Privacy Policy

Sail Technologies LLC
Effective Date: 9 June 2026
Last updated: 15 September 2026

1. Introduction

Sail Technologies LLC ("Sail," "we," "us," or "our") helps hotels and restaurants reach
guests through search, social media, metasearch, and AI-powered discovery.

This Privacy Policy explains what personal information we handle, why, and what rights
you have. It covers our website at sailtech.ai, our free tools, and our marketing
services.

If you do not agree with this policy, please do not use our website or services.

2. Our two roles

We handle personal information in two distinct roles. Which role applies determines who
is responsible and who you should contact.

We are a controller when we decide why and how information is used. This covers:

• Visitors to sailtech.ai and our free tools

• People who contact us, request a demo, or subscribe to our communications

• Travel-intent data we license from third-party data providers

• Our own marketing, sales, and business operations

We are a processor when we act on a client's instructions. This covers the
advertising, analytics, and tracking work we perform for a specific hotel or restaurant
using that client's own data.

We keep client data separated. Information collected on behalf of one client is used
only for that client. We do not combine one client's data with another's, and we do not
use one client's data to build audiences for another client.

Where we act as a processor, the client is the controller and their privacy policy
governs. Requests about that data are answered under our agreement with them — see
section 10.

3. Information we handle

3.1 Information you give us

• Name, email address, phone number, and postal address

• Company or property name and your role

• The content of messages you send us

• Payment and billing details, where you are a client

3.2 Information collected automatically

When you visit our website or use our tools:

• IP address and approximate location derived from it

• Device identifiers, browser type and version, operating system

• Pages viewed, time on page, click and scroll activity

• Referring website and search terms that brought you to us

• Cookie and similar identifiers — see our Cookie Policy

3.3 Travel-intent data we license

We license data from third-party data providers about people who are actively
researching travel. This typically includes:

• A pseudonymous advertising or device identifier

• Signals that the person is researching travel

• The destination or region they are researching

• Approximate location and general demographic attributes

Where this comes from. We obtain this data from commercial data providers and
advertising data marketplaces. We do not collect it from you directly, and we require
each provider to confirm it was collected lawfully and with the consents its use
requires. To ask which providers supplied data relating to you, contact us at
hi@sailtech.ai.

What we do not do. We do not license or purchase data about health, finances,
religion, politics, sexual orientation, or any other special category. We do not build
audiences from a client's own guest records. We do not knowingly license data about
children.

3.4 Information from our clients

Hotels and restaurants give us access to their advertising accounts, analytics, and
website tracking so we can run campaigns for them. We handle that information as their
processor, only on their instructions, and only for that client.

4. How we use information

As a controller, we use information to:

1. Operate, secure, and improve our website and free tools

2. Respond to your enquiries and provide our services

3. Deliver and measure advertising, including matching travel-intent audiences to
   relevant campaigns

4. Send you marketing communications, where you have consented or where permitted by law

5. Process payments, keep accounts, and meet tax and legal obligations

6. Detect, investigate, and prevent fraud and abuse

As a processor, we use client information only to perform the services that client
has instructed us to perform.

4.1 Advertising and audience matching

Our core service is placing advertising in front of people who are already looking for
somewhere to stay or eat. We do this by matching licensed travel-intent signals — such
as an interest in a destination — to advertising campaigns, using pseudonymous
identifiers rather than names.

This is automated. It does not produce a legal effect or a similarly significant effect
on anyone: it determines which advertisement someone may see, nothing more. We do not
use it to make decisions about credit, employment, housing, insurance, pricing to
individuals, or access to any service.

You may object to this processing at any time — see section 6 and
https://sailtech.ai/optout.

5. Who we share information with

We share personal information with the following categories of recipients:

Every service provider is bound by a written agreement requiring it to protect personal information and to use it only for the purposes we specify. Advertising platforms are different: they also use the data they receive for their own purposes, under their own terms. See section 11.1.

A current list of our named service providers and subprocessors is available on
request. Email hi@sailtech.ai and we will send it.

We also disclose information where the law requires it, to protect our legal rights, or
in connection with a merger, acquisition, or sale of assets.

We do not share SMS opt-in or consent information with any third party for marketing or
promotional purposes.

6. Your rights

Depending on where you live, you may have the right to:

• Access the personal information we hold about you

• Correct information that is inaccurate

• Request deletion of your information

• Restrict or object to how we use it

• Receive your information in a portable format

• Withdraw consent, where we rely on consent

• Opt out of targeted advertising and of the "sale" or "sharing" of your information

To exercise any of these rights, email hi@sailtech.ai or write to the address in
section 12. We will verify your identity before we respond, and we will respond within
the time the applicable law allows.

To opt out of targeted advertising, visit https://sailtech.ai/optout.

To stop marketing email, use the unsubscribe link in any message or contact us. We
will still send you service and account messages where you are a client.

We will not treat you differently for exercising any of these rights.

7. How long we keep information

We keep personal information for as long as it is needed for the purpose it was
collected for, and for as long as the law requires. We determine how long to keep
information using the following criteria:

• Whether we still have an active relationship with you or with the client the
  information relates to

• Whether the information is still needed to deliver, measure, or reconcile a campaign

• Whether we are required to retain it for tax, accounting, contractual, or legal
  purposes, or to establish or defend a legal claim

• The sensitivity of the information and the risk of harm from retaining it

Where we act as a processor, we delete or return client data as our agreement with that client sets out.

You may ask us to delete information we hold about you at any time — see section 6.

8. Security

We use technical and organizational measures appropriate to the risk, including
encryption in transit and at rest, access controls, and role-based permissions on
systems holding personal information. No method of transmission or storage is completely
secure, and we cannot guarantee absolute security.

9. International transfers

We are based in the United States and our service providers are located in the United States, Canada, Singapore, and the European Economic Area.

Where we transfer personal information out of the EEA or the United Kingdom, we rely on
the European Commission's Standard Contractual Clauses, the UK International Data
Transfer Addendum, or another lawful transfer mechanism, together with additional
safeguards where they are needed.

10. If we handle your information for a hotel or restaurant

If you interacted with one of our clients — booked a room, visited their website, or
joined their mailing list — that client controls your information, not us. Contact them
first. Their privacy policy applies.

If you contact us instead, we will pass your request to that client and support them in
answering it, as our agreement with them requires.

11. Additional rights by region

11.1 California

Under the CCPA as amended by the CPRA, we disclose the following.

Categories of personal information we have collected in the past 12 months:
identifiers; California Customer Records categories; commercial information; internet
and network activity; approximate geolocation; professional or employment information;
inferences drawn from the above.

Sources: you, your device, our clients, and commercial data providers.

Business purposes: those set out in section 4.

Categories disclosed for a business purpose: those set out in section 5.

Sale and sharing. We do not sell personal information for money. However, when we
share identifiers and internet activity information with advertising partners to deliver
targeted advertising, that qualifies as a "sale" and as "sharing for cross-context
behavioural advertising" under California law. You may opt out at https://sailtech.ai/optout.

Sensitive personal information. We do not collect or use sensitive personal
information for purposes requiring a right to limit.

We do not knowingly sell or share the personal information of anyone under 16.

You may exercise your California rights by emailing hi@sailtech.ai or writing to the
address in section 12. You may use an authorized agent.

11.2 Other US states

Residents of Colorado, Connecticut, Virginia, Utah, Texas, Oregon, and other states with
comprehensive privacy laws have comparable rights of access, correction, deletion,
portability, and opt-out of targeted advertising and profiling. Use the same contact
routes above. Where your state provides an appeal right and we decline your request, we
will tell you how to appeal.

11.3 European Economic Area and United Kingdom

Our legal bases:

Where we rely on legitimate interests, we have assessed that our interests do not
override your rights, and you may object at any time.

Additional rights: you may lodge a complaint with your supervisory authority. In the
UK that is the Information Commissioner's Office.

Data not collected from you. Where we license travel-intent data, we did not collect
it from you directly. Section 3.3 explains what it contains and where it comes from.

12. Contact us

Sail Technologies LLC
36 East 31st Street
New York, NY 10016
Email: hi@sailtech.ai

For privacy requests, please put "Privacy Request" in the subject line.

13. Children

Our website and services are not directed to children under 13, and we do not knowingly
collect their personal information. If you believe a child has given us information,
contact us and we will delete it.

14. Changes to this policy

We may update this policy. When we do, we will change the Effective Date above. If a
change materially affects how we use your information, we will give you clearer notice
and obtain your consent where the law requires it.