Privacy Policy of Sailsquare

Sailsquare collects some Personal Data from its Users.

This document contains a section dedicated to California consumers and their privacy rights.

This document contains a section dedicated to Virginia consumers and their privacy rights.

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Owner and Data Controller

Sailsquare Srl - Società Benefit – Via Aosta 4, Milan - Italy

Owner contact email: hello@sailsquare.com

Types of Data collected

Among the types of Personal Data that Sailsquare collects, by itself or through third parties, there are: first name; last name; gender; date of birth; phone number; address; email address; username; password; VAT Number; company name; country; Social Security number (SSN); city; picture; profile picture; website; language; Cookies; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data; geographic position; scroll-to-page interactions; clicks; device information; mouse movements; interaction events; page events; layout details; positional information.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Sailsquare.
Unless specified otherwise, all Data requested by Sailsquare is mandatory and failure to provide this Data may make it impossible for Sailsquare to provide its services. In cases where Sailsquare specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by Sailsquare or by the owners of third-party services used by Sailsquare serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through Sailsquare and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Sailsquare (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Registration and authentication provided directly by Sailsquare, Access to third party services' accounts, Handling payments, Registration and authentication, Analytics, Contacting the User, Managing contacts and sending messages, Managing support and contact requests, Advertising, Remarketing and behavioral targeting, Hosting and backend infrastructure, Backup saving and management, Displaying content from external platforms, Tag Management, Content performance and features testing (A/B testing), Heat mapping and session recording, Interaction with online survey platforms, Social features, Infrastructure monitoring, Interaction with support and feedback platforms, Interaction with data collection platforms and other third parties, Selling goods and services online and Interaction with live chat platforms.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Facebook permissions asked by Sailsquare

Sailsquare may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows Sailsquare to connect with the User's account on the Facebook social network, provided by Facebook Inc.

For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.

The permissions asked are the following:

Basic information

By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.

About Me

Provides access to the 'About Me' section of the profile.

Access private data

Access the User's and friends' private data.

Birthday

Provides access to the birthday.

Contact email

Access the User's contact email address.

Current City

Provides access to the User's current location.

Email

Provides access to the User's primary email address.

List of Friends

Share items on the User's behalf.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Access to third party services' accounts

This type of services allows Sailsquare to access Data from your account on a third party service and perform actions with it.
These services are not activated automatically, but require explicit authorization by the User.

Facebook account access (Sailsquare)

This service allows Sailsquare to connect with the User's account on the Facebook social network, provided by Facebook, Inc.

Permissions asked: About Me; Access private data; Birthday; Contact email; Current City; Email; List of Friends; Share.

Place of processing: US – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers; california Consumer Records Statute information; internet information.

Stripe account access (Stripe Inc)

This service allows Sailsquare to connect with the User's account on Stripe, provided by Stripe, Inc.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: US – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA

Advertising

This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on Sailsquare, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside Sailsquare. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

Google AdSense (Google Inc.)

Google AdSense is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. This service uses the “DoubleClick” Cookie, which tracks use of Sailsquare and User behavior concerning ads, products and services offered.
Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.

In order to understand Google's use of data, consult Google's partner policy.

Personal Data processed: Cookies; Usage Data.

Place of processing: US – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Facebook Audience Network (Meta Platforms Ireland Limited)

Facebook Audience Network is an advertising service provided by Meta Platforms Ireland Limited In order to understand Facebook's use of Data, consult Facebook's data policy.

Sailsquare may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Facebook Audience Network service. One of the ways Audience Network shows ads is by using the User's ad preferences. The User can control this in the Facebook ad settings.

Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.

Personal Data processed: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

Place of processing: Ireland – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: identifiers; internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Microsoft Advertising (Microsoft Corporation)

Microsoft Advertising is an advertising service provided by Microsoft Corporation.

Personal Data processed: Cookies; Usage Data.

Place of processing: US – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Google Inc.)

Personal Data processed: Cookies; Usage Data.

Place of processing: US – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Google Ads conversion tracking (Google Inc.)

Google Ads conversion tracking is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Google Ads advertising network with actions performed on Sailsquare.

Personal Data processed: Cookies; Usage Data.

Place of processing: US – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.)

Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Facebook advertising network with actions performed on Sailsquare. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.

Personal Data processed: Cookies; Usage Data.

Place of processing: US – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Google Analytics with anonymized IP (Google Inc.)

Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilizes the Data collected to track and examine the use of Sailsquare, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.

Personal Data processed: Cookies; Usage Data.

Place of processing: US – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Google Analytics Advertising Reporting Features

Google Analytics on Sailsquare has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).

Users can opt out of Google's use of cookies by visiting Google's Ads Settings.

Personal Data processed: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: identifiers; internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

User ID extension for Google Analytics (Google Inc.)

Google Analytics on Sailsquare makes use of a feature called User ID. This setup allows for a more accurate tracking of Users by associating that User with the same ID over various sessions and devices. It is set up in a way that doesn’t allow Google to personally identify an individual or permanently identify a particular device.
The User ID extension might make it possible to connect Data from Google Analytics with other Data about the User collected by Sailsquare.
The opt-out link below will only opt you out for the device you are on, but not from tracking performed independently by the Owner. Contact the Owner via the email address provided in this privacy policy to object to the aforementioned tracking as well.

Personal Data processed: Cookies.

Place of processing: US – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)

Hotjar is an analytics service provided by Hotjar Ltd.
Hotjar honors generic Do Not Track headers. This means your browser can tell its script not to collect any of your data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

Personal Data processed: Cookies; Usage Data.

Place of processing: Malta – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

TikTok conversion tracking

TikTok conversion tracking is an analytics and behavioral targeting service provided by TikTok Inc., TikTok Information Technologies UK Limited or by TikTok Technology Limited, depending on how the Owner manages the Data processing, that connects data from the TikTok advertising network with actions performed on Sailsquare. The TikTok pixel tracks conversions that can be attributed to TikTok ads and enables to target groups of Users on the base of their past use of Sailsquare.

Personal Data processed: Trackers.

Place of processing: United States – Privacy Policy; United Kingdom – Privacy Policy; Ireland – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Backup saving and management

This type of service allows the Owner to save and manage backups of Sailsquare on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to Sailsquare.

Amazon Glacier (Amazon)

Amazon Glacier is a service to save and manage backups provided by Amazon Web Services Inc.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: US – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

Contacting the User

Mailing list or newsletter (Sailsquare)

By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Sailsquare. Your email address might also be added to this list as a result of signing up to Sailsquare or after making a purchase.

Personal Data processed: city; country; date of birth; email address; first name; gender; last name.

Category of personal information collected according to the CCPA: identifiers; biometric information.

This processing constitutes:

a sale according to the VCDPA

Phone contact (Sailsquare)

Users that provided their phone number might be contacted for commercial or promotional purposes related to Sailsquare, as well as for fulfilling support requests.

Personal Data processed: phone number.

Category of personal information collected according to the CCPA: identifiers.

This processing constitutes:

a sale according to the VCDPA

Contact form (Sailsquare)

By filling in the contact form with their Data, the User authorizes Sailsquare to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data processed: email address; first name; last name.

Category of personal information collected according to the CCPA: identifiers.

This processing constitutes:

a sale according to the VCDPA

Content performance and features testing (A/B testing)

The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of Sailsquare.

Google Optimize (Google Inc.)

Google Optimize is an A/B testing service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, ("Google").

Google may use Personal Data to contextualize and personalize the ads of its own advertising network.

Personal Data processed: Cookies; Usage Data.

Place of processing: US – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of Sailsquare and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Google Fonts

Google Fonts is a typeface visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows Sailsquare to incorporate content of this kind on its pages.

Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Google Maps widget (Google Inc.)

Google Maps is a maps visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows Sailsquare to incorporate content of this kind on its pages.

Personal Data processed: Cookies; Usage Data.

Place of processing: US – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

YouTube video widget (Google Inc.)

YouTube is a video content visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows Sailsquare to incorporate content of this kind on its pages.

Personal Data processed: Cookies; Usage Data.

Place of processing: US – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Handling payments

Payment processing services enable Sailsquare to process payments by credit card, bank transfer or other means. To ensure greater security, Sailsquare shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

PayPal (PayPal Inc.)

PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Category of personal information collected according to the CCPA: internet information.

Stripe (Stripe Inc)

Stripe is a payment service provided by Stripe Inc.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: US – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

Heat mapping and session recording

Heat Mapping services are used to display the areas of a page where Users most frequently move the mouse or click. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.

Hotjar Heat Maps & Recordings (Hotjar Ltd.)

Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

Personal Data processed: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: Malta – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Microsoft Clarity (Microsoft Corporation)

Microsoft Clarity is a session recording and heat mapping service provided by Microsoft Corporation.
Microsoft processes or receives Personal Data via Microsoft Clarity, which in turn may be used for any purpose in accordance with the Microsoft Privacy Statement, including improving and providing Microsoft Advertising.

Personal Data processed: clicks; device information; interaction events; layout details; mouse movements; page events; positional information; scroll-to-page interactions.

Place of processing: United States – Privacy Policy; Brazil – Privacy Policy; Australia – Privacy Policy; Japan – Privacy Policy; Canada – Privacy Policy; Korea, Republic of – Privacy Policy; India – Privacy Policy; Germany – Privacy Policy; France – Privacy Policy; Netherlands – Privacy Policy; Ireland – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Hosting and backend infrastructure

This type of service has the purpose of hosting data and files that enable Sailsquare to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Sailsquare. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Amazon Web Services (AWS) (Amazon)

Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: See the Amazon privacy policy – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

DigitalOcean (DigitalOcean Inc.)

DigitalOcean is a hosting service provided by DigitalOcean Inc.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: US – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

Heroku (Salesforce.com, inc.)

Heroku is a hosting service provided by Salesforce.com, inc.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: Germany – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

Infrastructure monitoring

This type of service allows Sailsquare to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of Sailsquare.

Uptime Robot (Buzpark Bilisim Tarim Urunleri Sanayi Tic. Ltd. Sti.)

Uptime Robot is a monitoring service provided by Buzpark Bilisim Tarim Urunleri Sanayi Tic. Ltd. Sti.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: Turkey – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

Sentry (Functional Software, Inc. )

Sentry is a monitoring service provided by Functional Software, Inc. .

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

Interaction with data collection platforms and other third parties

This type of service allows Users to interact with data collection platforms or other services directly from the pages of Sailsquare for the purpose of saving and reusing data.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

Typeform widget (TYPEFORM S.L)

The Typeform widget is a service for interacting with the Typeform data collection platform provided by TYPEFORM S.L.

Personal Data processed: city; country; date of birth; email address; first name; gender; geographic position; last name; phone number; various types of Data as specified in the privacy policy of the service.

Place of processing: Spain – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers; biometric information; internet information; geolocation data.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Interaction with live chat platforms

This type of service allows Users to interact with third-party live chat platforms directly from the pages of Sailsquare, in order to contact and be contacted by Sailsquare‘s support service.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

Zendesk Chat (Zendesk, Inc.)

Zendesk Chat is a service for interacting with the Zendesk live chat platform provided by Zendesk, Inc.

Personal Data processed: email address; first name.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Interaction with online survey platforms

This type of service allows Users to interact with third party online survey platforms directly from the pages of Sailsquare.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

Hotjar Poll & Survey widgets (Hotjar Ltd.)

The Hotjar Poll & Survey widgets are services that enable interaction with the Hotjar platform provided by Hotjar Ltd.
Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

Personal Data processed: Cookies; Usage Data; various types of Data.

Place of processing: Malta – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Interaction with support and feedback platforms

This type of service allows Users to interact with third party support and feedback platforms directly from the pages of Sailsquare.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

Zendesk Widget (Zendesk)

The Zendesk Widget is a service for interacting with the Zendesk support and feedback platform provided by Zendesk Inc.

Personal Data processed: Cookies; Usage Data.

Place of processing: US – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Managing contacts and sending messages

This type of services makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Mailchimp (The Rocket Science Group, LLC.)

Mailchimp is an email address management and message sending service provided by Intuit Inc.

Personal Data processed: email address.

Place of processing: US – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Amazon Simple Email Service (Amazon)

Amazon Simple Email Service is an email address management and message sending service provided by Amazon.com Inc.

Personal Data processed: email address.

Place of processing: US – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Skebby (Skebby - Mobile Solution S.r.l.)

Skebby is a phone numbers management and communication service provided by Skebby - Mobile Solution S.r.l.

Personal Data processed: phone number.

Place of processing: Italy – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Mailgun (Mailgun Technologies, Inc.)

Mailgun is an email address management and message sending service provided by Mailgun Technologies, Inc.

Personal Data processed: email address.

Place of processing: Germany – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Managing support and contact requests

This type of services allows Sailsquare to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).

Zendesk (Zendesk)

Zendesk is a support and contact request management service provided by Zendesk Inc.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: US – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Registration and authentication

By registering or authenticating, Users allow Sailsquare to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, Sailsquare will be able to access some Data, stored by these third party services, for registration or identification purposes.

Facebook Authentication (Facebook, Inc.)

Facebook Authentication is a registration and authentication service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, and is connected to the Facebook social network.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: US – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Google OAuth (Google Inc.)

Google OAuth is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, and is connected to the Google network.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: US – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA

Registration and authentication provided directly by Sailsquare

By registering or authenticating, Users allow Sailsquare to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.

Direct registration (Sailsquare)

The User registers by filling out the registration form and providing the Personal Data directly to Sailsquare.

Personal Data processed: address; city; company name; country; date of birth; email address; first name; gender; language; last name; password; phone number; picture; profile picture; Social Security number (SSN); username; VAT Number; website.

Category of personal information collected according to the CCPA: identifiers; commercial information; biometric information; internet information; sensorial information; inferred information.

Remarketing and behavioral targeting

This type of service allows Sailsquare and its partners to inform, optimize and serve advertising based on past use of Sailsquare by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

Google Ads Remarketing (Google Inc.)

Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of Sailsquare with the Google Ads advertising network and the DoubleClick Cookie.

Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.

Personal Data processed: Cookies; Usage Data.

Place of processing: US – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Remarketing with Google Analytics (Google Inc.)

Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.

Personal Data processed: Cookies; Usage Data.

Place of processing: US – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Facebook Custom Audience (Facebook, Inc.)

Facebook Custom Audience is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of Sailsquare with the Facebook advertising network.

Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.

Personal Data processed: Cookies; email address.

Place of processing: US – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: identifiers; internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Facebook Remarketing (Facebook, Inc.)

Facebook Remarketing is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of Sailsquare with the Facebook advertising network.

Personal Data processed: Cookies; Usage Data.

Place of processing: US – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

TikTok Remarketing

TikTok Remarketing is a remarketing and behavioral targeting service provided by TikTok Information Technologies UK Limited , TikTok Inc. or by TikTok Technology Limited, depending on how the Owner manages the Data processing, that connects the activity of Sailsquare with the TikTok advertising network.

Personal Data processed: device information; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

Place of processing: United Kingdom – Privacy Policy; United States – Privacy Policy; Ireland – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers; internet information.

This processing constitutes:

a sale according to the CCPA and the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Selling goods and services online

This type of service helps the Owner to sell goods, provide services or monetize online content. To this end, the services listed below may for instance allow the Owner to process payments, set up subscription models, track orders, and manage deliveries.

Refund Protect

Refund Protect is a Membership programme which enables its clients to offer their customers an enhanced set of terms of conditions which in unforeseen circumstances outside of their control, enables their customer to apply for refund on non-refundable bookings.

This processing constitutes:

a sale according to the VCDPA
a sharing according to the CCPA
targeted advertising according to the VCDPA

Social features

Inviting and suggesting friends (Sailsquare)

Sailsquare may use the Personal Data provided to allow Users to invite their friends - for example through the address book, if access has been provided - and to suggest friends or connections inside it.

Personal Data processed: various types of Data.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the VCDPA

Public profile (Sailsquare)

Users may have public profiles that other Users can display. In addition to the Personal Data provided, this profile may contain Users' interactions with Sailsquare.

Personal Data processed: city; date of birth; first name; gender; picture.

Category of personal information collected according to the CCPA: identifiers; biometric information; sensorial information.

This processing constitutes:

a sale according to the VCDPA

Tag Management

This type of service helps the Owner to manage the tags or scripts needed on Sailsquare in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

Google Tag Manager

Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Category of personal information collected according to the CCPA: internet information.

This processing constitutes:

a sale according to the CCPA

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

Further information about the processing of Personal Data

Data sharing between Traveller and Crew Leader

When the Traveller books an Experience, Sailsquare sends to the Crew Leader the Traveller's personal data in order to finalise the agreement between them, and, if applicable, to allow the Crew Leader to issue the invoice.

Personal data processed: name, surname, email, fiscal code, address, city, province, country, phone number.

Selling goods and services online

The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by Sailsquare depends on the payment system used.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Cookie Policy

Sailsquare uses Trackers. To learn more, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Sailsquare or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, Sailsquare may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, Sailsquare and any third-party services may collect files that record interaction with Sailsquare (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

Sailsquare does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Sailsquare and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Information for Californian consumers

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running Sailsquare and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the state of California, United States of America, according to the "California Consumer Privacy Act of 2018" (the "CCPA"), as updated by the "California Privacy Rights Act" (the "CPRA") and subsequent regulations. For such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the terms “personal information” (and “sensitive personal information”) as defined in the California Consumer Privacy Act (CCPA).

Notice at collection

Categories of personal information collected, used, sold, or shared

In this section we summarize the categories of personal information that we've collected, used, sold, or shared and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.

Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you: identifiers, california Consumer Records Statute information, commercial information, biometric information, internet information, geolocation data, sensorial information and inferred information.

We have collected the following categories of sensitive personal information: username, password, VAT Number and Social Security number (SSN)

We will not collect additional categories of personal information without notifying you.

Your right to limit the use or disclosure of your sensitive personal information and how you can exercise it

You have the right to request that we limit the use or disclosure of your sensitive personal information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer.

We can also use your sensitive personal information to perform specific purposes set forth by the law (such as, including but not limited to, helping to ensure security and integrity; undertaking activities to verify or maintain the quality or safety of our service) and as authorized by the relevant regulations.

Outside of the aforementioned specific purposes, you have the right to freely request, at any time, that we do not use or disclose your sensitive personal information. This means that whenever you ask us to stop using your sensitive personal information, we will abide by your request and we will instruct our service providers and contractors to do the same.

To fully exercise your right to limit the use or disclosure of your sensitive personal information you can contact us at any time, using the contact details provided in this document.

For a simplified opt-out method you can also use the privacy choices link provided on Sailsquare.

We use any personal information collected from you in connection with the submission of your request solely for the purposes of complying with the request.

Once you have exercised this right, we are required to wait at least 12 months before asking whether you have changed your mind.

What are the purposes for which we use your personal information?

We may use your personal information to allow the operational functioning of Sailsquare and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.

We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.

How long do we keep your personal information?

Unless stated otherwise inside the “Detailed information on the processing of Personal Data” section, we will not retain your personal information for longer than is reasonably necessary for the purpose(s) they have been collected for.

How we collect information: what are the sources of the personal information we collect?

We collect the above-mentioned categories of personal information, either directly or indirectly, from you when you use Sailsquare.

For example, you directly provide your personal information when you submit requests via any forms on Sailsquare. You also provide personal information indirectly when you navigate Sailsquare, as personal information about you is automatically observed and collected.

Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.

How we use the information we collect: disclosing of your personal information with third parties for a business purpose

For our purposes, the word “third party” means a person who is not any of the following: a service provider or a contractor, as defined by the CCPA.

We disclose your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.

Sale or sharing of your personal information

For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to a third party, for monetary or other valuable consideration”, as defined by the CCPA.

This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.

For our purposes, the word “sharing” means any “sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged”, as defined by the CCPA.
Please note that the exchange of personal information with a service provider pursuant to a written contract that meets the requirements set by the CCPA, does not constitute a sale or sharing of your personal information.

Your right to opt out of the sale or sharing of your personal information and how you can exercise it

We sell or share your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.

You have the right to opt out of the sale or sharing of your personal information. This means that whenever you request us to stop selling or sharing your personal information, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request.
To fully exercise your right to opt out, you can contact us at any time using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on Sailsquare.

If you want to submit requests to opt out of the sale or sharing of personal information via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.

We use any personal information collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.

Once you have opted out, we are required to wait at least 12 months before asking whether you have changed your mind.

What are the purposes for which we use your personal information?

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.

How long do we keep your personal information?

Your privacy rights under the California Consumer Privacy Act and how to exercise them

The right to access personal information: the right to know and to portability

You have the right to request that we disclose to you:

the categories of personal information that we collect about you;
the sources from which the personal information is collected;
the purposes for which we use your information;
to whom we disclose such information;
the specific pieces of personal information we have collected about you.

You also have the right to know what personal information is sold or shared and to whom. In particular, you have the right to request two separate lists from us where we disclose:

the categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared;
the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

The disclosure described above will be limited to the personal information collected or used over the past 12 months.

If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.

The right to request the deletion of your personal information

You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on Sailsquare, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising your right, we will delete your personal information and notify any of our service providers and all third parties to whom we have sold or shared the personal information to do so – provided that this is technically feasible and doesn’t involve disproportionate effort.

The right to correct inaccurate personal information

You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.

The right to opt out of sale or sharing of personal information and to limit the use of your sensitive personal information

You have the right to opt out of the sale or sharing of your personal information. You also have the right to request that we limit our use or disclosure of your sensitive personal information.

The right of no retaliation following opt-out or exercise of other rights (the right to non-discrimination)

We will not discriminate against you for exercising your rights under the CCPA. This means that we will not discriminate against you, including, but not limited to, by denying goods or services, charging you a different price, or providing a different level or quality of goods or services just because you exercised your consumer privacy rights.

However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction.

To the extent permitted by the law, we may offer you promotions, discounts, and other deals in exchange for collecting, keeping, or selling your personal information, provided that the financial incentive offered is reasonably related to the value of your personal information.

How to exercise your rights

To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.

For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:

provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will use any personal information collected from you in connection with the verification of your request solely for the purposes of verification and shall not further disclose the personal information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.

If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.

You can submit a maximum number of 2 requests over a period of 12 months.

How and when we are expected to handle your request

We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.

We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Our disclosure(s) will cover the preceding 12-month period. Only with regard to personal information collected on or after January 1, 2022, you have the right to request that we disclose information beyond the 12-month period, and we will provide them to you unless doing so proves impossible or would involve a disproportionate effort.

Should we deny your request, we will explain you the reasons behind our denial.

We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.

Information for Virginia consumers

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the Commonwealth of Virginia, according to the “Virginia Consumer Data Protection Act" (the "VCDPA"), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the terms “personal data” (and “sensitive data”) as defined in the VCDPA.

Categories of personal data processed

In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.

Categories of personal data we collect

We have collected the following categories of personal data: identifiers, commercial information, internet information, geolocation data, sensorial information and inferred information

With your consent, we collect the following categories of sensitive data: VAT Number and Social Security number (SSN)

You can freely give, deny or withdraw your consent for the processing of sensitive data at any time using the contact details provided in this document or via the privacy choices link provided on Sailsquare.

We will not collect additional categories of personal data without notifying you.

Why we process your personal data

To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.

How we use the data we collect: sharing of your personal data with third parties

We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word "third party" means "a natural or legal person, public authority, agency, or body other than the consumer, controller, processor, or an affiliate of the processor or the controller" as defined by the VCDPA.

Sale of your personal data

For our purposes, the word “sale” means any “exchange of personal data for monetary consideration by us to a third party“ as defined by the VCDPA.
Please note that according to the VCDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale.
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal information may be considered a sale under VCDPA.

Your right to opt out of the sale of your personal data and how you can exercise it

You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request. To fully exercise your right to opt out you can contact us at any time using the contact details provided in this document.

We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.

Processing of your personal data for targeted advertising

For our purposes, the word "targeted advertising" means "displaying advertisements to you where the advertisement is selected based on personal data obtained from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests" as defined by the VCDPA.

To find out more details on the processing of your personal data for targeted advertising purposes, you can read the section titled “Detailed information on the processing of Personal Data” within this document.

Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it

You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request. To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.

We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.

Your privacy rights under the Virginia Consumer Data Protection Act and how to exercise them

You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:

access personal data: the right to know. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
request the deletion of your personal data. You have the right to request that we delete any of your personal data.
obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
non-discrimination. We will not discriminate against you for exercising your rights under the VCDPA. This means that we will not, among other things, deny goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your consumer privacy rights. However, if you refuse to provide your personal data to us or ask us to delete or stop selling your personal data, and that personal data or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction. To the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if you have exercised your right to opt out, or our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

How to exercise your rights

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we need to know who you are.

We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relates to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.

Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.

If you are an adult, you can make a request on behalf of a minor under your parental authority.

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 60 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.

We do not charge a fee to respond to your request, for up to two requests per year. If your request is manifestly unfounded, excessive or repetitive, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through Sailsquare (or third-party services employed in Sailsquare), which can include: the IP addresses or domain names of the computers utilized by the Users who use Sailsquare, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using Sailsquare who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Sailsquare. The Data Controller, unless otherwise specified, is the Owner of Sailsquare.

Sailsquare (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by Sailsquare as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to Sailsquare, if not stated otherwise within this document.

Latest update: March 03, 2023

Cookie Policy of Sailsquare

This document informs Users about the technologies that help Sailsquare to achieve the purposes described below. Such technologies allow the Owner to access and store information (for example by using a Cookie) or use resources (for example by running a script) on a User’s device as they interact with Sailsquare.

For simplicity, all such technologies are defined as "Trackers" within this document – unless there is a reason to differentiate.
For example, while Cookies can be used on both web and mobile browsers, it would be inaccurate to talk about Cookies in the context of mobile apps as they are a browser-based Tracker. For this reason, within this document, the term Cookies is only used where it is specifically meant to indicate that particular type of Tracker.

Some of the purposes for which Trackers are used may also require the User's consent. Whenever consent is given, it can be freely withdrawn at any time following the instructions provided in this document.

Sailsquare uses Trackers managed directly by the Owner (so-called “first-party” Trackers) and Trackers that enable services provided by a third-party (so-called “third-party” Trackers). Unless otherwise specified within this document, third-party providers may access the Trackers managed by them.
The validity and expiration periods of Cookies and other similar Trackers may vary depending on the lifetime set by the Owner or the relevant provider. Some of them expire upon termination of the User’s browsing session.
In addition to what’s specified in the descriptions within each of the categories below, Users may find more precise and updated information regarding lifetime specification as well as any other relevant information – such as the presence of other Trackers - in the linked privacy policies of the respective third-party providers or by contacting the Owner.

To find more information dedicated to Californian consumers and their privacy rights, Users may read the privacy policy.

Activities strictly necessary for the operation of Sailsquare and delivery of the Service

Sailsquare uses so-called “technical” Cookies and other similar Trackers to carry out activities that are strictly necessary for the operation or delivery of the Service.

Other activities involving the use of Trackers

Basic interactions & functionalities

Sailsquare uses Trackers to enable basic interactions and functionalities, allowing Users to access selected features of the Service and facilitating the User's communication with the Owner.

Interaction with support and feedback platforms

Zendesk Widget (Zendesk)

The Zendesk Widget is a service for interacting with the Zendesk support and feedback platform provided by Zendesk Inc.

Personal Data processed: Cookies and Usage Data.

Place of processing: US – Privacy Policy.

Experience enhancement

Sailsquare uses Trackers to provide a personalized user experience by improving the quality of preference management options, and by enabling interaction with external networks and platforms.

Displaying content from external platforms

Google Maps widget (Google Inc.)

Personal Data processed: Cookies and Usage Data.

Place of processing: US – Privacy Policy.

YouTube video widget (Google Inc.)

Personal Data processed: Cookies and Usage Data.

Place of processing: US – Privacy Policy.

Storage duration:

PREF: 8 months
VISITOR_INFO1_LIVE: 8 months
YSC: duration of the session

Interaction with online survey platforms

Hotjar Poll & Survey widgets (Hotjar Ltd.)

Personal Data processed: Cookies, Usage Data and various types of Data.

Place of processing: Malta – Privacy Policy – Opt Out.

Storage duration:

_hjAbsoluteSessionInProgress: 30 minutes
_hjCachedUserAttributes: duration of the session
_hjClosedSurveyInvites: 1 year
_hjDonePolls: 1 year
_hjFirstSeen: duration of the session
_hjIncludedInPageviewSample: 30 minutes
_hjIncludedInSessionSample: 30 minutes
_hjLocalStorageTest: duration of the session
_hjMinimizedPolls: 1 year
_hjRecordingEnabled: duration of the session
_hjRecordingLastActivity: duration of the session
_hjSession*: 30 minutes
_hjSessionRejected: duration of the session
_hjSessionResumed: duration of the session
_hjSessionTooLarge: duration of the session
_hjSessionUser*: 1 year
_hjShownFeedbackMessage: 1 year
_hjTLDTest: duration of the session
_hjUserAttributesHash: duration of the session
_hjViewportId: duration of the session
_hjid: 1 year

Measurement

Sailsquare uses Trackers to measure traffic and analyze User behavior with the goal of improving the Service.

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Google Inc.)

Personal Data processed: Cookies and Usage Data.

Place of processing: US – Privacy Policy – Opt Out.

Storage duration:

AMP_TOKEN: 1 hour
_ga: 2 years
_gac*: 3 months
_gat: 1 minute
_gid: 1 day

Google Ads conversion tracking (Google Inc.)

Personal Data processed: Cookies and Usage Data.

Place of processing: US – Privacy Policy.

Storage duration:

IDE: 2 years
test_cookie: 15 minutes

Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.)

Personal Data processed: Cookies and Usage Data.

Place of processing: US – Privacy Policy.

Storage duration:

_fbp: 3 months
fr: 3 months

Google Analytics Advertising Reporting Features

Users can opt out of Google's use of cookies by visiting Google's Ads Settings.

Personal Data processed: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Storage duration:

IDE: 2 years
_gcl_*: 3 months
test_cookie: 15 minutes

User ID extension for Google Analytics (Google Inc.)

Personal Data processed: Cookies.

Place of processing: US – Privacy Policy – Opt Out.

Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)

Personal Data processed: Cookies and Usage Data.

Place of processing: Malta – Privacy Policy – Opt Out.

Storage duration:

_hjAbsoluteSessionInProgress: 30 minutes
_hjCachedUserAttributes: duration of the session
_hjClosedSurveyInvites: 1 year
_hjDonePolls: 1 year
_hjFirstSeen: duration of the session
_hjIncludedInPageviewSample: 30 minutes
_hjIncludedInSessionSample: 30 minutes
_hjLocalStorageTest: duration of the session
_hjMinimizedPolls: 1 year
_hjRecordingEnabled: duration of the session
_hjRecordingLastActivity: duration of the session
_hjSession*: 30 minutes
_hjSessionRejected: duration of the session
_hjSessionResumed: duration of the session
_hjSessionTooLarge: duration of the session
_hjSessionUser*: 1 year
_hjShownFeedbackMessage: 1 year
_hjTLDTest: duration of the session
_hjUserAttributesHash: duration of the session
_hjViewportId: duration of the session
_hjid: 1 year

TikTok conversion tracking

Personal Data processed: Trackers.

Place of processing: United States – Privacy Policy; United Kingdom – Privacy Policy; Ireland – Privacy Policy.

Anonymized analytics services

The services contained in this section allow the Owner, through the use of third-party Trackers, to collect and manage analytics in an anonymized form.

Google Analytics with anonymized IP (Google Inc.)

Personal Data processed: Cookies and Usage Data.

Place of processing: US – Privacy Policy – Opt Out.

Storage duration:

AMP_TOKEN: 1 hour
_ga: 2 years
_gac*: 3 months
_gat: 1 minute
_gid: 1 day

Content performance and features testing (A/B testing)

Google Optimize (Google Inc.)

Google Optimize is an A/B testing service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, ("Google").

Google may use Personal Data to contextualize and personalize the ads of its own advertising network.

Personal Data processed: Cookies and Usage Data.

Place of processing: US – Privacy Policy.

Storage duration:

_gaexp: 3 months
_opt_awcid: 1 day
_opt_awgid: 1 day
_opt_awkid: 1 day
_opt_awmid: 1 day
_opt_expid: 10 seconds
_opt_utmc: 1 day

Heat mapping and session recording

Hotjar Heat Maps & Recordings (Hotjar Ltd.)

Personal Data processed: Cookies, Usage Data and various types of Data as specified in the privacy policy of the service.

Place of processing: Malta – Privacy Policy – Opt Out.

Storage duration:

_hjAbsoluteSessionInProgress: 30 minutes
_hjCachedUserAttributes: duration of the session
_hjClosedSurveyInvites: 1 year
_hjDonePolls: 1 year
_hjFirstSeen: duration of the session
_hjIncludedInPageviewSample: 30 minutes
_hjIncludedInSessionSample: 30 minutes
_hjLocalStorageTest: duration of the session
_hjLocalStorageTest: duration of the session
_hjMinimizedPolls: 1 year
_hjRecordingEnabled: duration of the session
_hjRecordingLastActivity: duration of the session
_hjSession*: 30 minutes
_hjSessionRejected: duration of the session
_hjSessionResumed: duration of the session
_hjSessionTooLarge: duration of the session
_hjSessionUser*: 1 year
_hjShownFeedbackMessage: 1 year
_hjTLDTest: duration of the session
_hjUserAttributesHash: duration of the session
_hjViewportId: duration of the session
_hjid: 1 year

Targeting & Advertising

Sailsquare uses Trackers to deliver personalized marketing content based on User behavior and to operate, serve and track ads.

Advertising

Google AdSense (Google Inc.)

In order to understand Google's use of data, consult Google's partner policy.

Personal Data processed: Cookies and Usage Data.

Place of processing: US – Privacy Policy – Opt Out.

Storage duration:

AID: 2 years
ANID: 2 years
Conversion: 3 months
DSID: 14 days
FCNEC: 1 year
FLC: 10 seconds
FPAU: 3 months
FPGCLAW: 3 months
FPGCLDC: 3 months
FPGCLGB: 3 months
IDE: 2 years
NID: 6 months
RUL: 1 year
TAID: 14 days
__gads: 2 years
__gsas: 2 years
_gac_: 3 months
_gac_gb_: 3 months
_gcl_au: 3 months
_gcl_aw: 3 months
_gcl_dc: 3 months
_gcl_gb: 3 months
_gcl_gf: 3 months
_gcl_ha: 3 months
id: 2 years
test_cookie: 15 minutes

Facebook Audience Network (Meta Platforms Ireland Limited)

Facebook Audience Network is an advertising service provided by Meta Platforms Ireland Limited In order to understand Facebook's use of Data, consult Facebook's data policy.

Personal Data processed: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.

Place of processing: Ireland – Privacy Policy – Opt Out.

Microsoft Advertising (Microsoft Corporation)

Microsoft Advertising is an advertising service provided by Microsoft Corporation.

Personal Data processed: Cookies and Usage Data.

Place of processing: US – Privacy Policy – Opt Out.

Storage duration:

MUID: 2 years
_uetmsclkid: 3 months
_uetmsclkid: indefinite
_uetsid: 1 day
_uetsid: indefinite
_uetvid: 2 years
_uetvid: indefinite

Remarketing and behavioral targeting

Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

Google Ads Remarketing (Google Inc.)

Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.

Personal Data processed: Cookies and Usage Data.

Place of processing: US – Privacy Policy – Opt Out.

Storage duration:

AID: 2 years
ANID: 2 years
Conversion: 3 months
DSID: 14 days
FCNEC: 1 year
FLC: 10 seconds
FPAU: 3 months
FPGCLAW: 3 months
FPGCLDC: 3 months
FPGCLGB: 3 months
IDE: 2 years
NID: 6 months
RUL: 1 year
TAID: 14 days
__gads: 2 years
__gsas: 2 years
_gac_: 3 months
_gac_gb_: 3 months
_gcl_au: 3 months
_gcl_aw: 3 months
_gcl_dc: 3 months
_gcl_gb: 3 months
_gcl_gf: 3 months
_gcl_ha: 3 months
id: 2 years
test_cookie: 15 minutes

Remarketing with Google Analytics (Google Inc.)

Personal Data processed: Cookies and Usage Data.

Place of processing: US – Privacy Policy – Opt Out.

Storage duration:

test_cookie: 15 minutes
IDE: 2 years
_gcl_*: 3 months

Facebook Custom Audience (Facebook, Inc.)

Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.

Personal Data processed: Cookies and email address.

Place of processing: US – Privacy Policy – Opt Out.

Storage duration:

_fbp: 3 months

Facebook Remarketing (Facebook, Inc.)

Personal Data processed: Cookies and Usage Data.

Place of processing: US – Privacy Policy – Opt Out.

Storage duration:

_fbp: 3 months

TikTok Remarketing

Personal Data processed: device information, Trackers, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.

Place of processing: United Kingdom – Privacy Policy; United States – Privacy Policy; Ireland – Privacy Policy.

There are various ways to manage Tracker related preferences and to provide and withdraw consent, where relevant:

Users can manage preferences related to Trackers from directly within their own device settings, for example, by preventing the use or storage of Trackers.

Additionally, whenever the use of Trackers is based on consent, Users can provide or withdraw such consent by setting their preferences within the cookie notice or by updating such preferences accordingly via the relevant consent-preferences widget, if available.

It is also possible, via relevant browser or device features, to delete previously stored Trackers, including those used to remember the User’s initial consent.

Other Trackers in the browser’s local memory may be cleared by deleting the browsing history.

With regard to any third-party Trackers, Users can manage their preferences and withdraw their consent via the related opt-out link (where provided), by using the means indicated in the third party's privacy policy, or by contacting the third party.

Locating Tracker Settings

Users can, for example, find information about how to manage Cookies in the most commonly used browsers at the following addresses:

Users may also manage certain categories of Trackers used on mobile apps by opting out through relevant device settings such as the device advertising settings for mobile devices, or tracking settings in general (Users may open the device settings and look for the relevant setting).

How to opt out of interest-based advertising

Notwithstanding the above, Users may follow the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar services. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.

The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.

Consequences of denying consent

Users are free to decide whether or not to grant consent. However, please note that Trackers help Sailsquare to provide a better experience and advanced functionalities to Users (in line with the purposes outlined in this document). Therefore, in the absence of the User's consent, the Owner may be unable to provide related features.

Owner and Data Controller

Sailsquare Srl - Società Benefit – Via Aosta 4, Milan - Italy

Owner contact email: hello@sailsquare.com

Since the use of third-party Trackers through Sailsquare cannot be fully controlled by the Owner, any specific references to third-party Trackers are to be considered indicative. In order to obtain complete information, Users are kindly requested to consult the privacy policies of the respective third-party services listed in this document.

Given the objective complexity surrounding tracking technologies, Users are encouraged to contact the Owner should they wish to receive any further information on the use of such technologies by Sailsquare.

Definitions and legal references

Personal Data (or Data)

Usage Data

User

The individual using Sailsquare who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

Sailsquare (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by Sailsquare as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to Sailsquare, if not stated otherwise within this document.

Latest update: March 03, 2023