Sail Technologies LLC Privacy Policy

Effective Date: January 1, 2024

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 1. Introduction

Welcome to Sail Technologies LLC ("Sail," "we," "us," or "our"). We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or use our services.

This policy applies where we are acting as a data controller with respect to your personal data; in other words, where we determine the purposes and means of the processing of that personal data.

By using our website or services, you agree to the terms of this Privacy Policy. If you do not agree with the practices described in this policy, please do not use our website or services.

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 2. Information We Collect

 2.1 Personal Information

We may collect the following types of personal information:

- Name

- Email address

- Phone number

- Postal address

- IP address

- Device identifiers

- Browser type and version

- Operating system

- Referring website

- Pages viewed on our website

- Time spent on pages

- Click data

We collect this information when you:

- Fill out forms on our website

- Communicate with us directly

- Use our services

- Visit our website (through cookies and similar technologies)

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 2.2 Non-Personal Information

We also collect non-personal information that does not directly identify you. This may include:

- Aggregated usage statistics

- Demographic information

- Browsing and search history

- Device information

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 3. How We Collect Information

 3.1 Direct Collection

We collect information directly from you when you provide it to us voluntarily, such as when you fill out forms on our website or communicate with us.

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 3.2 Automated Collection

We use cookies, web beacons, pixels, and other tracking technologies to automatically collect information about your interactions with our website and services. For more information about our use of these technologies, please see our Cookie Policy.

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 3.3 Information from Clients

We may receive personal information about you from our clients (such as hotels) when they provide us with their customer relationship management (CRM) data.

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 3.4 Information from Third Parties

We may obtain information about you from other sources, such as data partners, public databases, and social media platforms.

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 4. How We Use Your Information

We use the information we collect for the following purposes:

1. To provide and improve our services

2. To create and optimize traveler profiles

3. To personalize your experience

4. To communicate with you

5. To conduct analytics and develop insights

6. To comply with legal obligations

7. To detect and prevent fraud

8. To send you marketing communications (with your consent where required by law)

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 4.1 Traveler Profile Creation

One of our primary services involves using website traffic data from our clients (mostly hotels) to create traveler profiles. We use both anonymous data from user activity and sometimes non-anonymous data provided by our clients (such as CRM data) to create accurate traveler profiles. These profiles help us bring more similar travelers to our clients' websites.

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 4.2 Automated Decision-Making and Profiling

We may use automated decision-making and profiling techniques to analyze your information, predict your preferences, and create traveler profiles. This helps us provide more personalized services and targeted marketing. You have the right to object to this processing; please see the "Your Rights" section for more information.

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 5. How We Share Your Information

We may share your information with data partners, including service providers, business partners, advertising partners, and other third parties. These partners help us provide and improve our services, deliver targeted advertisements, and enhance our data sets. We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

We may also disclose your information if required by law or in connection with a business transfer.

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 6. Data Security

We have implemented appropriate technical and organizational measures to protect the personal information we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. However, please note that no method of transmission over the Internet or method of electronic storage is 100% secure.

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 7. Data Retention

We retain personal information we collect from you for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means, and the applicable legal requirements.

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 8. Your Rights

Depending on your location, you may have certain rights regarding your personal information. These may include:

- The right to access your personal information

- The right to correct inaccurate personal information

- The right to request deletion of your personal information

- The right to restrict processing of your personal information

- The right to data portability

- The right to object to processing of your personal information

- The right to withdraw consent (where processing is based on consent)

To exercise any of these rights, please contact us using the information provided in the "Contact Us" section below. We may need to verify your identity before responding to your request.

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 8.1 Opting Out

You may opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or by contacting us directly. Please note that even if you opt-out of receiving marketing communications, we may still send you non-marketing communications (e.g., about your account or our ongoing business relations).

You may also opt-out of our use of your information for targeted advertising purposes by visiting https://sailtech.ai/optout.

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 9. Children's Privacy

Our services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will promptly delete that information. If you believe we might have any information from or about a child under 13, please contact us using the information provided in the "Contact Us" section below.

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 10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

You can see when this Privacy Policy was last updated by checking the "Effective Date" displayed at the top of this Privacy Policy.

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 11. California Residents

If you are a California resident, you have specific rights regarding your personal information under the California Consumer Privacy Act (CCPA). This section provides information about those rights and how to exercise them.

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11.1 Your Rights Under the CCPA

As a California resident, you have the right to:

1. Know what personal information we collect about you and how we use and disclose that information

2. Request deletion of your personal information (subject to certain exceptions)

3. Opt-out of the sale of your personal information

4. Non-discrimination for exercising your CCPA rights

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 11.2 Categories of Personal Information We Collect

In the past 12 months, we have collected the following categories of personal information:

- Identifiers (e.g., name, email address, IP address)

- Personal information categories listed in the California Customer Records statute

- Commercial information

- Internet or other electronic network activity information

- Geolocation data

- Professional or employment-related information

- Inferences drawn from other personal information

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 11.3 How We Use and Disclose Your Personal Information

We use and disclose the personal information we collect for the business and commercial purposes described in the "How We Use Your Information" and "How We Share Your Information" sections of this Privacy Policy.

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 11.4 Sale of Personal Information

California law requires that we provide transparency about personal information we "sell," which for the purposes of the CCPA, means scenarios in which we have shared personal information with partners in exchange for valuable consideration. We do not sell your personal information for monetary compensation. However, we may "sell" your personal information as defined by the CCPA when we share it with our advertising partners to provide you with targeted advertising.

You have the right to opt-out of the sale of your personal information. To exercise this right, please visit our "Do Not Sell My Personal Information" page at https://sailtech.ai/optout.

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 11.5 Exercising Your CCPA Rights

To exercise your CCPA rights, please submit a verifiable consumer request to us by:

- Emailing us at hi@sailtech.ai

- Visiting 38 East 32nd Street, New York, NY 10016

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 11.6 Verification Process

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

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 12. GDPR Compliance

While our email resolver tool operates only on traffic from the United States, we recognize that we may process personal data of individuals in the European Economic Area (EEA) through our website and other services. This section provides additional information for individuals protected by the General Data Protection Regulation (GDPR).

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 12.1 Legal Basis for Processing

We process personal data on the following legal bases:

- Consent: We may process your personal data based on your consent, such as for sending marketing communications.

- Contract: We may process your personal data to fulfill our contractual obligations to you.

- Legitimate Interests: We may process your personal data based on our legitimate interests, such as to improve our services and for fraud prevention.

- Legal Obligation: We may process your personal data to comply with applicable laws and regulations.

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 12.2 International Transfers

If we transfer your personal data outside the EEA, we will ensure that appropriate safeguards are in place to protect your personal data, such as Standard Contractual Clauses approved by the European Commission.

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 12.3 Additional Rights Under GDPR

In addition to the rights outlined in the "Your Rights" section, individuals in the EEA have the following rights:

- Right to lodge a complaint with a supervisory authority

- Right to object to processing based on legitimate interests

- Right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you

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 12.4 Data Protection Officer

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact our DPO using the details provided in the "Contact Us" section below.

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 13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Sail Technologies LLC

38 East 32nd Street

New York, NY 10016

Email: hi@sailtech.ai

By using our website and services, you acknowledge that you have read and understood this Privacy Policy and agree to be bound by its terms.