Sailes General Privacy Policy

Updated as of September, 2023

Sailes, Inc. (“Saile”, “Sailes”, “Sailebot^®”, we”, “our”, or “us”) respects your privacy and is committed to protecting it through our compliance with this policy.

This Privacy Policy (“Policy”) discloses the privacy practices of Sailes, Inc. This Policy describes the types of information we may collect from you or that you may provide when you visit the site https://www.Sailes.com (“Site”) and our practices for collecting, using, maintaining, protecting and disclosing that information. Please also visit our Terms & Conditions for restrictions, disclaimers, liability limitations, and other terms you need to know to use our site. 

This policy applies to information we collect:

• On the Site; and
• In email, text and other electronic messages between you and Sailes.

This policy does not apply to:

• services offered by other companies or individuals, including through any application or content (including advertising) that may link or be accessible from or through our Site.

This policy is supplemented where: 

• certain specific product and service offerings of Sailes, for example our Starboard™ product and services, include additional terms and conditions pertaining to third party personal information which may be provided to us by you (users of such products and services) and for which there are separate terms and conditions.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Site. By accessing or using our Site, you consent to this Policy. This Policy may change from time to time (see Changes to our Privacy Policy). Your continued use of our Site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

INFORMATION WE COLLECT AND HOW WE COLLECT IT

As used in this Policy, the term “personal information” means information that specifically identifies an individual (such as a name, address, telephone number, mobile number, email address, driver’s license number, credit card number, or any other account number). Personal information also includes demographic information such as date of birth, gender, geographic area and preferences when that information is linked to other personal information that identifies the individual. Personal information does not include “aggregate” information, which is data we collect about the use of our Site or a group or category of products, services, or customers if all personal information has been removed.

When you register on our Site, we may ask you for certain personal information including your name, email address and a username and password you create. When you place an order online we will ask for your name, email address, shipping and billing addresses and credit card information. When you complete a survey or request further information on our site, we will request personal contact information and demographic information. If you apply for a job online, we will ask for your name, email address, mobile number, home phone number, home address, county, resume, work samples, transcripts, certifications, education level, work eligibility status, visa status, social security number, driver’s license number, accommodations, gender, ethnicity, race, veteran status and disability information. We will maintain records for a reasonable period concerning your registration with and use of our Site, including any correspondence you have with us.

We collect the information listed above directly from you when you submit it through our Site. If you do not wish to share this type of information, you may choose not to participate in a particular service or activity.

INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES

As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain usage information about your equipment, browsing actions and patterns, including:

• Details of your visits to our Site, including traffic data, logs and other communication data and the resources that you access and use through our Site; and
• Information about your computer or device and internet connection, including your IP address, operating system and browser type.

The information we collect automatically may include personal information. It helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Site according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Site.

The technologies we use for this automatic data collection may include:

Cookies: A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site.

Site Analytics: We utilize Amplitude to help us gather various pieces of usage and demographic information. Specifically, we have enabled geographic and general site movement pattern features within Amplitude. You have the option to opt-out of any Amplitude features we use by following the instructions provided by Amplitude for opting out of their analytics tracking.

THIRD PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

Some content, including advertisements and social networking platform plug-ins, displayed on our Site are served by third parties including advertisers, content providers and application providers. These third parties may use cookies, alone or in conjunction with other tracking technologies, to collect information about you when you use our Site. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or targeted content, you should contact the responsible provider directly.

USE OF INFORMATION

Sailes will use your personal information solely for its internal business purposes. That includes use of your information: to facilitate our administration and operation of our Site; to understand better how you engage with our Site; to present our Site and their contents to you; to maintain the integrity of our Site; to fulfill any other purpose for which you provide your information; to process your requests; to provide you with information or services you request; to notify you about changes to our Site or any products or services we offer or provide through the Site; to allow you to participate in interactive feature on our Site; to inform you about other promotion, products or service we think will be of interest to you; to process submitted job applications; to enable you to review products we offer; in any other way we may describe when you provide the information; and for any other purpose with your consent. We strive to improve our Site and offerings based on your information and feedback, to personalize your experience to respond to our customers’ individual needs and to improve customer service so we may effectively respond to your requests.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

We may also collect information from third party service providers. Any information we collect about you may be combined and used to help us tailor our services and communications to you and may be shared with third parties consistent with this Policy. You hereby authorize Sailes to request, receive, use and store such information for a reasonable period. Additionally, you agree that the personal information provided by you may be linked together or merged with other personal information so that we may gain a better understanding of your account information and your use of our Site. In any case, this Policy governs any information we maintain about you and your use of our Site.

DISCLOSURE OF YOUR INFORMATION

Sailes will not sell, trade or rent your personal information to others, or share the personal information we collect from you with third parties except as described in this Policy.

We may disclose personal information that we collect or that you provide as described in this Policy:

• To our subsidiaries and affiliates.
• To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by use when you provide the information
• With your consent.

We may share personal information with other vendors and service providers who are engaged by or working with us in connection with the operation of our Site and who need access to such information to carry out their work for us. For example, we utilize a third party service to generate push notifications to users’ mobile devices. Sailes will endeavor to choose service providers who have agreed to protect the confidentiality of any personal information the service provider receives. Sailes is not responsible for the act or omission of its service providers.

Sailes may disclose personal information in the good faith belief that we are lawfully authorized or required to do so, or that doing so is reasonably necessary or appropriate to comply with the law or with legal process or authorities, respond to any claim, or to protect the rights, property or safety of Sailes, our customers, our employees or the public. That includes actions we may take to protect Sailes or our customers from fraudulent, abusive, inappropriate, or unlawful use of our Site.

Information about our customers, including personal information, may also be disclosed or transferred as part of, or during negotiation of, any merger, sale of company assets, financing or acquisition or in any other situation where personal information may be transferred as one of the business assets of Sailes, or as part of a bankruptcy, liquidation or similar proceeding.

AGGREGATE DATA

Sailes may compile aggregate information about the use of our Site. In other words, information about how you use our Site may be collected and combined with information about how others use the same service. Aggregate data helps us understand trends and our customers’ needs so that we can better consider new features or otherwise tailor our Site. Sailes may also share aggregated demographic information with advertisers and partners. This Policy in no way restricts or limits our collection and use of aggregate information.

SECURITY

We take precautions to protect your information. To this effect, we have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. Your personal information is transmitted to us securely through encryption and is stored on secure servers. Offline, only employees who need personal information to perform a specific job are granted access to collected personal information.

The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Site.

OUR POLICIES CONCERNING CHILDREN AND MINORS

Our Site is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on our Site. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on our Site or through any of the Site’s features, register or create an account on our Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at dpo@saile.ai

ACCESSING AND CORRECTING YOUR INFORMATION

You may opt out of future contacts from us at any time. You may contact us via the email address or phone number provided at the end of this Policy or on our Site’s Contact Us page to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. You may also contact us to express concerns you may have about our use of your data.

DO NOT TRACK DISCLOSURES

Do Not Track (“DNT”) is a privacy preference that users can set in their web browsers. Our Site does not support DNT codes. Except in the case of analytics cookies, remarketing and other features of Google Analytics described above, our Site limits tracking to the internal uses described above and does not track your use across multiple websites. However, other websites to which we link may. Please review their privacy policies to understand how you may be tracked.

YOUR STATE PRIVACY RIGHTS

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. To learn more about California residents’ privacy rights, see below. Colorado, Connecticut, Virginia and Utah each provide their state residents with rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Data portability
• Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut and Virginia also provide their state residents with rights to:

• Correct inaccuracies in their personal information, taking into account the information’s nature or processing purpose.
• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

Finally, Nevada provides their state residents with rights to:

• Opt-out of the sale of certain kinds of personal information, where a sale is the transfer of personal information to third parties for monetary consideration so the third parties can then resell or license the sold information.

We do not sell your information to third parties as defined in Nevada law.

To exercise any of these rights please contact us via email at dpo@saile.ai

CALIFORNIA PRIVACY RIGHTS

If you are a customer that resides in the State of California, please see our supplemental policy.

CHANGES TO OUR PRIVACY POLICY

This Policy may change from time to time as we continue to evaluate this Policy against new technologies, regulations and business practices. We will not reduce your rights under this Policy without your explicit consent. We will post any privacy policy changes on this page, and if the changes are significant, we will provide a more prominent notice, including by email. The date the privacy policy was revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date, active and deliverable email address for you, and for periodically visiting our Site and this Policy to check for any changes.

CONTACT

If have any questions about this Policy, the practices of our Site, or your dealings with Sailes, please contact us at: 816.355.4501 or dpo@saile.ai.

Sailes, Inc. Privacy Policy Supplement for California Residents

Updated as of September, 2023

This Privacy Policy for California Residents supplements the information contained in Sailes, Inc.’s general Privacy Policy and applies solely to all visitors, users, customers and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Policy.

INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device (collectively, “personal information”). Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, such as:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data;
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.Some personal information included in this category may overlap with other categories.	Yes
D. Commercial information.	Records or personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health or exercise data.	No
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	No
G. Geolocation data.	Physical location or movements.	Yes
H. Sensory data.	Audio, electronic, visual, thermal, olfactory or similar information.	No
I. Professional or employment-related information.	Current or past job history or performance evaluations.	Yes
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information or student disciplinary records.	No
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.	No

USE OF PERSONAL INFORMATION

See our General Privacy Policy.

YOUR RIGHTS AND CHOICES

The CCPA provides consumers with specific rights regarding this personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability: You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • Sales, identifying the personal information categories that each category of recipient purchased; and
  • Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Requests to Delete: You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction or service for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise performing our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug online services to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Rights to Know or Delete: To request your rights to know or delete as described above, please submit a request by either:

• Calling us at +1 (816) 355-4501 or
• Emailing us at dpo@saile.ai and asking for a Consumer Request Form

Only you, or someone legally authorized to act on your behalf, may make a request to know or to delete related to your personal information.  To designate an authorized agent, email us at dpo@saile.ai and we will provide you with a form to make a designated agent request.

You may only submit a request to know or delete twice within a 12-month period. Your request to know or delete must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: your full name, address, date of birth and driver’s license number.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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.

You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format: We will try to respond to your request within forty-five (45) days of when we receive it. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights:  If you are age 16 or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years old, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 15 years old, or the parent or guardian of a consumer less than 13 years old. Consumers who opt-in to personal information sales may opt-out of future sales at any time. 

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing dpo@saile.ai.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing dpo@saile.ai

We will only use personal information provided in an opt-out request to review and comply with the request. We will act upon your opt-out request within 15 business days of receipt.

NON-DISCRIMINATION

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this Policy, we will post the updated notice on our Services and update the notice’s effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.

CONTACT INFORMATION

If you have any questions or comments about this notice, the ways in which we collect and uses your information described here and in this Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at dpo@saile.ai