GDPR Privacy Policy

Effective date: 2021-07-01

At SardineAI Corp. ("Sardine"), we take your privacy seriously. If you are a resident of the European Union ("EU"), United Kingdom, Lichtenstein, Norway or Iceland, this privacy policy applies to the personal data we collect about you. If you are a resident of another jurisdiction, please see our privacy policy. Please read this Privacy Policy to learn how we treat your personal data.

Remember that your use of Sardine's Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

You may print a copy of this Privacy Policy by clicking here. If you have a disability, you may access this Privacy Policy in an alternative format by contacting privacy@sardine.ai.

Privacy Policy Table of Contents

What this Privacy Policy Covers

Personal Data

  • Categories of Personal Data We Collect
  • Categories of Sources of Personal Data
  • Our Commercial or Business Purposes for Collecting Personal Data

How We Share Your Personal Data

Tracking Tools and Opt-Out

Data Security and Retention

Personal Data of Children

European Union Data Subject Rights

Changes to this Privacy Policy

Contact Information

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. "Personal Data" means any information that identifies or relates to a particular individual and also includes information referred to as "personally identifiable information" or "personal information" under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don't own or control or people we don't manage.

Personal Data

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we collect and have collected over the past 12 months:

Category of Personal Data 

Examples of Personal Data We Collect

Categories of Third Parties With Whom We Share this Personal Data: 

Profile or Contact Data

  • First and last name
  • Email
  • Phone number
  • Unique identifiers such as passwords
  • Social security number
  • Date of birth



  • Service Providers
  • Merchants

Transactional Data (collected when evaluating a consumer that applies for products or services of some of our merchants)

  • Credit or debit card number (full number)
  • Hashed credit card number
  • Bank account information
  • Billing address, phone number, and email
  • Service Providers
  • Merchants

Payment Data (collected when a customer pays for our services) 

  • Payment card type
  • Last 4 digits of payment card
  • Bank account information
  • Billing address, phone number, and email
  • Service Providers (specifically our payment processing partner, currently Stripe)

Commercial Data

  • Purchase history
  • Service Providers

Identifiers

  • Social security number
  • Driver’s license number
  • Passport number
  • Service Providers

Device/IP Data

  • IP address
  • Device ID
  • Domain server
  • Type of device/operating system/browser used to access the Services
  • Fonts
  • Plugins
  • Android ID
  • Service Providers

Web Analytics

  • Web page interactions
  • Referring web page/source through which you accessed the Services
  • Statistics associated with the interaction between device or browser and the Services
  • Service Providers

Geolocation Data

  • IP-address-based location information
  • Service Providers

Social Network Data

  • Link to public social network profile (e.g., Twitter, LinkedIn)
  • Service Providers

Consumer Demographic Data

  • Age / date of birth
  • Zip code
  • Service Providers

Sensory Data

  • Photos, videos or recordings of your environment
  • Service Providers

Inferences Drawn From Other Personal Data Collected

  • Risk score
  • Service Providers
  • Merchants 

Other Identifying Information that You Voluntarily Choose to Provide

  • Identifying information in emails or letters you send us
  • Service Providers

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

  • You
    • When you provide such information directly to us.
      • When you use our interactive tools and Services.
      • When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
      • When you send us an email or otherwise contact us.
    • When you use the Services and such information is collected automatically.
      • Through Cookies (defined in the "Tracking Tools and Opt-Out" section below).
      • If you use a location-enabled browser, we may receive information about your location.
      • If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services.
  • Public Records
    • From the government or other sources.
  • Third Parties
    • Vendors
      • We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
      • We may use vendors to obtain information to create user profiles.

Our Commercial or Business Purposes for Collecting Personal Data

  • Providing, Customizing and Improving the Services
    • Processing orders or other transactions; billing.
    • Providing you with the products, services or information you request.
    • Meeting or fulfilling the reason you provided the information to us.
    • Providing support and assistance for the Services.
    • Improving the Services, including testing, research, internal analytics and product development.
    • Personalizing the Services, website content and communications based on your preferences.
    • Doing fraud protection, security and debugging.
    • Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.
  • Marketing the Services
    • Marketing and selling the Services.
  • Corresponding with You
    • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Sardine or the Services.
    • Sending emails and other communications according to your preferences or that display content that we think will interest you.
  • Meeting Legal Requirements and Enforcing Legal Terms
    • Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
    • Protecting the rights, property or safety of you, Sardine or another party.
    • Enforcing any agreements with you.
    • Responding to claims that any posting or other content violates third-party rights.
    • Resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

Note that our merchant may, in its own discretion, use our Services to determine whether or not to complete a transaction with you based on automated decision-making. Please contact the merchant for any questions regarding such automated decision-making.

How We Share Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section.

  • Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
    • Hosting, technology and communication providers.
    • Security and fraud prevention consultants, such as risk intelligence providers.
    • Support and customer service vendors.
    • Payment processors.
  • Merchants. Merchants, such as banks and retail businesses. These parties partner with us in offering various services. These merchants may include businesses that you have a relationship with.
  • Parties You Authorize, Access or Authenticate
    • Third parties you access through the services.
    • Social media services.

Legal Obligations

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under "Meeting Legal Requirements and Enforcing Legal Terms" in the "Our Commercial or Business Purposes for Collecting Personal Data" section above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

Tracking Tools and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, "Cookies") to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data-- usually text files -- placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).

We use the following types of Cookies:

  • Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
  • Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled "Information about Interest-Based Advertisements."

You can decide whether or not to accept Cookies through your internet browser's settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you, look in the "preferences" or "options" section of your browser's menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.

Information about Interest-Based Advertisements:

We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors ("Interest-Based Ads"). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users' activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a "web beacon") from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.

To obtain information about online behavioral advertising, users in the European Union should visit the European Interactive Digital Advertising Alliance's user information website http://www.youronlinechoices.eu/.

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. Although we work to protect the security of your data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain Personal Data about you for as long as necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at privacy@sardine.ai.

European Union Data Subject Rights

EU Residents

If you are a resident of the EU, United Kingdom, Lichtenstein, Norway or Iceland, you have the rights identified below under the GDPR with respect to your Personal Data.

For this section, we use the term "processing" as it is defined in the GDPR, but "processing" generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Sardine will be the controller of your Personal Data processed in connection with the Services.

If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@sardine.ai.

Personal Data We Collect

The "Categories of Personal Data We Collect" section above details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds

The "Our Commercial or Business Purposes for Collecting Personal Data" section above explains how we use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our "legitimate interests" or the legitimate interest of others, as further described below.

  • Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:
    • Profile or Contact Data, Transactional Data, Payment Data, Commercial Data, Identifiers, Device/IP Data, Web Analytics, Social Network Data, Consumer Demographic Data, Geolocation Data, Sensory Data, Inferences Drawn from Other Personal Data Collected, and Other Identifying Information that You Voluntarily Choose to Provide.
    • We may also de-identify or anonymize Personal Data to further our legitimate interests.
    • Examples of these legitimate interests include (as described in more detail above):
      • Providing, customizing and improving the Services.
      • Marketing the Services.
      • Corresponding with you.
      • Meeting legal requirements and enforcing legal terms.
      • Completing corporate transactions.
  • Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
  • Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Sharing Personal Data

The "How We Share Your Personal Data" section above details how we share your Personal Data with third parties.

EU Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at privacy@sardine.ai. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

  • Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
  • Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
  • Erasure: You can request that we erase some or all of your Personal Data from our systems.
  • Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
  • Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
  • Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
  • Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
  • Right to File Complaint: You have the right to lodge a complaint about Sardine's practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

Transfers of Personal Data

The Services are hosted and operated in the United States ("U.S.") through Sardine and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Sardine in the U.S. and will be hosted on U.S. servers, and you authorize Sardine to transfer, store and process your information to and in the U.S., and possibly other countries.

Changes to this Privacy Policy

We're constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Sardine website, by sending you an email and/or by some other means. Please note that if you've opted not to receive legal notice emails from us (or you haven't provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contact Information:

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

If you are located in the European Union or the United Kingdom, you may use the following information to contact our Data Protection Officer and our European Union- and United Kingdom-Based Member Representative: dpo@sardine.ai