Last updated:
October 6, 2022

Privacy Policy

Overview

This Privacy Policy describes how The San Francisco Sailing Club, Inc. ("Sail," "we", “us” or "our") handles personal information that we collect through our digital properties that link to this Privacy Policy, including our website and mobile application (collectively, the “Service”), as well as through social media, our marketing activities, our live events and other activities described in this Privacy Policy.

We provide important information for users of the Service located in the European Economic Area, Switzerland and the United Kingdom (collectively, “Europe” or “European”) in the Notice to European users section of this policy. Additionally, Sail may provide supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.

Sail offers a software-as-a-service multiplayer web browsing platform for people that wish to collaborate on projects or activities or otherwise communicate in a dedicated forum. Our customers may be enterprise, business, or individuals acting in a personal or household capacity. This Privacy Policy does not apply to information that we process on behalf of our enterprise customers while providing the Sail platform to them. Our use of such information is restricted by our agreements with those enterprise customers. If you have concerns regarding personal information that we process on behalf of an enterprise customer, please direct your concerns to that customer. For the avoidance of doubt, this Privacy Policy does apply to individual customers who use the Service in a personal or household capacity and self-serve business customers.

Personal information we collect

Information you provide to us

Personal information you may provide to us through the Service or otherwise includes:

  • Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.
  • Profile data, such as the username and password that you may set to establish an online account on the Service, biographical details, photograph, links to your profiles on social networks, interests, preferences, information about your participation in our contests, promotions, or surveys, and any other information that you add to your account profile.
  • Communications that we exchange with you, including when you contact us through the Service, social media, or otherwise.
  • Transactional data, such as information relating to or needed to complete your orders on or through the Service, including payment card information or bank account number, order numbers, and transaction history. 
  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
  • Service data, such as images, music, videos, comments, questions, messages, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata regarding your interaction with the Service (e.g., information regarding how, when, where and by whom a piece of content was viewed, collected or contributed and how that content has been formatted or edited).
  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources

We may combine personal information we receive from you with personal information we obtain from other sources, such as:

  • Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
  • Marketing partners, such as joint marketing partners and event co-sponsors.
  • Third-party services, such as OAuth services, that you use to log into, or otherwise link to or utilize through, your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.

Automatic data collection

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

  • Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 4G), and general location information such as city, state or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
  • Location data when you authorize the Service to access your device’s location.

For more information concerning our automatic collection of data, please see the Tracking technologies section below.

Data about others

As parts of the Service are designed to be interactive, we may collect personal information about you from other users of the Service, including those with whom you collaborate. We may also offer features that help users invite their friends or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details or other personal information with us unless you have their permission to do so.

Tracking technologies

Some of the automatic collection described in the personal information we collect section, above, is facilitated by the following technologies. Please see our Cookie Notice for further information.

  • Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. 
  • Local storage technologies, like HTML5 and Flash, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications. 
  • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email address was accessed or opened, or that certain content was viewed or clicked. 

For information concerning your choices with respect to the use of tracking technologies, see the Your choices section, below, as well as our Cookie Policy.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery

We may use your personal information to:

  • provide, operate and improve the Service and our business;
  • establish and maintain your user profile on the Service;
  • facilitate your invitations to friends who you want to invite to join the Service;
  • enable security features of the Service, such as by remembering devices from which you have previously logged in;
  • communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
  • understand your needs and interests, and personalize your experience with the Service and our communications; and
  • provide support for the Service, and respond to your requests, questions and feedback.

Research and development

We may use your personal information for research and development purposes, such as to analyze and improve the Service and our business, including through the use of analytics. For example, we may use analytics in connection with the Service to understand user activity on the Service, such as which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. 

Marketing and advertising

We, our service providers and our third-party partners may collect and use your personal information for marketing and advertising purposes:

  • Direct marketing. We may send you direct marketing communications.You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
  • Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms.

Compliance and protection

We may use your personal information to:

  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
  • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); 
  • audit our internal processes for compliance with legal and contractual requirements or our internal policies; 
  • enforce the terms and conditions that govern the Service; and 
  • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent

In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create anonymous, aggregated or de-identified data

We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Retention

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

When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.

Affiliates

Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers

Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics). 

Payment processors

Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy.

Advertising partners

Third-party advertising companies for the interest-based advertising purposes described above. 

Business and marketing partners

Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.

Linked third-party services

If you log into, link to, or otherwise access or use third-party services, through your Service account, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.

Professional advisors

Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others

Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above. 

Business transferees

Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Sail or our affiliates (including, in connection with a bankruptcy or similar proceedings).

Other users and the public

Your profile and other Service data, including user-generated content, are visible in some cases to other users of the Service and the public. For example, other users of the Service with whom you collaborate or the public, depending on the nature of the forum you’re using or in which you’re posting, may have access to your information if you chose to make it available to them through the Service, such as when you provide comments, post, or share or provide other content. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.

We make commercially reasonable efforts to verify that the parties with whom our mobile application shares personal information provide a level of protection of personal information consistent with the practices described in this Privacy Policy, except that all such parties described above other than service providers and affiliates may, to the extent permitted by law, use personal information as described in their own privacy policies.

Your choices 

Access or update your information

If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account. 

Opt-out of marketing communications

You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Mobile location data

You can disable our access to your device’s precise geolocation in your mobile device settings.

Cookies & advertising choices 

Your options for controlling what information cookies and similar technologies collect about you may include the following. Please see our Cookie Policy for further information.

  • Blocking cookies in your browser: Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to manage and delete cookies on your device, visit www.allaboutcookies.org. If you do not accept our cookies, you may experience some inconvenience in your use of the Service. For example, we may not be able to recognize your computer and you may need to log in every time you use the Service.
  • Privacy browsers/plug-ins: By using privacy browsers or ad-blocking browser plug-ins, you may be able to block certain tracking technologies. 
  • Platform settings: You can opt-out of interest-based advertising through certain third parties by using such third-party’s opt-out tool. For example, Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising: Google (https://adssettings.google.com), Facebook (https://www.facebook.com/about/ads).
  • Ad industry tools: You may opt out of interest-based ads from companies participating in the following industry opt-out programs: Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp), Digital Advertising Alliance (optout.aboutads.info), AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance. 
  • Mobile settings: Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

You will need to apply these opt-out settings on each device from which you wish to opt-out.

We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above. 

Do not track

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information

We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Third-party platforms

If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Delete your content or close your account

You can choose to delete certain content through your account. If you wish to request to close your account, please go to https://sail.online/delete-account or contact us.

Other sites & services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect against unauthorized access, use, disclosure, and loss. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information. 

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country. If you are located in the EEA/UK, please see the section on transfers in the Notice to European users for more information.

Children

The Service is not intended for use by anyone under the age of 13 in the United States or 16 in the EEA/UK. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy 

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

How to contact us

  • Email: team@sailoften.com
  • Mail: 2309 Bryant Street San Francisco, CA 94110
  • Phone: 415-707-SAIL (415-707-7245)

Notice to European users

The information provided in this “Notice to European users” section applies only to individuals in the United Kingdom, Switzerland, and the European Economic Area (hereafter collectively referred to as “Europe”).

Personal information

References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation. 

Controller

Sail is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation.

Legal bases for processing

We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described in the table below.

Use for new purposes

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis. 

Retention

We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for compliance and protection purposes.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. 

When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Sensitive personal information

We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service, or otherwise to us. 

Your rights

European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

  • Access: Provide you with information about our processing of your personal information and give you access to your personal information.
  • Correct: Update or correct inaccuracies in your personal information.
  • Delete: Delete your personal information where there is no lawful reason for us continuing to store or process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.
  • Portability: Port a machine-readable copy of your personal information to you or a third party of your choice, in certain circumstances. Note that this right only applies to automated information for which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Restrict: Restrict the processing of your personal information, if, (i) you want us to establish the personal information's accuracy; (ii) where our use of the personal information is unlawful but you do not want us to erase it; (iii) where you need us to hold the personal information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use.
  • Object: Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights, where we are relying on legitimate interests (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedom. You also have the right to object where we are processing your personal information for direct marketing purpose.
  • Withdraw Consent: When we use your personal information based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent.

You may submit these requests by email to team@sailoften.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here

Cross-border data transfer

We may transfer your personal information outside of the EEA and/or UK. Some of these recipients are located in countries in respect of which either the European Commission and/or UK Government (as and where applicable) has issued adequacy decisions, in which case, the recipient’s country is recognized as providing an adequate level of data protection under UK and/or European data protection laws (as applicable) and the transfer is therefore permitted under Article 45 of the GDPR.

Some recipients of your personal data may be located in countries outside the EEA and/or the UK for which the European Commission or UK Government (as and where applicable) has not issued adequacy decisions in respect of the level of data protection in such countries (“Restricted Countries”). For example, the United States is a Restricted Country. Where we transfer your personal information to a recipient in a Restricted Country, we will either:

  • enter into appropriate data transfer agreements based on so-called Standard Contractual Clauses approved from time-to-time under GDPR Art. 46 by the European Commission, the UK Information Commissioner’s Office or UK Government (as and where applicable); or
  • rely on other appropriate means permitted by the EEA/UK GDPR, which establish that such recipients will provide an adequate level of data protection and that appropriate technical and organizational security measures are in place to protect personal information against accidental or unlawful destruction, loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.

You may ask for a copy of such appropriate data transfer agreements by contacting us using the contact details above.

Your right to lodge a complaint with your supervisory authority

In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence. 

  • For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en
  • For users in the UK – the contact information for the UK data protection regulator is below:

The Information Commissioner’s Office
Water Lane, Wycliffe House
Wilmslow - Cheshire SK9 5AF
Tel. +44 303 123 1113
Website: https://ico.org.uk/make-a-complaint/