messages such as Free Friday communications.

(h) Vessel & Operational Data

To operate our services and maintain required records, we collect operational data, including:

• Departure and arrival timestamps, whether entered manually or detected through GPS, BLE beacons, or accelerometer-based detection
• Passenger counts per crossing
• Engine on/off events, including “Engine placed on-line” and “Engine placed off-line” events
• Vessel GPS position, heading, and speed, including information maintained in the vessel_positions table
• Crossing records, weather observations, vessel status, crossing counts, passenger counts, revenue totals, and daily logs

(i) GPS & Location Data

Wheelhouse App devices transmit GPS location data continuously while in use for vessel and operational tracking. Ferry Godmother may use a member’s location to provide “Leave Now” smart departure alerts and display live ferry position in the app. Ferry Godmother departure-alert calculations are processed on the user’s device; home and work locations are not transmitted to our servers. Vessel positions displayed in the app come from our operational tracking system, not from the user’s device.

Users may disable Location permission in device settings. If disabled, Ferry Godmother departure alerts are unavailable, while other app features continue to work.

(j) BLE Beacon Data

Our apps may detect BLE beacon signals, including UUID, major/minor identifiers, RSSI signal strength, and timestamps. The Wheelhouse App uses dock beacons for operational purposes. Ferry Godmother uses BLE detection, while the app is running and Bluetooth permission has been granted, to support automatic check-in, queue management, crossing verification, and related dock functions. Users may disable Bluetooth permission in device settings; if it is disabled, Ferry Godmother queue features require manual check-in.

(k) Call Data (Sentinel Queue)

When a person calls one of our operations’ phone lines, Sentinel Queue may collect the caller’s phone number, call duration, recording and transcription, inquiry type, and resolution status. Sentinel Queue is further described in §12.

(l) Vehicle Information (Ferry Godmother)

Ferry Godmother members may register vehicle details, including make, model, color, and license plate, for priority boarding.

(m) Mileage & Behavioral Data (Ferry Godmother)

Ferry Godmother tracks crossings to calculate nautical miles traveled, rank progression, badges, and streaks. Crossing history includes date, route, vessel, and nautical miles. Leaderboard participation is opt-in and uses only a member’s chosen display name, not their real name.

(n) Waitlist Data (Ferry Godmother)

For the Ferry Godmother membership waitlist, we collect name, email address, phone number, preferred dock, and zip code. Zip code is used for local-priority scoring, including preference for Talbot County residents.

(o) Call Flag (Dock Request)

The OXBF-specific Call Flag feature collects dock selection and a timestamp only; it does not collect personal information. A browser localStorage token enforces a five-minute cooldown for repeat prompts and contains no personal information.

§3 How We Use Information

We use information collected under this Policy to:

• Fulfill bookings, reservations, payments, boarding, manifests, and other service operations
• Issue boarding passes and process check-in
• Send confirmations, schedule changes, weather cancellations, boarding notifications, service alerts, and safety alerts
• Provide customer service through live staff and our AI-powered phone system
• Schedule and manage crew, track certifications, and coordinate payroll
• Support operational reporting, internal recordkeeping, dispatch, fleet monitoring, and revenue reporting
• Meet safety and regulatory obligations, including U.S. Coast Guard (USCG) reporting, crossing logs, and passenger-count requirements
• Improve our websites, apps, services, systems, troubleshooting, performance monitoring, and features
• Support grant reporting using only anonymized or aggregated ridership data; individual passenger identities are not disclosed in grant reports
• Deliver Ferry Godmother queue, check-in, crossing, mileage, and notification features

We do not use passenger or crew data for purposes unrelated to operating and improving the platform and services, except as described in this Policy or with consent.

§4 Payment Processing

Payments are processed through PayArc, Stripe (including Stripe Terminal and M2 card readers), and NMI (Network Merchants, Inc.). These processors are PCI-DSS compliant. JettyLight does not store, process, or transmit full credit card numbers on its own servers; card data entered at checkout is transmitted directly and securely to the applicable payment processor. Those processors are independently responsible for safeguarding the card data they handle under their PCI-DSS obligations. We retain only card type, last four digits, and billing zip code for receipt and support purposes.

§5 Data Sharing

We do not sell personal data and do not share personal data for third-party advertising purposes. We share information only as needed to operate our services and platforms or comply with law, including with:

• Payment processors PayArc, Stripe, and NMI, to process transactions and tips
• Twilio, to deliver SMS/text messages, including booking and service communications and one-time crew sign-in codes
• Google Analytics, to measure and understand website and application use
• Cloudflare Turnstile, to detect automated traffic and prevent abuse
• Microsoft Azure Bot Service, to provide automated conversational and customer-support features
• AI service VAPI, for Sentinel Queue voice call handling
• Cloud infrastructure providers Supabase, Render, Cloudflare, and Microsoft Azure, for database, hosting, CDN, DNS, security, and application services
• Apple Push Notification Service and Google Firebase Cloud Messaging, to deliver mobile push notifications
• Gusto, for crew payroll processing
• Grant funders, solely in anonymized or aggregated form, such as Erie Community Foundation
• U.S. Coast Guard and other regulatory authorities, when required for safety and regulatory compliance
• Law enforcement, when legally required, such as in response to a subpoena, court order, or other legal process

The third-party services used across our platforms are listed in §14.

§6 Data Retention

We retain data according to the following schedule, or as otherwise required by applicable law:

When data is no longer needed for these purposes, we take reasonable steps to delete or anonymize it. Ferry Godmother queue data is transient and is not retained after a crossing. Ferry Godmother waitlist data is retained until the person is invited and accepts or declines, or requests removal. Transaction records, including payments and tips, remain subject to the transaction-record retention period even if a Ferry Godmother account is deleted.

§7 Children’s Privacy (COPPA)

JettyLight sells youth and child fare tickets as part of its normal ferry, water taxi, and sailing operations. We do not knowingly collect personal information directly from children under 13 without parental or guardian consent. Child and youth tickets are purchased and managed by an adult guardian, and we do not independently collect a child’s name or personal information as part of that transaction.

If we learn that a child has provided personal information without parental involvement, we will take steps to delete it.

§8 Security

We use industry-standard safeguards to protect information across our operations and platforms, including:

• SSL/TLS encryption for data in transit
• Encryption of data at rest
• Supabase row-level security (RLS) to enforce database access boundaries
• PCI-compliant payment processing through PayArc, Stripe, and NMI
• Role-based access controls (RBAC), including Management Portal access limited to authorized operations
• Text-message verification codes for crew sign-in to the Wheelhouse App and other tools
• Cloudflare Turnstile and related controls designed to detect automated traffic and prevent abuse
• Staff access limited to the information needed for their role

No system is completely secure, but we continually work to protect the information entrusted to us.

§9 Ops Normal Platform Supplement

Ops Normal includes the main platform at opsnormal.ai and its subdomains, including vessel-specific Wheelhouse App subdomains; the Wheelhouse App used by captains and crew; the Management Portal at manage.opsnormal.ai; POS systems on vessels and at docks; booking/reservation pages; boarding and check-in tools; GPS and vessel tracking; BLE dock-beacon detection; Sentinel Queue; SMS/text communications; and related crew scheduling, payroll integration, operational reporting, and grant-reporting tools.

The platform currently supports OXBF, PIWT, HOTGS, SWCG, and DRWC. The following provisions clarify Ops Normal features:

• Wheelhouse App and operational detection: The Wheelhouse App supports captains and crew and may generate GPS, BLE, accelerometer, vessel, crossing, engine-event, and device/app-use data while in operation.
• Management Portal and POS: Authorized managers use the Management Portal for their authorized operations. POS and booking/check-in tools support sales, reservations, passenger manifests, and boarding records.
• GPS vessel tracking and BLE dock beacons: Operational devices may continuously transmit GPS while in use. Dock beacons may detect BLE signal identifiers, RSSI, and timestamps to support operational detection and logging.
• Crew scheduling and payroll: Ops Normal supports crew schedules, vessel and shift assignments, crew slots, certifications, and payroll coordination. Payroll and wage data are processed by Gusto and are not stored within Ops Normal. Gusto’s handling of payroll data is governed by Gusto’s own privacy policy.
• Sentinel Queue: Sentinel Queue is the AI-powered phone handling system for operations phone lines. It may collect the call data described in §2(k), and is subject to the disclosure in §12.
• Crew tipping: Crew members can see total tip amounts earned, but the identity of a tipper is never shared with crew.
• Crew text-code authentication: Crew sign in to the Wheelhouse App and other tools using a verification code sent by text message. Twilio processes the destination phone number and message-delivery information needed to send the code. The code is used for authentication.
• Deactivated crew records: Deactivated crew records are retained only as long as required by applicable legal, tax, and labor recordkeeping requirements, then securely deleted.
• Call Flag: The OXBF Call Flag system records dock selection and timestamp only, uses a no-PII localStorage cooldown token, and is described in §2(o).

§10 Ferry Godmother App Supplement

Ferry Godmother is an Ops Normal product — a consumer mobile application and related membership service. The following provisions apply specifically to Ferry Godmother features:

• BLE queue and check-in: The app detects dock BLE beacons in two zones—Approach, at the parking/entrance area, and Landing, at the boarding ramp. This supports boarding-queue position, deckhand arrival notification, crossing verification for mileage tracking, and wait-time measurement. Bluetooth detection occurs only while the app is running and Bluetooth permission is granted.
• GPS and “Leave Now” alerts: Location supports “Leave Now” smart departure alerts based on estimated time of arrival to the dock and displays live ferry position on the in-app map. Alert calculations occur on the device, and home or work locations are never transmitted to our servers. Users can disable Location permission; departure alerts will then be unavailable, while other app features remain available.
• Mileage, ranks, badges, and streaks: The app records crossing history—date, route, vessel, and nautical miles—to calculate mileage, rank progression, badges, and streaks. Leaderboards are opt-in and display only a chosen display name. Members may request deletion of mileage history.
• Vehicle registration: Members may add or remove vehicle make, model, color, and license plate information for priority boarding. Vehicle data is visible to the deckhand during boarding only.
• Household members: Primary members may add household or subordinate memberships, manage household-member profiles, and share household mileage in a family pool. Household members may also maintain individual statistics.
• Queue and boarding data: While a member is in the boarding queue, queue position, zone status, and vehicle information are visible to the deckhand on an operations tablet. Queue data is transient and not retained after the crossing. Boarding confirmations, including timestamp and pass code, are retained as part of crossing history.
• Crew tipping: Tips are processed through Stripe and are anonymous: crew members see the tip amount, not the tipper’s identity. A member’s own tip history is visible only to that member in their profile.
• Waitlist: The membership waitlist collects name, email, phone, preferred dock, and zip code. Zip code supports local-priority scoring, including preference for Talbot County residents. Waitlist data is retained until invitation acceptance or decline, or removal on request.
• Push notifications: We send push notifications for boarding-queue signals, departure alerts, crossing completion, service alerts, and mileage milestones. Device tokens are stored securely and used solely to deliver Ferry Godmother notifications. Users can disable push notifications in device settings.
• Data portability: Members can export complete crossing history and mileage data from the Profile screen.
• Account deletion: Members can delete their Ferry Godmother account from the Profile screen. Account deletion removes the membership, crossing history, mileage data, and vehicle data. Transaction records for payments and tips are retained as described in §6.

Bluetooth and Location permissions are requested at first use with a clear explanation of why they are needed. The app remains functional with reduced features if either permission is denied.

§11 SMS / Text Message Policy (TCPA Compliance)

JettyLight and Ops Normal send text messages through Twilio for booking confirmations, weather cancellation notices, schedule changes, boarding notifications, Free Friday promotional messages, safety alerts, one-time crew sign-in codes, and other service communications.

• Transactional messages: Booking confirmations, schedule changes, weather cancellations, boarding notifications, and one-time crew sign-in codes are sent as part of the applicable service or account-security process.
• Promotional messages: Promotional messages, including Free Friday communications, are sent only after explicit opt-in, typically at booking or program sign-up.
• Opt-out: Reply STOP at any time to cancel text messages where that command is supported. Opting out may prevent receipt of text-based sign-in codes and access to tools that require them.
• Help: Reply HELP for assistance.
• Frequency and charges: Message frequency varies based on bookings, program participation, authentication activity, and interactions. Message and data rates may apply under the recipient’s mobile plan.
• Use of phone numbers: Phone numbers used for SMS are stored with consent and used solely for the purposes described in this Policy unless the recipient separately agrees to additional uses. We do not sell phone numbers to third parties.

§12 AI-Powered Phone Handling

Calls to our operations’ phone lines may be answered by Sentinel Queue, an AI voice assistant powered by VAPI, rather than a live person. Calls handled by Sentinel Queue may be recorded and transcribed for customer service, quality assurance, training, and contractor invoicing purposes. Call recordings are retained as described in §6.

A caller may be transferred to a live staff member at any point, and Sentinel Queue is designed to facilitate a warm transfer when needed.

§13 Your Rights & Contact

Depending on where you live, you may have rights regarding personal information, including the right to:

• Request access to the personal data we hold about you
• Request deletion of personal data, subject to the legal, regulatory, operational, and retention requirements described in this Policy
• Opt out of SMS messages by replying STOP or contacting us directly
• Export Ferry Godmother crossing history and mileage data from the app

California residents have the right to know what personal information we collect, request deletion, opt out of the sale of personal information, and not be discriminated against for exercising these rights. JettyLight does not sell personal information.

To exercise these rights or ask questions about this Policy, contact:

JettyLight LLC
Attn: Privacy — Captain Jim Andrews, President
Email: jim@jettylight.com
Phone: (855) 766-3682

§14 Third-Party Services

JettyLight uses the following third-party services across its operations and platforms:

Each provider maintains its own privacy practices governing the data it processes on our behalf.

§15 Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. Changes will be posted at jettylight.com/privacy-policy with an updated effective date and Last Updated date. Material changes may be communicated through the applicable platform or by email/SMS where appropriate. Continued use of JettyLight services after changes take effect constitutes acceptance of the updated Policy.