First Edition: January 21, 2019
Table of Contents:
- Information We Collect
- How We Use Information We Collect
- Sharing & Disclosure
- Other important information
- Your rights
- Operating Globally & International Transfers
- Contact Us
Thank you for using sail.me! Your trust is important to us and we’re committed to protecting the privacy and security of your personal information. The information that’s shared with us helps us to provide a great experience with sail.me. We have a dedicated privacy team that’s committed to protecting all the personal information we collect and help ensure that personal information is handled properly worldwide.
1.2 Data Controller
1.3 Applicability to Payments
Please see the Contact Us section below for contact details of the Data Controllers and Payments Data Controllers.
2. Information We Collect
There are three general categories of information we collect.
2.1 Information You Give to Us.
2.1.1 Information that is necessary for the use of the sail.me Platform.
We ask for and collect the following personal information about you when you use the sail.me Platform. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.
- Account Information. When you sign up for an sail.me Account, we require certain information such as your first name, last name, email address, and password.
- Profile and Listing Information. To use certain features of the sail.me Platform (such as booking or creating a Listing), we may ask you to provide additional information, which may include your address, phone number, and a profile picture.
- Identity Verification Information. To help create and maintain a trusted environment, we may collect identity verification information (such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other authentication information. To learn more, see our FAQ Section article about providing identification on sail.me.
- Payment Information. To use certain features of the sail.me Platform (such as booking or creating a Listing), we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments (via sail.me Payments).
- Communications with sail.me and other Users. When you communicate with sail.me or use the sail.me Platform to communicate with other Users, we collect information about your communication and any information you choose to provide.
2.1.2 Information you choose to give us.
You may choose to provide us with additional personal information in order to obtain a better user experience when using sail.me Platform. This additional information will be processed based on our legitimate interest or when applicable, your consent.
- Additional Profile Information. You may choose to provide additional information as part of your sail.me profile (such as gender, preferred language(s), city, and a personal description). Some of this information as indicated in your Account settings is part of your public profile page, and will be publicly visible to others.
- Other Information. You may otherwise choose to provide us information when you fill in a form, update or add information to your sail.me Account, respond to surveys, post to community forums, participate in promotions, communicate with our customer support team, share your experience with us (such as through Reviews), or use other features of the sail.me Platform.
2.1.3 Information that is necessary for the use of the Payment Services.
The Payments Data Controller needs to collect the following information necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations). Without it, you will not be able to use Payment Services:
- Payment Information. When you use the Payment Services, the Payments Data Controller requires certain financial information (like your bank account or credit card information) in order to process payments and comply with applicable law.
- Identity Verification and Other Information. If you are a Boat Owner, the Payments Data Controller may require identity verification information (such as images of your government issued ID, passport, national ID card, or driving license) or other authentication information, your date of birth, your address, email address, phone number and other information in order to verify your identity, provide the Payment Services to you, and to comply with applicable law.
2.1.4 Information We Automatically Collect from Your Use of the sail.me Platform and Payment Services.
When you use the sail.me Platform and the Payment Services, we automatically collect personal information about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the sail.me Platform and Payment Services.
- Geo-location Information. When you use certain features of the sail.me Platform, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. sail.me may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
- Usage Information. We collect information about your interactions with the sail.me Platform such as the pages or content you view, your searches for Listings, bookings you have made, and other actions on the sail.me Platform.
- Log Data and Device Information. We automatically collect log data and device information when you access and use the sail.me Platform, even if you have not created an sail.me Account or logged in. That information includes, among other things: details about how you’ve used the sail.me Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the sail.me Platform.
For example, we may use information we collect to better understand website traffic patterns and to optimize our website experience. In some cases we associate the information we collect using cookies and other technology with your personal information. Our business partners may also use these tracking technologies on the sail.me Platform or engage others to track your behavior on our behalf.
- Do Not Track Signals. While you may disable the usage of cookies through your browser settings, the sail.me Platform currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted.
- Payment Transaction Information. sail.me Payments collects information related to your payment transactions through the sail.me Platform, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details. This information is necessary for the adequate performance of the contract between you and sail.me Payments and to allow the provision of the Payment Services.
2.1.5 Information We Collect from Third Parties.
sail.me and sail.me Payments may collect information, including personal information, that others provide about you when they use the sail.me Platform and the Payment Services, or obtain information from other sources and combine that with information we collect through the sail.me Platform and the Payment Services. We do not control, supervise or respond for how the third parties providing your information process your Personal Information, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.
- Third Party Services. If you link, connect, or login to your sail.me Account with a third party service (e.g. Google, Facebook, Twitter, Instagram), the third party service may send us information such as your registration, friends list, and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
- Your Reviews. If someone has written a review for your listing, it will be published on your sail.me public profile page with your consent. To learn more, see our FAQ Section article about Reviews.
- Background Information. For Users in the United States, to the extent permitted by applicable laws, sail.me and sail.me Payments may obtain reports from public records of criminal convictions or sex offender registrations. For Users outside of the United States, to the extent permitted by applicable laws and with your consent where required, sail.me and sail.me Payments may obtain the local version of police, background or registered sex offender checks. We may use your information, including your full name and date of birth, to obtain such reports.
Referrals. If you are invited to sail.me, the person who invited you may submit personal information about you such as your email address or other contact information.
- Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or information to help detect fraud and safety issues, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the sail.me Platform through partnerships, or about your experiences and interactions from our partner ad networks.
2.2 Children’s Data.
Our websites and applications are not directed to children under 18 and we do not knowingly collect any personal information directly from children under 18. If you believe that we processing the personal information pertaining to a child inappropriately, we take this very seriously and urge you to contact us using the information provided under the "Contact Us" section below.
3. How We Use Information We Collect
We may use, store, and process personal information to (1) provide, understand, improve, and develop the sail.me Platform, (2) create and maintain a trusted and safer environment (such as to comply with our legal obligations and ensure compliance with sail.me Policies) and (3) provide, personalize, measure, and improve our advertising and marketing.
3.1 Provide, Improve, and Develop the sail.me Platform.
We may use the personal information to provide, improve, and develop the sail.me Platform such as to:
- enable you to access and use the sail.me Platform,
- enable you to communicate with other Users,
- operate, protect, improve, and optimize the sail.me Platform and experience, such as by performing analytics and conducting research,
- provide customer service,
- send you service or support messages, updates, security alerts, and account notifications,
- if you provide us with your contacts’ information, we may process this information: (i) to facilitate your referral invitations, (ii) send your requests for reviews, (iii) for fraud detection and prevention, and (iv) for any purpose you authorize at the time of collection,
- to operate, protect, improve, and optimize the sail.me Platform and experience, and personalize and customize your experience (such as making Listing suggestions, ranking search results), we conduct profiling based on your interactions with the sail.me Platform, your search and booking history, your profile information and preferences, and other content you submit to the sail.me Platform.
We process this personal information for these purposes given our legitimate interest in improving the sail.me Platform and our Users’ experience with it, and where it is necessary for the adequate performance of the contract with you.
3.2 Create and Maintain a Trusted and Safer Environment.
We may use the personal information to create and maintain a trusted and safer environment such as to:
- detect and prevent fraud, spam, abuse, security incidents, and other harmful activity,
- conduct security investigations and risk assessments,
- verify or authenticate information or identifications provided by you (such as to verify your Address or compare your identification photo to another photo you provide),
- conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required,
- comply with our legal obligations,
- Resolve any disputes with any of our Users and enforce our agreements with third parties,
- in connection with the activities above, we may conduct profiling based on your interactions with the sail.me Platform, your profile information and other content you submit to the sail.me Platform, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the sail.me Platform if such processes detect activity that we think poses a safety or other risk to the sail.me Platform, our community, or third parties. If you challenge the decisioning based on the automated process, please contact us as provided in the Contact Us section below.
We process this personal information for these purposes given our legitimate interest in protecting the sail.me Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.
3.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing.
We may use the personal information to provide, personalize, measure, and improve our advertising and marketing such as to:
- send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about sail.me or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Google),
- personalize, measure, and improve our advertising,
- Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by sail.me or its third party partners,
- conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the sail.me Platform, information obtained from third parties, and your search and booking history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you,
- enrolling in an email subscription will not affect the frequency of administrative emails that we may send in connection with any sail.me Account. No fee is charged for sending promotional emails to you, but third-party data rates may apply. Note that you may not be able to take advantage of certain promotions if you do not have an sail.me Account, and
- invite you to events and relevant opportunities.
We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest.
3.4 How the Payments Data Controller uses the Personal Information Collected.
We may use the personal information as a part of Payment services such as to:
- Enable you to access and use the Payment Services.
- Detect and prevent fraud, abuse, security incidents, and other harmful activity.
- Conduct security investigations and risk assessments.
- Conduct checks against databases and other information sources.
- Comply with legal obligations (such as anti-money laundering regulations).
- Enforce the Payment Terms and other payment policies.
- With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.
The Payments Data Controller processes this personal information given its legitimate interest in improving the Payment Services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.
3.5 SMS Terms.
sail.me will use reasonable commercial efforts to deliver the automated marketing text messages to the number you provide through compatible wireless carriers. Carriers and sail.me are not liable for delayed or undelivered messages. The short code we use for some Text Message Services may not be supported on all carriers.
By Opting In to a Text Message Service:
- You expressly authorize sail.me to use autodialer or non-autodialer technology to send text messages to the mobile phone number associated with your Opt-In (i.e., the number listed on the Opt-In form or instructions, or, if none, the number from which you send the Opt-In, or, if none, the number on file for your account). You also authorize sail.me to include marketing content in any such messages. You do not have to Opt In or agree to Opt In as a condition of purchase.
- You consent to the use of an electronic record to document your Opt-In. To withdraw that consent, request a free paper or email copy of the Opt-In, or to update our records with your contact information, please contact us via the methods described in the Contact Us section. To view and retain an electronic copy of these SMS Terms or the rest of your Opt-In, you will need (i) a device (such as a computer or mobile phone) with internet access, and (ii) either a printer or storage space on such device. If you withdraw your consent, certain features of our service may not be available to you. To update information on how we would contact you electronically, visit your Notification settings in your account settings.
- You confirm that you are the subscriber to the relevant phone number or that you are the customary user of that number on a family or business plan and that you are authorized to Opt In.
- You consent to the use of an electronic record to document your Opt-In. To withdraw that consent, update our records with your contact information, please visit your sail.me account Notifications settings or contact customer support.
- These SMS Terms still will apply if you withdraw the consent mentioned above or opt out of the Text Message Service.
After Opting In, in addition to the main messages the service offers, you may receive one or more welcome messages or administrative messages, such as (in some cases) a request to confirm your Opt-In.
About the Text Message Services and Opting Out
Message and data rates may apply. Unless otherwise noted, Text Message Services send multiple, recurring messages. sail.me may terminate any Text Message Service or your participation in it at any time with or without notice, including, for example, before you have received any or all messages that you otherwise would have received, but these SMS Terms still will apply. Text STOP to any promotional message to Opt Out or if applicable update your “Notification” settings on your sail.me account.
For additional help, text HELP in response to a marketing message or contact customer support.
3.6 Your Choices
You have choices on the promotional messages that you choose to receive.
- You can limit the information you provide to sail.me. Participation in promotions and marketing programs is voluntary.
- You can limit the communications that sail.me sends to you.
- To opt-out of marketing emails, simply click the link labeled “unsubscribe” at the bottom of any marketing email we send you or access the notification settings in your sail.me Account.
- To revoke permissions that you may have given to send promotional text messages, text STOP in response to any message.
- You can always update your notification settings within your sail.me Account by visiting the Notifications section of your sail.me Account. Please note that even if you opt-out of marketing communications, we may still need to contact you with important transactional information about your account. For example, even if you opt-out of emails, we may still send you activity confirmations or fraud alerts.
4. Sharing & Disclosure
4.1 Advertising and Social Media; Sharing with Your Consent.
Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your sail.me Account or when you participate in promotional activities conducted by sail.me partners or third parties.
Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the sail.me Platform. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest.
The social media platforms with which we may share your personal information are not controlled or supervised by sail.me. Therefore, any questions regarding how your social media platform service provider processes your personal information should be directed to such provider.
Please note that you may, at any time ask sail.me to cease processing your data for these direct marketing purposes by sending an e-mail to [email protected]
4.2 Sharing between Users.
To help facilitate bookings or other interactions between Users, we may need to share certain information, including personal information, with other Users, as it is necessary for the adequate performance of the contract between you and us, as follows:
- When you as a Renter submit a booking request, certain information about you is shared with the Boat Owner, including your profile, full name, the full name of any additional Renters, your cancellation history, and other information you agree to share. When your booking is confirmed, we will disclose additional information to assist with coordinating the trip, like your phone number.
- When you as a Boat Owner have a confirmed booking, certain information is shared with the Renter (and the additional Renters they may invite, if applicable) to coordinate the booking, such as your profile, full name, phone number, and address.
We don’t share your billing and payout information with other Users.
4.3 Profiles, Listings, and other Public Information.
The sail.me Platform lets you publish information, including personal information, that is visible to the general public. For example:
- Parts of your public profile page, such as your first name, your description, and city, are publicly visible to others.
- Listing pages are publicly visible and include information such as the Boat’s approximate location (neighborhood and city) or precise location (where you have provided your consent), Listing description, calendar availability, your public profile photo, aggregated demand information (like page views over a period of time), and any additional information you choose to share.
- After completing a booking, Renters and Boat Owners may write Reviews and rate each other. Reviews and Ratings are a part of your public profile page and may also be surfaced elsewhere on the sail.me Platform (such as the Listing page).
- If you submit content in a community or discussion forum, blog or social media post, or use a similar feature on the sail.me Platform, that content is publicly visible.
Based on our legitimate interest to promote the sail.me Platform we may display parts of the sail.me Platform (e.g., your Listing page) on sites operated by sail.me’s business partners, using technologies such as widgets or APIs. If your Listings are displayed on a partner’s site, information from your public profile page may also be displayed.
Information you share publicly on the sail.me Platform may be indexed through third party search engines. In some cases, you may opt-out of this feature in your Account settings. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.
4.4 Additional Services by Boat Owners.
Boat Owners may need to use third party services available through the sail.me Platform to assist with managing their Boat or providing additional services requested by you, such as cleaning services etc. Boat Owners may use features on the sail.me Platform to share information about the Renter (like check-in and check-out dates, Renter name, Renter phone number) with such third party service providers for the purposes of coordinating the stay, managing the Boat, or providing other services. Boat Owners are responsible for third party service providers they use and ensuring those service providers process Renter information securely and in compliance with applicable law including data privacy and data protection laws.
4.5 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.
These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person's vital interests or for the purposes of our or a third party’s legitimate interest in keeping the sail.me Platform secure, preventing harm or crime, enforcing or defending legal rights, facilitating the collection of taxes and prevention of tax fraud or preventing damage.
Where appropriate, we may notify Users about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon sail.me’s property, its Users and the sail.me Platform. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that User about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.
4.6 Service Providers.
sail.me and sail.me Payments uses a variety of third-party service providers to help us provide services related to the sail.me Platform and the Payment Services. Service providers may be located inside or outside of the European Economic Area (“EEA”). In particular, our service providers are based in Europe and North America.
For example, service providers may help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the sail.me Services through third party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service, advertising, or payments services, or (vii) process, handle or assess insurance claims or other similar claims. These providers have limited access to your personal information to perform these tasks on our behalf, and are contractually bound to protect the personal information and only use the personal information in accordance with our instructions.
sail.me and the sail.me Payments will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.
4.7 Corporate Affiliates.
To enable or support us in providing the sail.me Platform and the Payment Services, we may share your information, including personal information, within our corporate family of companies (both financial and non-financial entities) that are related by common ownership or control.
- Sharing with SUERA LLC. Even if your country of residence is not the United States, your information may be shared with SUERA LLC which provides the technical infrastructure for the sail.me Platform, product development and maintenance, customer support, trust and safety and other business operation services to other sail.me entities. The data sharing is necessary for the performance of the contract between you and us and is based on our legitimate interests in providing the sail.me Platform globally.
- Sharing with sail.me Payments. In order to facilitate payments on or through the sail.me Platform, certain information as described above in “Information that is necessary for the use of the Payment Services” section above, may be shared with the relevant sail.me Payments entity. The data sharing is necessary for the performance of the contract between you and us.
Additionally, we share your information, including personal information, with our corporate affiliates in order to support and integrate, promote, and to improve the sail.me Platform and our affiliates’ services.
4.8 Collection and Remittance of Occupancy Taxes.
4.9 Government Registration.
In jurisdictions where sail.me facilitates or requires a registration, notification, permit, or license application of a Boat Owner with a local governmental authority through the sail.me Platform in accordance with local law, we may share information of participating Boat Owners with the relevant authority, both during the application process and, if applicable, periodically thereafter, such as the Boat Owner’s full name and contact details, Boat address, tax identification number, Listing details, and number of nights booked.
4.10 Business Transfers.
4.11 Aggregated Data.
We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes.
5. Other Important Information
5.1 Analyzing your Communications.
We may review, scan, or analyze your communications on the sail.me Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.
These activities are carried out based on sail.me's legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.
5.2 Linking Third Party Accounts.
You may link your sail.me Account with your account at a third party social networking service. Your contacts on these third party services are referred to as “Friends.” When you create this link:
- some of the information you provide to us from the linking of your accounts may be published on your sail.me Account profile;
- your activities on the sail.me Platform may be displayed to your Friends on the sail.me Platform and/or that third party site;
- a link to your public profile on that third party social networking service may be included in your sail.me public profile;
- other sail.me users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;
- other sail.me users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking service;
- the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes; and
- the publication and display of information that you provide to sail.me through this linkage is subject to your settings and authorizations on the sail.me Platform and the third party site.
We only collect your information from linked third party accounts to the extent necessary to ensure the adequate performance of our contract with you, or to ensure that we comply with applicable laws, or with your consent.
5.3 Third Party Partners & Integrations
The sail.me Platform may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). sail.me doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, sail.me, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.
6. Your Rights
You may exercise any of the rights described in this section before your applicable sail.me Data Controller and Payments Data Controller by sending an email to [email protected] Please note that we may ask you to verify your identity and request before taking further action on your request.
6.1 Managing Your Information.
You may access and update some of your information through your Account settings. If you have chosen to connect your sail.me Account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping your personal information up-to-date.
6.2 Rectification of Inaccurate or Incomplete Information.
You have the right to ask us to correct inaccurate or incomplete personal information about you (and which you cannot update yourself within your sail.me Account).
6.3 Data Access and Portability.
In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
6.4 Data Retention and Erasure.
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. In certain jurisdictions, you can request to have all your personal information deleted entirely. Please note that if you request the erasure of your personal information:
- We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an sail.me Account for fraud or safety reasons, we may retain certain information from that sail.me Account to prevent that User from opening a new sail.me Account in the future.
- We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, sail.me and sail.me Payments may keep some of your information for tax, legal reporting and auditing obligations.
- Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on the sail.me Platform, even after your sail.me Account is deleted. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
- Because we maintain the sail.me Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
6.5 Withdrawing Consent and Restriction of Processing.
If we are processing your personal information based on your consent you may withdraw your consent at any time by changing your Account settings or by sending a communication to sail.me specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of sail.me override your own.
6.6 Objection to Processing.
In some jurisdictions, applicable law may entitle you to require sail.me and sail.me Payments not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing sail.me and/or sail.me Payments will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.
Where your personal information is processed for direct marketing purposes, you may, at any time ask sail.me to cease processing your data for these direct marketing purposes by sending an e-mail to [email protected]
6.7 Lodging Complaints.
You have the right to lodge complaints about our data processing activities by filing a complaint with our Data Protection Officer who can be reached by the “Contact Us” section below or with a supervisory authority.
7. Operating Globally & International Transfers
7.1 EU-US & Swiss-US Privacy Shield.
Under the Privacy Shield Framework, sail.me and sail.me Payments are subject to the authority of the Federal Trade Commission. If you have any questions or concerns relating to our Privacy Shield certification, contact us at SUERA LLC, 300 Delaware Ave Ste 210-A, Wilmington, DE 19801, USA or via email. If we are not able to resolve your concern, you may also contact your European Data Protection Authority or Commission or seek assistance from our designated Privacy Shield independent recourse mechanism, JAMS. In certain circumstances, you may also have the right to pursue binding arbitration through the Privacy Shield Framework, as described in Annex I to the Privacy Shield Principles.
7.2 Other Means to Ensure an Adequate Level of Data Protection.
If sail.me LLC is the Data Controller and your information is shared with corporate affiliates or third party service providers outside the EEA, we have (prior to sharing your information with such corporate affiliate or third party service provider) established the necessary means to ensure an adequate level of data protection. This may be an adequacy decision of the European Commission confirming an adequate level of data protection in the respective non-EEA country or an agreement on the basis of the EU Model Clauses (a set of clauses issued by the European Commission). We will provide further information on the means to ensure an adequate level of data protection on request.
7.3 California & Vermont Residents.
sail.me Payments will not share information it collects about you with its affiliates or third parties (both financial and non-financial), except as required or permitted by your state’s law.
7.4 California Privacy Rights.
California law permits Users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those third parties. See the “Contact Us” section for where to send such requests. sail.me and sail.me Payments do not share personal information with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personal information to third parties for their direct marketing purposes by withholding consent.
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your sail.me Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your sail.me Account, please contact us following the instructions in the Contact Us section below.
10. Contact Us
SUERA LLC, 300 Delaware Ave Ste 210-A, Wilmington, DE 19801, USA