Sailthru is part of the CM Group family of brands (“Sailthru”, “we”, or “us”) that provides Software-as-a-Service (SaaS) and software products (“Services”) to our customers and clients (“Customers”). We may disclose your information to affiliates within the CM Group for customer support, marketing, technical operations, and account management purposes.
This Privacy Statement (“Privacy Statement”) describes how Sailthru collect, uses, discloses, and transfers information, including personal information, from users accessing and using our websites that display a link to this Privacy Statement (“Sites”). The Privacy Statement also describes Sailthru’s collection and use of information in providing the Services. This Privacy Statement does not govern collection or use of information you provide to third parties, such as our Customers. You should refer to these third parties’ separate privacy policies to learn about their collection and use of your information.
Personal Information: In accessing and using the Sites or the Services, you may be prompted to provide Sailthru your name, email address, telephone number, job title, company name, and other personal information.
Other Information: Sailthru may collect information about your computer or mobile device that may include your browser or operating system, your manner of connecting to the Internet and the name of your Internet service provider or wireless carrier; your Internet Protocol (IP) address or Advertising Identifier; information about websites you used before or after using the Sites or Services; data relating to malfunctions or problems occurring when you use our Sites or Services, other information specifically related to your use of Services, including information that you publicly post using tools made available by us; location information; and information about the searches you perform on our Sites or when using the Services and how you use the results of those searches To collect this information, Sailthru and Sailthru’s business partners may use tracking technologies, including cookies and web beacons.
We do not rent or sell your personal information (such as name, address and telephone number) to third parties for their marketing purposes. We may share your information with third parties to provide products and services you have requested, when we have your consent, or as described in this Privacy Statement.
We may share aggregated, non-personally identifiable information, publicly and with our Customers and partners. For example, we may share information publicly to show trends about the general use of our services.
The contents of your online communications, as well as other information about you as a user of our Services, may be accessed and disclosed under the following circumstances: in response to lawful governmental requests or legal process (for example, a court order, search warrant or subpoena), in other circumstances in which we have a good faith belief that a crime has been or is being committed by a user of our Services, that an emergency exists that poses a threat to the safety of you or another person, when necessary either to protect our rights or property, or for us to render the service you have requested.
Many of our services let you share information with others. Remember that when you share information publicly, others besides us have access to it, and it may be indexable by search engines, or copied, forwarded or archived by others. Our offerings may include features or functionalities provided by third parties. In the process of providing such functionalities within our Services, your browser may automatically send certain technical information to the third party provider. The use of these third-party provided features or functionalities is subject to their own privacy policies. Business partners or other third parties may receive data about groups of our users, but do not receive information that personally identifies you.
We may use agents and contractors in order to help operate our Services. Their use of information is limited to these purposes.
In the event that Sailthru’s ownership changes as a result of a merger, acquisition, reorganization, sale of assets, dissolution, or similar event, information we collect may be part of the transferred assets. If such a transfer results in a material change in the use of your information, you will be provided notice (which may be via updates to this page) about the choices you have to decline to permit such a transfer.
Sailthru primarily stores and processes the personal information we collect in the United States. As a global company, Sailthru may transfer and access information from around the world, including from other countries in which Sailthru operates. If you operate outside of the United States, transfer of your data is necessary for you to use our Services, access our Sites, or request information from us. By registering for our Sites or accessing the Services, or by communicating with us by email, you acknowledge and expressly consent to our cross border transfer of your personal information. By registering for the Site, by subscribing to our Services, or by emailing us, you expressly agree to the processing of your personal information as described in this Privacy Statement.
By emailing us or by opting-in to use the Site or access the Services you expressly consent to the collection, use, retention, transfer and disclosure, including cross-border disclosure, of your information as described in this Privacy Statement. Each time you email us, register with us, or use our services you are giving your express consent to the collection, use, retention, transfer and disclosure, including cross-border disclosure, of your information as described in this Privacy Statement.
If you wish to opt out and withdraw your consent, you may do so at any time by contacting us at: firstname.lastname@example.org. If you opt out and withdraw your consent you will no longer be able to use our Services and we will not have any means by which to respond to your questions or comments that you email to the Site. In addition, if you wish to correct, update, amend, or remove your personal information that Sailthru controls, you may contact us by emailing to email@example.com.
A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use both session ID cookies and persistent cookies on our Site. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. If you wish to deactivate cookies while visiting our Site during your browsing session, please see "How to Control Cookies" below. Please note that you may need to erase all cookies that have already been placed on your computer in order to delete the Sailthru cookie.
Please note that Internet browsers allow you to change your cookie settings. These settings are usually found in the ‘options’ or ‘preferences’ menu of your Internet browser. In order to understand these settings, the following links may be helpful. Otherwise you should use the ‘Help’ option in your Internet browser for more details.
For more detailed information on how to control cookies you may wish to visit www.allaboutcookies.org
We will retain your personal information for as long as needed for the uses described in this Privacy Statement.
Sailthru uses third party services including Google Analytics, to collect information about how visitors use the Site in order to optimize visitor experiences. Google Analytics uses web beacons and cookies in order to track visitor page views and clicks within pages, length of time spent on our Sites , and the search term or referring site that brought a visitor to our Site.
Our Sites include features from social media websites such as the Facebook Like button and features on LinkedIn and Twitter that run on our Site. These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Site. This Privacy Statement does not apply to these features. Your interactions with these features are governed by the Privacy Statement and other policies of the companies providing them.
Sailthru takes reasonable precautions to protect personal information from loss, misuse, unauthorized access, disclosure, alteration and destruction. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. For example, to protect your privacy and security, we may use passwords or other technologies to register or authenticate you and enable you to use our Services, and before granting access or making corrections to your information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
The California Consumer Privacy Act (“CCPA”) provides consumers, as defined in the text of CCPA, certain privacy rights:
This privacy notice provides descriptions of the types of information we collect, the reasons for its collection, and the parties to whom we disclose that information and for what reasons. California consumers who are users of Sailthru’s services, website visitors, or recipients of emails from Sailthru may, no more than twice in a 12 month period and at no cost to them, request a report from Sailthru which details the personal information collected about them and the recipients, if any, of that information. Requests may be sent to firstname.lastname@example.org or direct mail to the address:
One World Trade Center. Suite 48A.
New York, NY 10007
California consumers may, at any time, request that Sailthru delete their personal data via the same email or direct mail address listed above. Our subscribers may visit the Sailthru Preference Center at any time to access personal data processed for that purpose, amend such data, and alter their marketing choices.
Sailthru shares the Personal Information of our Users and Website Visitors with other Affiliates of CM Group, as described in their respective privacy notices, for the purposes of marketing and selling CM Group Affiliate Services. You may, at any time, request that your information not be shared between CM Group Affiliates for commercial purposes by request to email@example.com or via this form:
To learn more about the Privacy Shield program, and to view Sailthru’s certification, please visit www.privacyshield.gov
Sailthru’s commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
If you believe Sailthru maintains your personal data, you may direct any inquiries or complaints concerning our Privacy Shield compliance to firstname.lastname@example.org. Sailthru will respond within 45 days. If we fail to respond within that time, or if our response does not address your concern, you may contact the International Centre for Dispute Resolution ("ICDR/AAA"), which Sailthru has chosen as its independent recourse mechanism, via its via the contact information provided below. ICDR/AAA provides an independent third-party dispute resolution body and has committed to respond to complaints and to provide appropriate recourse at no cost to you. If you feel that neither Sailthru nor ICDR/AAA can resolve your complaint, you may seek to engage in binding arbitration through the Privacy Shield Panel.
EU and Swiss individuals have the right to access the personal data Sailthru processes pertaining to them and to limit use and disclosure of their personal data. EU and Swiss data subjects may receive notice of Sailthru's processing of their personal data, access to that personal data, and seek to amend that personal data by request to email@example.com.
If you believe a Sailthru Customer transferred your personal data to Sailthru, in making a request please provide the name of the Customer. We will refer your request to that Customer, and assist them as needed in responding to your request.
In providing access and use of our Services and Sites, Sailthru utilizes third parties that may access, process, or store personal information in the course of providing their services. Our agreements with these third parties require their access, use, and processing of personal information is in compliance with our Privacy Shield obligations. If either Sailthru or these third parties processes such personal data in a manner inconsistent with the Privacy Shield Principles, Sailthru will be liable. In the following limited situations, we may disclose information that we collect or that you provide to us:
Sailthru may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Since there is no uniform technological standard for "Do Not Track", our Sites does not respond to browser "Do Not Track" signals.
For more information: http://www.allaboutdnt.com/.
January 9. 2020
What did we change?
We last updated our Privacy Statement on January 9, 2020. We made changes to provide information about the California Consumer Privacy Act.
We may change this policy from time to time by updating this page. You should check this page from time to time to keep up to date with any changes. If you do not agree to any changes, you should immediately stop using the Services.