1. INFORMATION WE COLLECT
There are three general categories of information we collect:
1.1 Information you give to us
1.1.1 Information that is necessary for the use of the Sailo website and/or mobile application
We ask for and collect the following personal information about you when you use the Sailo website and/or mobile application. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.
Account information. When you sign up for a Sailo account, we require certain information such as your first name, last name and email address.
Profile and Boat Listing information. To use certain features of the Sailo website and/or mobile application (such as booking a boat or creating a boat profile), we may ask you to provide additional information, which may include your address, phone number, and a profile picture.
Identity verification Information. To help create and maintain a trusted environment, we may collect identity verification information (such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other authentication information.
Payment information. To use certain features of the Sailo website and/or mobile application (such as booking a boat or creating a boat profile), we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments (via our 3rd party payment processors).
Communications with Sailo and other members. When you communicate with Sailo or use the Sailo website and/or mobile application to communicate with other members, we collect information about your communication and any information you choose to provide.
1.1.2 Information you choose to give us
You may choose to provide us with additional personal information in order to obtain a better user experience when using Sailo website and/or mobile application. This additional information will be processed based on your consent.
Additional profile information. You may choose to provide additional information as part of your Sailo profile (such as date of birth, language(s) spoken, and a personal description). Some of this information as indicated in your account settings is part of your public profile page, and will be publicly visible to others.
Address Book contact information. You may choose to import your address book contacts or enter your contacts’ information manually to access certain features of the Sailo website, like inviting them to use Sailo or to an event you organize using Sailo’s event tool.
Other information. You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your Sailo account, respond to surveys, post to community forums, participate in promotions, or use other features of the Sailo website and/or mobile application.
1.1.3 Information that is necessary for the use of the payment services
We need to collect the following information, as it is necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations):
Payment Information. Your financial information (like your bank account or credit card information) necessary to process payments and comply with applicable law.
Identity Verification and Other Information. We may require identity verification information (such as images of your government issued ID, passport, national ID card, or driving license) or other authentication information, your date of birth, your address, email address, phone number and other information in order to verify your identity.
1.2 Information automatically collected from your use of the Sailo website and/or mobile application
When you use Sailo website and/or mobile application, we automatically collect information, including personal information, about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Sailo website and mobile application.
Geo-location information. When you use certain features of Sailo website and mobile application we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. Sailo may also collect this information even when you are not using the mobile application if this connection is enabled through your settings or device permissions.
Usage information. We collect information about your interactions with Sailo website and mobile application such as the pages or content you view, your searches for boats, bookings you have made, and other actions on Sailo website and mobile application.
Log data and device information. We automatically collect log data and device information when you access and use Sailo website and mobile application, even if you have not created a Sailo account or logged in. That information includes, among other things: details about how you’ve used Sailo website and mobile application (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using Sailo website and mobile application.
Payment transaction information. Sailo collects information related to your payment transactions through Sailo website and mobile application, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, IBAN information, your address and other related transaction details. This information is necessary for the adequate performance of the contract between you, Sailo and the third party payment services providers.
1.3 Information we collect from third parties
Sailo may collect information, including personal information, that others provide about you when they use Sailo website and/or mobile application, or obtain information from other sources and combine that with information we collect through Sailo website and/or mobile application. We do not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.
Third party services. If you link, connect, or login to your Sailo account with a third party service (e.g. Google, Facebook), the third party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
Other sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Sailo website and/or mobile application through partnerships, or about your experiences and interactions from our partner ad networks.
2. HOW WE USE INFORMATION WE COLLECT
We use, store, and process information, including personal information, about you to provide, understand, improve, and develop the Sailo website and mobile application, create and maintain a trusted and safer environment and comply with our legal obligations.
2.1 Provide, improve, and develop Sailo website and mobile application
Enable you to access and use Sailo website and mobile application.
Enable you to communicate with other members.
Operate, protect, improve, and optimize Sailo website and mobile application and experience, such as by performing analytics and conducting research.
Provide customer service.
Send you service or support messages, updates, security alerts, and account notifications.
If you provide us with your contacts’ information, we may process this information: (i) to facilitate your referral invitations, (ii) for fraud detection and prevention, and (iii) for any purpose you authorize at the time of collection.
To operate, protect, improve, and optimize Sailo website and mobile application and experience, and personalize and customize your experience (such as making boats suggestions or ranking search results), we conduct profiling based on your interactions with the Sailo website and mobile application, your search and booking history, your profile information and preferences, and other content you submit to the Sailo website and mobile application.
We process this information given our legitimate interest in improving Sailo website and mobile application and the experience of our members with it, and where it is necessary for the adequate performance of the contract with you.
2.2 Create and maintain a trusted and safer environment
Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
Conduct security investigations and risk assessments.
Verify or authenticate information or identifications provided by you (such as to verify your boat address or compare your identification photo to another photo you provide).
Conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required.
Comply with our legal obligations.
Resolve any disputes with any of our members and enforce our agreements with third parties.
Enforce our Terms of Service and other policies.
In connection with the activities above, we may conduct profiling based on your interactions with Sailo website and mobile application, your profile information and other content you submit to Sailo website and mobile application, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to Sailo website and mobile application if such processes detect a member or activity that we think poses a safety or other risk to the Sailo website and mobile application, other members, or third parties.
We process this information given our legitimate interest in protecting Sailo website and mobile application, to measure the adequate performance of our contract with you, and to comply with applicable laws.
2.3 Provide, personalize, measure, and improve our advertising and marketing
Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Sailo or partner campaigns and services) and social media advertising through social media platforms such as Facebook, Google, Twitter, Instagram and LinkedIn).
Personalize, measure, and improve our advertising.
Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Sailo or its third party partners.
Conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with Sailo website and/or mobile application, information obtained from third parties, and your search and booking history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you.
We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your Sailo account.
2.4 How do we use your personal financial data
Enable you to send and receive payments via Sailo website and/or mobile application
Detect and prevent fraud, abuse, security incidents, and other harmful activity
Conduct security investigations and risk assessments
Conduct checks against databases and other information sources
Comply with legal obligations (such as anti-money laundering regulations)
Enforce the payment terms and other payment policies.
3. SHARING & DISCLOSURE
3.1 With your consent
Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your Sailo account or when you participate in promotional activities conducted by Sailo partners or third parties.
3.2 Sharing between members
To help facilitate bookings or other interactions between members, we may need to share certain information, including personal information, with other members, as it is necessary for the adequate performance of the contract between you and us, as follows:
When you as a Renter submit a booking request, certain information about you is shared with the Boat Owner, including your full name, and other information you agree to share. When your booking is confirmed, we will disclose additional information to assist with coordinating the trip, like your phone number.
When you as a Boat Owner have a confirmed booking, certain information is shared with the Renter to coordinate the booking, such as your full name, phone number, and pick-up and drop-off location.
We don’t share your billing and payout information with other members.
3.3 Profiles, boat listings, and other public information
Sailo website and mobile application allows you to publish information, including personal information, that is visible to the general public. For example:
Parts of your public profile page, such as your first name, your description, and city, are publicly visible to others.
Boat listings are publicly visible and include information such as the approximate location of the Boat Owner (City, State, Country), public profile photo, aggregated information such as (Response Rate and Response Time), and any additional information you choose to share.
After completing a booking, Renters and Boat Owners may write reviews and rate each other. Reviews and Ratings are a part of your public profile page and may also be surfaced elsewhere on the Sailo website and mobile application (such as the Boat Page).
If you submit content in a community or discussion forum, blog or social media post, or use a similar feature on Sailo website or mobile application, that content is publicly visible.
Based on our legitimate interest to promote Sailo we may display parts of Sailo website and mobile application (e.g., your Boat Page) on sites operated by Sailo’s business partners, using technologies such as widgets or APIs. If your Boat Page will be displayed on a partner’s site, information from your public profile page may also be displayed.
Information you share publicly on Sailo website and mobile application may be indexed through third party search engines. In some cases, you may opt-out of this feature in your Account settings. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.
3.4 Compliance with law, responding to legal requests, preventing harm and protection of our rights
Sailo website and mobile application may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Sailo, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Service or other agreements with Members, or (v) to protect the rights, property or personal safety of Sailo, its employees, its Members, or members of the public.
Where appropriate, we may notify members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Sailo’s property, its members and the Sailo website and mobile application. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that member about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.
3.5 Service Providers
Sailo website and mobile application use a variety of third party service providers to help us provide services related to the Sailo website and mobile application and payment processor partners (e.g. Stripe, MangoPay). Service providers may be located inside or outside of the European Economic Area (“EEA”). In particular, our service providers are based in Europe and North America.
Sailo website and mobile application will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.
3.6 Social media platforms
Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or Sailo website and mobile application. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest.
The social media platforms with which we may share your personal data are not controlled or supervised by Sailo. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such provider.
Please note that you may, at any time ask Sailo to cease processing your data for these direct marketing purposes by sending an e-mail to firstname.lastname@example.org.
3.7 Business Transfers
3.8 Aggregated data
We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
4. OTHER IMPORTANT INFORMATION
4.1 Analyzing your communications
We may review, scan, or analyze your communications on Sailo website and/or mobile application for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.
These activities are carried out based on Sailo's legitimate interest in ensuring compliance with applicable laws and our Terms of Service, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.
4.2 Linking third party accounts
You may link your Sailo account with your account at a third party social networking service. Your contacts on these third party services are referred to as “Friends.” When you create this link:;
your activities on Sailo website and/or mobile application may be displayed to your Friends on the Sailo website and/or mobile application and/or that third party site;
Other Sailo users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;
other Sailo users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking service;
the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes; and
the publication and display of information that you provide to Sailo through this linkage is subject to your settings and authorizations on Sailo website and/or mobile application and the third party site.
We only collect your information from linked third party accounts to the extent necessary to ensure the adequate performance of our contract with you, or to ensure that we comply with applicable laws, or with your consent.
5. THIRD PARTY PARTNERS & INTEGRATIONS
The Sailo website and/or mobile application may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). Sailo doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, Sailo, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.
6. YOUR RIGHTS
You may exercise any of the rights described in this section before Sailo by sending an email to email@example.com. Please note that we may ask you to verify your identity before taking further action on your request.
6.1 Managing your information
You may access and update some of your information through your account settings. If you have chosen to connect your Sailo account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your Account Settings. You are responsible for keeping your personal information up-to-date.
6.2 Rectification of inaccurate or incomplete information
You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your Sailo account).
6.3 Data access and portability
In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
6.4 Data retention and erasure
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the Sailo website and/or mobile application to you, you can request that we erase your personal information and close your Sailo account. Please note that if you request the erasure of your personal information:
We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a Sailo account for fraud or safety reasons, we may retain certain information from that Sailo account to prevent that member from opening a new Sailo account in the future.
We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Sailo may keep some of your information for tax, legal reporting and auditing obligations.
Information you have shared with others (e.g. reviews, comments, questions) may continue to be publicly visible on Sailo website and mobile application, even after your Sailo account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g. log records) may remain in our database, but are disassociated from personal identifiers.
Because we maintain Sailo website and mobile application to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
6.5 Withdrawing consent and restriction of processing
Where you have provided your consent to the processing of your personal information by Sailo you may withdraw your consent at any time by changing your Account Settings or by sending a communication to Sailo specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of Sailo override your own.
6.6 Objection to processing
In some jurisdictions, applicable law may entitle you to require Sailo not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing Sailo will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.
Where your personal information is processed for direct marketing purposes, you may, at any time ask Sailo to cease processing your data for these direct marketing purposes by sending an e-mail to firstname.lastname@example.org.
6.7 Lodging Complaints
You have the right to lodge complaints about the data processing activities carried out by Sailo before the competent data protection authorities.
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls.
Sailo uses end-to-end encryption for all pages served, so all information is encrypted and transmitted to us in a secure way. You can verify this by looking for a lock icon in the address bar and looking for "https" at the beginning of the address of the Web page.
For further security we do not store directly on our servers any sensitive payment information (such as credit card data); this information is stored by our payment services providers Stripe and Mangopay on secure servers.
While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment.
If you know or have reason to believe that your Sailo account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Sailo account, please contact us immediately at email@example.com.
9. CONTACT US
A cookie is a small data file that is transferred to your device (e.g. your phone or your computer). For example, a cookie could allow us to recognize your browser, while another could store your preferences. There are two types of cookies used on Sailo website and/or mobile application: (1) “session cookies” and (2) “persistent cookies.” Session cookies normally expire when you close your browser, while persistent cookies remain on your device after you close your browser, and can be used again the next time you access Sailo website and/or mobile application.
Why Sailo Uses These Technologies
We use these technologies for a number of purposes, such as:
To enable you to use and access Sailo website and/or mobile application.
To enable, facilitate and streamline the functioning of and your access to Sailo website and/or mobile application.
To better understand how you navigate through and interact with Sailo website and mobile application and to improve Sailo website and mobile application.
To serve you tailored advertising (on Sailo website and mobile application and on third party websites).
To show you content (e.g., advertisements) that is more relevant to you.
To monitor and analyze the performance, operation, and effectiveness of Sailo website and mobile application and Sailo advertisements.
To enforce legal agreements that govern use of Sailo website and mobile application.
For fraud detection and prevention, and investigations.
For purposes of our own customer support, analytics, research, product development, and regulatory compliance.
We may also allow certain business partners to place these technologies on Sailo website and mobile application. These partners use these technologies to (1) help us analyze how you use Sailo website and mobile application, such as by noting the third party services from which you arrived, (2) market and advertise Sailo services to you on Sailo website and mobile application and third party websites, (3) help us detect or prevent fraud or conduct risk assessments, or (4) collect information about your activities on Sailo website and mobile application, other sites, and/or the ads you have clicked on. For example, to help us better understand how people use Sailo website and mobile application, we work with a number of analytics partners, including Google Analytics. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser by clicking here.
Third parties may also use such tracking technologies to serve ads that they believe are most likely to be of interest to you and measure the effectiveness of their ads both on Sailo website and mobile application and on other websites and online services. Targeting and advertising cookies we use may include Google, and other advertising networks and services we use from time to time. For more information about targeting and advertising cookies and how you can opt out, you can visit the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or http://youronlinechoices.eu. To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. To the extent advertising technology is integrated into Sailo website and mobile application and you opt-out of tailored advertising, you may still receive advertising content. In that case, the advertising content will just not be tailored to your interests. Also, we do not control any of these opt-out links and are not responsible for the availability or accuracy of these mechanisms.
Third Party Social Plugins
The Sailo website and mobile application may use social plugins provided and operated by third parties, such as Facebook’s Like Button. As a result of this, you may send to the third party the information that you are viewing on a certain part of Sailo website and mobile application. If you are not logged into your account with the third party, then the third party may not know your identity. If you are logged in to your account with the third party, then the third party may be able to link information or actions about your interactions with Sailo website and mobile application to your account with them. Please refer to the third party’s privacy policies to learn more about its data practices.
Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar.
Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel.
Your mobile device may allow you to control cookies through its settings function. Refer to your device manufacturer’s instructions for more information.
If you choose to decline cookies, some parts of Sailo website and mobile application may not work as intended or may not work at all.