Sailthru, Inc. (“Sailthru,” “we,” “us,” “our”) has created this privacy statement to demonstrate our firm commitment to privacy and the protection of sensitive information (“Privacy Statement”). This Privacy Statement describes the policies and procedures applicable to the collection, use and disclosure of information collected on our website http://www.sailthru.com
(the “Site”) as well as through email service and our service platform https://my.sailthru.com
(collectively with the Site, the “Service”). We receive information about you from various sources, including: (i) if you register for the Service (your “Account”); (ii) email and your use of the Service generally; (iii) from third party websites and services who have an Account with us; (iv) your browser if you visit the Site; and (iv) from third party websites and services who provide services to us. When you use the Service, you are consenting to the collection, transfer, analysis, storage, disclosure and other uses of your information as described in this Privacy Statement. This Privacy Statement also covers the treatment of personally identifiable information (“Personal Information”) gathered when you are using or accessing the Service and our treatment of any Personal Information that our business partners share with us or that we share with our business partners. This Privacy Statement does not apply to the practices of third parties that we do not own or control or do business with, including but not limited to any third party websites, services and applications (“Third Party Services”) that you elect to access through the Service, or to persons that we do not employ or manage. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy statements of those Third Party Services. We encourage you to carefully review the privacy statements of any Third Party Services you access.
EU and Swiss Safe Harbor
Sailthru complies with the U.S.–E.U. Safe Harbor framework and the U.S.--Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. Sailthru has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Sailthru’s certification, please visit http://www.export.gov/safeharbor/.
Information Collected by Sailthru and How We Use It
The information we collect enables us to personalize, improve and continue to operate the Service. In connection with certain aspects of the Service, we may request, collect and/or display some of your Personal Information. We collect the following types of information from visitors to our Site, Account Holders (defined below)and their visitors or subscribers: Visitors to our Site
Visitors to our Site are not required to submit their information or register for an Account. However, when you inquire about our services, post a comment to our blog, or apply for employment with us, you may provide information that could be Personal Information such as your name, email address, phone number, physical address, company information and work history. You acknowledge that this information may be personal to you, and by engaging in the aforementioned activities and providing Personal Information to us, you allow others, including us, to identify you and therefore may not be anonymous. We may use this information to respond to your requests, send you email communications, or enable you to use features on our Site.We also collect statistical information about how both visitors and registered users, collectively, use the Service (“Aggregate Information”). Some of this information is derived from Personal Information. Please visit our Cookie Statement for more information on the technologies we use on the Site. Account Holders
In order for you to view our Site, you are not required to register; however, you must register to take advantage of the Service. To register, you must create an Account which requires you to provide information that could be Personal Information, such as your email address, a username and password, and information about your business, including billing information (the treatment of which is described below) (all registrants are deemed "Account Holders"). Once you become an Account Holder, we will ask you for your list of subscriber names and email addresses ("Subscriber Data").You acknowledge that this information may be personal to you, and by creating an Account and providing Personal Information and Subscriber Data to us, you allow us and our partners or service providers to identify you and your subscribers. We receive and store on our servers any information you enter on the Service or provide to us in any other way. Account Holder data and Subscriber Datails used for such purposes such as delivering the Service, responding to your requests for services, onboarding, support to your account and communicating with you about new products and services. This information is stored on our servers. Only an authorized representative of an Account Holder may access its Account Holder data or Subscriber Data and we will not rent, sublicense or sell Account Holder data or Subscriber Data without authorization from the Account Holder. Sailthru will use Subscriber Data solely to provide the Service, such as submitting email communications to your list of subscribers on your behalf (as discussed in the section on Email Communications below). An Account Holder’s payment method (such as valid credit card number, type, expiration date or other financial information) may be collected and stored by our third party payment processing company (the “Payment Processor”), and use and storage of that information is governed by the Payment Processor’s applicable terms of service and privacy statement. Subscribers; Visitors to Account Holder’s Website
Sailthru offers its Account Holders an email monitoring and delivery service and an email authentication service. On behalf of our Account Holders, we send out emails with news and/ or promotions, transaction receipts or account information. We receive a confirmation when each Account Holder’s subscriber opens an email from Sailthru. In addition, our Service allows us to collect inferred data about the subscriber, which allows us to, among other things, personalize our Account Holder’s emails and personalize the subscriber’s or visitor’s experience while browsing the Account Holder’s website or applications. We also provide a content slider for certain of our Account Holders. The content slider does not install code on a subscriber’s or visitor’s computer nor does it attempt to contact the individual. If you wish to temporarily disable the slider, simply press the “x” button located in the content slider.
Cookies and Other Technologies
Disclosure of Information
The information obtained from visitors to our Site, our Account Holders, and their visitors and subscribers is an integral part of our business. Except as described below, we neither rent nor sell your Personal Information or the Subscriber Data of our Account Holders to anyone. We share the information we collect only as described within this Privacy Statement. We may share your information:
- to other agents or service providers to perform tasks on our behalf. Examples include analyzing data, providing marketing assistance, and providing customer service. Unless we tell you differently, our agents do not have any right to use the personal information we share with them beyond what is necessary to assist us.
- as required by law, such as to comply with a subpoena, or similar legal process.
- when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
- to any other third party with your prior consent to do so.
In some cases, we may choose to buy or sell assets. In these types of transactions, Personal Information and Subscriber Data may be the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, Personal Information and Subscriber Data would be assets that are transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information and Subscriber Data as set forth in this Privacy Statement.
If you do not wish to receive emails from Sailthru, please follow the unsubscribe instructions included in each communication or contact us at email@example.com.
Access to Information Visitors to our Site and Account Holders
Visitors to our Site can access and delete cookies through their web browser settings. If your Personal Information changes, you may correct, update, delete, or ask to have it removed from our blog by contacting us via one of the methods listed below. Account Holders may be able to make these changes within their account settings. When you update information, however, we often maintain a copy of the unrevised information in our records. You may request deletion of your Account by sending an email to firstname.lastname@example.org.
Please note that some information may remain in our records after deletion of your Account. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why. We will respond to your request to access within 30 days. Subscribers
Sailthru has no direct relationship with the Account Holder’s subscribers whose data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to Sailthru’s Account Holder (the data controller). If the Account Holder requests Sailthru to remove the data, we will respond to their request within 30 business days. California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: Privacy Officer, Sailthru, 160 Varick St., 12th floor New York, NY 10013.
Sailthru will retain the data we collect on our Site, the data we collect through our Service, and the data we process on behalf of our Account Holders for as long as needed to provide our Services. Sailthru will retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Personally Identifiable Information
Sailthru defines "personally identifiable information" to mean non-public, unencrypted data that identifies an individual. The definition of what is personally identifiable information varies depending on the laws of the state or country in which you reside.
Information Your Subscribers Might Want to Know:
We may obtain Personal Information from our Account Holders and their subscribers. Sailthru only discloses Personal Information to Account Holders who engage Sailthru to process data on their behalf and have received the appropriate consent. Due to the global nature of services provided by Sailthru, the Personal Information you provide may be transmitted, used, stored and otherwise processed outside of the country where you submitted that information, including jurisdictions that may not have data privacy laws that provide equivalent protection to such laws in your home country.
We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. If you enter Personal Information (such as a credit card number) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). To learn more about SSL, follow this link: http://www.thawte.com/resources/ssl-information-center/get-started-with-ssl/index.html.
No method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personally Identifiable Information, we cannot guarantee its absolute security.
In no case whatsoever will Sailthru’s liability exceed the amount of monies paid for services nor will Sailthru be liable for indirect, special, or consequential damages of any kind to any party.
Other Information Information We Share With Your Consent
Except as set forth above, you will be notified when your Personal Information may be shared with any other third party, and you will be able to prevent the sharing of this information. Links to Third Party Sites
The Serviceinclude links to other websites whose privacy practices may differ from those of Sailthru. If you submit any of your own data to any of those sites, your data is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit. Blog
Our website offers publicly accessible blogs. You should be aware that any information you provide in these areas may be read, collected, used and disclosed by others who access that information, and search engines may index that information. Testimonials
With your consent we may post your testimonial along with your name. You can request the deletion of your testimonial by contacting us via one of the methods listed below. Co-branded sites
Some pages, such as our employment application pages, may have the look and feel of being on the Sailthru Site. However, the information collected on these pages may be shared and processed by our service provider. All information collected on www.sailthru.com
is owned and controlled by us. Social Media Widgets
You can log in to our site using an Open ID provider. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form. Services like these give you the option to post information about your activities on this website to your profile page to share with others within your network.
Privacy Statement Changes
If this privacy statement changes in the future, we will provide notice by posting such notice on the Site. By continuing to use the Site and the Service after such notice has been posted, you will be deemed to have accepted the changes. If you do not agree to the changes, you have the option to terminate your account and have your data removed from our system. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a prominent notice within our Site or Service prior to the change becoming effective.
Phone: 877-812-8689 Email: email@example.com
Mail: 160 Varick St., 12th floor New York, NY 10013 Sailthru participates in the EU and Swiss Safe Harbor Privacy Framework as set forth by the United States Department of Commerce. As part of our participation in the safe harbor, we have agreed to TRUSTe dispute resolution for disputes relating to our compliance with the Safe Harbor Privacy Framework. If you have any complaints regarding our compliance with the Safe Harbor you should first contact us (as provided above). If contacting us does not resolve your complaint, you may raise your complaint with TRUSTe by Internet here, fax to 415-520-3420, or mail to TRUSTe Safe Harbor Compliance Dept., click for mailing address. If you are faxing or mailing TRUSTe to lodge a complaint, you must include the following information: the name of company, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaint shared with the company. For information about TRUSTe or the operation of TRUSTe's dispute resolution process, click here or request this information from TRUSTe at any of the addresses listed above.
Privacy Statement Last Updated
March 12, 2015 What did we change?
We last updated our Privacy Statement and Cookie Statement on March 12th 2015. We made changes to explain our Site's policy regarding Do Not Track signals.