Privacy Policy

This Privacy Policy explains how Clearwell Resources LLC, an Arizona limited liability company doing business as Headgate ("Headgate," "we," "us," or "our"), collects, uses, and shares information in connection with the website at headgatewater.com and any related subdomains, pages, forms, and tools (the "Site"), including the eligibility-check feature and the lead-capture form.

This Policy is incorporated into our Terms of Service. By using the Site or submitting information to us, you agree to this Policy.

a. Information you give us. When you use the lead form or request an eligibility check, you provide your name and the county where the water right is located; your phone number (required) and email address (optional); information about the water right, such as the owner name on the document, the certificate or file number (often beginning with "58-"), and the amount in acre-feet; and, if you are unsure what you own, the names you ask us to search, your relationship to each named person, the rough location, and how the right came to be held. A phone number is required to submit the lead form; everything else is optional and helps us respond.

b. Information captured as you type. For operational reasons, information you enter into a form field may be captured when you move to the next field, even if you do not press a final submit button. If you do not want us to receive your information, do not enter it.

c. Information from public and third-party records. To check eligibility and to confirm ownership, we look up publicly available records, including the Arizona Department of Water Resources ("ADWR") public groundwater-rights records and county-assessor records, and we may use third-party data-enrichment and skip-trace services to locate or verify a mailing address or holder. Access to public records is governed by the Arizona Public Records Law (A.R.S. § 39-121 et seq.).

d. Information collected automatically. When you visit the Site, we and our service providers may collect device and usage information such as IP address, browser type, pages viewed, and referring page, through cookies, pixels, and similar technologies, including a site-wide advertising pixel used for retargeting and analytics. See Section 6.

We use the information we collect to:

• Respond to your inquiry, contact you, and discuss a potential transaction.
• Perform the eligibility check and look up records on your behalf.
• Evaluate, prepare, and make a no-obligation offer, and, if you accept, complete the purchase, including ADWR filings, title, and escrow.
• Operate, maintain, secure, and improve the Site.
• Advertise our services, including retargeting visitors who did not complete the form.
• Comply with law and enforce our Terms.

We do not make automated decisions that produce legal or similarly significant effects about you without human involvement; offers are prepared and delivered by a person.

By submitting your phone number and/or email, you authorize us and persons acting on our behalf to contact you about your inquiry and a potential transaction by phone call, email, and, if you provide a mobile number, text message (SMS). Message and data rates may apply, message frequency varies, and you may opt out of text messages at any time by replying STOP. You may ask us to stop calling or emailing you at any time by contacting us at the address in Section 11. Your consent to be contacted is not a condition of any purchase or of using the eligibility check.

We may record or monitor calls for quality, training, and recordkeeping purposes.

We do not sell your personal information. We share it only as follows:

• Service providers who work on our behalf, such as hosting, communications, call handling, analytics, advertising, and data-enrichment or skip-trace vendors, under obligations to protect it.
• Transaction partners needed to complete a purchase you accept, such as title and escrow companies and ADWR in connection with a change-of-ownership filing.
• Professional advisors, such as our attorneys and accountants.
• Legal and safety, when required by law, subpoena, or government request, or to protect our rights, property, or safety or that of others.
• Business transfers, in connection with a merger, financing, acquisition, or sale of assets, in which case information may be transferred as a business asset.

We use cookies, pixels, and similar technologies to operate the Site, measure usage, and serve advertising, including retargeting visitors across other sites and platforms. Retargeting runs off a site-wide pixel and is not tied to the name you submit. You can usually control cookies through your browser settings, and you can opt out of certain interest-based advertising through industry tools such as the Digital Advertising Alliance (optout.aboutads.info) and the Network Advertising Initiative (optout.networkadvertising.org). The Site does not respond to "Do Not Track" signals.

We retain personal information for as long as we have a business or legal reason to keep it. This includes responding to your inquiry, evaluating and completing a potential transaction, pursuing future transactions, maintaining business and transaction records, exercising or defending legal claims, and complying with our legal obligations.

Unless a longer period is required or permitted by law, we retain inquiry and communication records for up to seven (7) years after our last contact with you, and we retain records relating to a completed transaction for at least the longer of seven (7) years or the period required by applicable law. We may retain de-identified or aggregated information, which no longer identifies you, indefinitely.

We use reasonable administrative, technical, and physical safeguards designed to protect information. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

This Policy is governed by the laws of the State of Arizona. Arizona does not currently have a comprehensive consumer-privacy statute granting general rights of access, correction, or deletion, so this Policy follows applicable Arizona law, including the Arizona data-breach notification law (A.R.S. § 18-552).

You may still contact us at the address in Section 11 to ask a question about your information, request a copy or correction, ask that we stop contacting you, or ask that we delete information we are not required to keep. We will verify and respond to reasonable requests, and we will not deny you service for making one. We do not sell your personal information.

The Site is intended for adults and is not directed to children under 18. We do not knowingly collect personal information from children. If you believe a child has provided us information, contact us and we will delete it.

To ask a question or exercise a privacy right, contact:

We may update this Policy from time to time. The "Last updated" date above reflects the current version, and material changes will be posted on the Site. Your continued use of the Site after changes take effect constitutes acceptance.