Privacy policy

USER PRIVACY NOTICE

For US Resident Privacy Rights click here

Effective Date: 09.03.2023

1. ABOUT THIS PRIVACY NOTICE
2. PERSONAL INFORMATION WE COLLECT
3. PURPOSE AND LEGAL BASIS OF THE PROCESSING
4. HOW LONG WE KEEP YOUR PERSONAL INFORMATION
5. HOW WE SHARE YOUR DATA
6. YOUR CHOICES AND RIGHTS
7. HOW WE PROTECT YOUR DATA
8. PERSONAL DATA PROTECTION AUTHORITY
9. HOW TO CONTACT US
10. CHANGES TO THIS PRIVACY NOTICE

ABOUT THIS PRIVACY NOTICE

SUERA LLC, registered in Delaware, US under the registration Nr. 5948896 (referred to as "We", "Us" or "Our") is the data controller. This Policy explains how We process and put you in control of your Personal Information. "Personal Information" or "Personal data" means any information that allows someone to identify, or reasonably link to, you directly or indirectly. When we describe "processing" of Personal Information, we mean how we collect, use, share, and retain Personal Information.

This Privacy Notice covers the following services:

- Sail.me Boat Rentals - Sail.me Boat Rentals is our service that connects Boat Owners and Renters on our iOs, Android or Web App, including the payment processing from the Renters to the Boat Owners. (the "Service"). The Service is accessible as iOS, Android, Web application (available at https://sailme.com)

PERSONAL INFORMATION WE COLLECT

We process the personal data of the following data subject categories:

Boat Owners and Agencies	Boat Owners and Agencies are all natural persons or representatives of legal entities who are using the Services provided by the Company to rent boats, yachts, and other water vehicles to the Renters
Email Newsletter Subscribers	Email Subscribers are natural persons who have signed up to receive our email newsletter.
Renters	Renters are all natural persons or representatives of legal entities who are using the Services provided by the Company to rent boats, yachts, etc. from the Boat Owners and Agencies
Website Visitors	Website Visitors are all visitors of https://sailme.com (the "Website") of the Company.

We process the following categories of personal data:

Category	Description	Collection	Notes
Analytical data	anonymized IP address, website sessions, duration of sessions, visited links etc. We process analytical data about the user experience on our Website and while using our Service We collect analytical information only after receiving your consent. You can opt-out at any time.	- Automatically collected data
Chat data	The personal data includes any information exchanged between the Users of the Service. The personal data is processed with the purpose of providing the Users with chat functionalities.	- Directly from the Data Subject
Data collected for marketing purposes	personal data includes your behavior on our website and app and unique identifier that helps our marketing service providers identify you and serve you relevant ads We process personal data to promote our services to people who may be interested in using them You can opt-out of the processing of this personal information at any time.	- Automatically collected data
Email subscription data	email and name We process email subscription data to be able do deliver our email newsletter to you. You can opt-out from receiving our email newsletter at any time using the "unsubscribe" link at the end of any email or by contacting us.	- Directly from the Data Subject
Identification data	names, email, birth date and username, The purpose of the data processing is to identify the data subject and determine whether he or she is of age to use our Services	- Directly from the Data Subject
Payment information	amount paid, date of payment, purchased services or goods The data is processed with the purpose to track payments done by the data subject.	- Data received from a 3rd party	- Payment Service Providers
Profile Information	personal information includes date of birth, profile description, photos, gender, etc. We process profile information data to provide our services and ensure the best user experience.	- Directly from the Data Subject

PURPOSE AND LEGAL BASIS OF THE PROCESSING

We process your personal data for the following purposes:

Purpose	Legal basis	Collected data category
We process personal data to analyze the usage of our website and app and improve our services.	- consent	- Analytical data
We process personal data to be able to deliver our email newsletter.	- consent	- Email subscription data
We process personal data to be able to serve the data subjects with relevant ads and promote our services.	- consent	- Data collected for marketing purposes
We are processing personal data to perform our legal accounting obligations.	- legal obligation	- Payment information
We process personal information to provide our Service.	- performance of a contract	- Chat data - Identification data - Payment information - Profile Information - Rental information

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We keep your personal data only as long as necessary to achieve the purpose it is processed for. Full list of the purposes for which we process personal data can be found above.

We determine the appropriate retention period for personal information on the basis of the amount, nature and sensitivity of your personal information processed, the potential risk of harm from unauthorized use or disclosure of your personal information and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation).

Here are some of the categories of our retention periods:

Automatic expiration after a period of time	We have set certain retention periods so that some data expires after a specific period of time.
Data Backups	We back up data for security reasons. Sometimes it is impossible to delete the data stored in a backup immediately. In such cases, we will securely store your personal information and isolate it from any further processing until deletion is possible.
Deletion of the data by the data subject	data subjects can delete the data by themselves. In this case, the data is retained for a short period of time after the deletion so the data subject could be able to revert a deletion by mistake. can request data erasure under Art. 17 GDPR. For more information please refer to the Data subject rights section.
Manual deletion of the data after period of time or at request	We delete the personal data manually after a certain period of time or at a request from the data subject
Profile deletion	the data subject can delete their profile and all associated with it personal data
Retention or deletion under a legal or contractual obligation	We may be subject to a legal or contractual obligation to keep or delete the data. Examples include mandatory data retention laws, government orders to preserve data relevant to an investigation or data kept for the purposes of litigation. Conversely, we will remove unlawful content if the law requires us to do so.

After expiration of the applicable retention periods, we will either delete or anonymize your personal information

HOW WE SHARE YOUR DATA

We share personal data with the following 3rd parties:

Accounting Service Providers	We may share personal data with accounting service providers who help us maintain our accounting and comply with all applicable laws.	- Payment information
Analytics service providers	We may use analytics service providers such as Google or Facebook to analyse your behavior on our website or while using our services	- Analytical data
Chat Service Providers	We may share personal data to be able to provide the chat functionalities of our Services to 3rd parties providing such chat services.	- Chat data
Customer support service providers	We may share personal data with companies providing client support services.	- Identification data - Payment information - Profile Information - Rental information
Email marketing service providers	We may use email marketing service providers to deliver our email newsletter	- Identification data
Government institutions	We may share perosnal data with government institutions to perform our legal obligations such as accounting.	- Payment information
Infrastructure and cloud service providers	We may share personal data with infrastructure and cloud service providers to be able to provide our Services.	- Chat data - Identification data - Profile Information - Rental information

We share personal data internationally with subcontractors and partners when carrying out the activities described in this Policy. They may process your data in countries whose data protection laws are not considered to be as strong as EU laws or the laws which apply where you live. For example, they may not give you the same rights over your data.

Whenever we transfer personal data internationally, we use tools to:

- make sure the data transfer complies with applicable law

- help to give your data the same level of protection as it has in the EU

To ensure each data transfer complies with applicable EU legislation, we use the following legal mechanisms:

- Standard Contractual Clauses ('SCCs'). These clauses require the other party to protect your data and to provide you with EU-level rights and protections.

- Adequacy Decisions. This means that we transfer personal data to countries outside of the European Economic Area which have adequate laws to protect personal data, as determined by the European Commission. Such countries are United Kingdom, Canada, Japan, Republic of Korea and Switzerland.

We also identify and use additional protections as appropriate for each data transfer

YOUR CHOICES AND RIGHTS

Here are your rights as a data subject:

Right	Description	How to use it
Be informed	Be informed of the personal data we process about you and how we process it.	We inform you: ● through this Policy ● through information provided to you as you use our Service ● by answering your specific questions and requests when you contact us
Know/ Access	Request to know and access the personal data we process about you.	To request a copy of your personal data you can contact us.
Correction	Request that we amend or update your personal data where it’s inaccurate or incomplete.	You can edit your User Data by contacting us or by using your user profile
Deletion	Request that we delete certain of your personal data. For example, you can ask us to delete your personal data: ● that we no longer need for the purpose it was collected for ● that we process based on the legal basis of consent, and you withdraw your consent ● when you object (see section ‘Object’ below) and ● you make a justified objection, or ● you object to direct marketing There are situations where We are unable to delete your data, for example when: ● it’s still necessary to process the data for the purpose we collected it for ● Our interest in using the data overrides your interest in having it deleted. For example, where we need the data to protect our services from fraud ● We have a legal obligation to keep the data, or ● We need the data to establish, exercise or defend legal claims. For example, if there’s an unresolved issue relating to your account	To delete your personal data you can contact us. You can also see more details in the section "HOW LONG WE KEEP YOUR PERSONAL INFORMATION"
Restriction	Request that we stop processing all or some of your personal data. You can do this if: ● your personal data is inaccurate ● our processing is unlawful ● we do not need your information for a specific purpose, or ● you object to our processing and we are assessing your objection request. See section ‘Object’ below You can request that we stop this processing temporarily or permanently.	You can exercise your right to restriction by contacting us.
Object	Object to us processing your personal data. You can do this if: ● We are processing your personal data on the legal basis of legitimate interests, or ● We are processing your personal data for tailored advertising.	To exercise your right to object, you can contact us
Data portability	Request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service. You can request us to transmit your data when we are processing your personal data on the legal bases of consent or performance of a contract. However, We will try to honor any request to the extent possible.	For information about how to exercise the right to portability, see ‘Access’ above.
Not be subject to automated making	Not be subject to a decision based solely on automated decision making (decisions without human involvement), including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.	We don't perform automated decision making including profiling.
Withdrawal of consent	Withdraw your consent to us collecting or using your personal data. You can do this if We are processing your personal data on the legal basis of consent.	To withdraw your consent, you can: ● adjust the relevant control ● contact us
Lodge a complaint with a supervisory authority	You have the right to lodge a complaint with a supervisory authority if you believe any of your rights have been violated	See the contact details of the data protection authorities here.

HOW WE PROTECT YOUR DATA

We take the privacy and security of your Personal Information, including information considered sensitive, seriously. Our cybersecurity team actively works to maintain the integrity, confidentiality and availability of our Services and our policies and protocols are focused on protecting your Personal Information. We consistently strive to improve our defenses in the ongoing battle against threat actors. That said, no method of transmission over the Internet, or method of electronic storage, is fully secure, and We cannot guarantee the security of your Personal Information. Our security, safety, and privacy features are provided on an "as-is" basis. As such, their effectiveness and error-free operation cannot be guaranteed, and we cannot ensure absolute confidentiality, anonymity, or personal safety.

In the event that we are required by law to inform you of any unauthorized access to your Personal Information, we may notify you electronically or in writing in accordance with applicable law.

PERSONAL DATA PROTECTION AUTHORITY

Authority: Commission for Personal Data Protection

phone number: 00359 2 915 3580

email: [email protected]

address: 2, Prof. Tsvetan Lazarov blvd. Sofia 1592, Bulgaria

Website: http://www.cpdp.bg/

You can find a full list of the Data Protection Authorities under GDPR here.

HOW TO CONTACT US

We welcome your comments, questions, or complaints regarding this Privacy Notice, our use of your Personal Information, or our response to your requests regarding your Personal Information. Please contact us using the following contact information:

Privacy Support Center

[email protected]

CHANGES TO THIS PRIVACY NOTICE

The latest version of the policy will govern our use of your Personal Information. We may revise this policy from time to time. If we determine, in our sole discretion, that the changes we make to this policy are material, we will notify you in advance.

YOUR US RESIDENT PRIVACY RIGHTS

Effective Date: 09.03.2023

Below we provide specific information for US residents and describe the specific rights afforded to them in accordance with the California Consumer Privacy Act of 2018 ("CCPA"), California Privacy Rights Act of 2020 ("CPRA") or other applicable regulations. Where available, we provide links to sections within our Privacy Policy where these rights and additional information may already be described. Key terms (e.g., "sold" and "shared" for cross-contextual behavioral advertising, or "disclosed" for a business purpose) throughout this section have the same meaning as defined by CCPA and CPRA.

Your Rights as a US Resident

1. You can request the following information about how we have collected and used your Personal Information during the past 12 months:

a. The categories of Personal Information we have collected (see Privacy Notice and information listed below).
b. The categories of sources from which we collected the Personal Information (see Privacy Notice)
c. The business or commercial purpose for collecting and/or selling (or sharing for cross-contextual behavioral advertising) Personal Information (see Privacy Notice and the information below)
d. The categories of third parties with whom we share the Personal Information (see Privacy Notice and information below)
e. The categories of Personal Information that we sold or shared for cross-contextual behavioral advertising (i.e., Ad / Marketing Partners) or disclosed for a business purpose (e.g., Service Providers and Other Partners) (see Legal Bases)
f. The categories of third parties to whom the Personal Information was sold or shared for cross-contextual behavioral advertising, or disclosed for a business purpose (see Privacy Notice and information below)

2. You can request a copy of the Personal Information that we have collected about you during the past 12 months (see Privacy Notice).

3. You can ask us to delete the Personal Information that we have collected from you (see Privacy Notice).

4. You can correct inaccurate Personal Information (see Privacy Notice).

5. You can easily opt-out of selling or sharing your Personal Information for cross-contextual behavioral advertising purposes with our Ad / Marketing Partners by sending us an email at [email protected]

6. You are entitled to exercise the rights described above free from discrimination.

Personal Information Collected, Sold, Shared, or Disclosed and Sources

You can find a full description of how we share personal information in our Privacy Notice, For convenience, here are the categories of information we have collected in the past twelve (12) months:

Category under the CCPA	Category as described in our Privacy Notice	Disclosed for Business Purpose, or Sold/Shared With
A. Identifiers and contact information, such as email, phone number, online identifiers (e.g., IDFA, GAID, IDFV) and IP address	- Email subscription data - Identification data	- Accounting Service Providers (disclosed for business purpose) - Email marketing service providers (shared) - Infrastructure and cloud service providers (disclosed for business purpose) - IT Service Providers (disclosed for business purpose)
B. California customer records (as defined in California Civil Code § 1798.80), such as contact details and communications we collect through our support channels and marketing activities	- Identification data - Profile Information	- Customer support service providers (disclosed for business purpose)
C. Characteristics of protected classifications under California or federal law (if you choose to provide them), such as age, gender identity, marital status, sexual orientation, race, and medical information (i.e., HIV status, and Last Tested Date, and vaccination status)	- Profile Information	- Infrastructure and cloud service providers (disclosed for business purpose)
D. Commercial information, such as information related to payment for services	- Payment information	- Accounting Service Providers (disclosed for business purpose) - Payment service providers (disclosed for business purpose)
E. Biometric information	Not Collected	Not shared or disclosed
F. Internet and other electronic network activity information (e.g., data collected through server logs and cookies and similar technologies)	- Analytical data - Data collected for marketing purposes	- Analytics service providers (shared) - Marketing and Ad Service Providers (shared)
G. Geolocation data, such as Distance Information and precise location	- Analytical data	- Analytics service providers (shared)
H. Audio, electronic, visual or similar information, such as photos, audio, and videos	- Profile Information	- Infrastructure and cloud service providers (disclosed for business purpose)
I. Professional or employment-related information	- Employee performance data - Payroll data	- Payroll service providers (disclosed for business purpose)
J. Education information as defined in the Family Educational Rights and Privacy Act	Not Collected	Not shared or disclosed
K. Inferences that we derive from the preceding information collected	Not Collected	Not shared or disclosed

No sale of personal information.

In the twelve months prior to the effective date of this Disclosure, We have not sold any personal information, as those terms are defined under the California Privacy Rights Act.

California Privacy Rights Act Retention Disclosure

We keep your personal information to enable your continued use of our Services, for as long as it is required in order to fulfill the relevant purposes described in our Privacy Notice, as permitted or as may be required by law, or as otherwise communicated to you.

California Privacy Rights Act Non-discrimination Statement.

We will not discriminate against any consumer for exercising their rights under the California Privacy Rights Act.

If you would like to request a copy of information regarding our disclosure to third parties for their direct marketing purposes in the preceding calendar year, or if you have questions about your California privacy rights, please contact us by email. You can see our contact details in our Privacy Notice.

Annual Reporting

Year	Type of request	Received	Completed
2022	Right to Know / Access	2	2