Sardine’s Privacy Policy

SardineAI Corp. (SardineAI Corp., together with all its affiliates, collectively “Sardine,” “we,” “us,” or “our”) respects, and works hard to protect, your privacy. This Privacy Policy is designed to help those who are interacting with our websites or exploring our Services (“visitors”) or individuals who directly sign up for and access, or who use our products as part of a transaction flow (“transacting users”) (visitors and transacting users are referred to as “you”), understand how we collect, use, process, and disclose your personal information, and to help you understand and exercise your privacy rights when you access our websites and use our websites, product offerings or services (“Services”). For residents of California and other states that provide additional rights, more information about the data we collect is available in our Notice at Collection and Supplemental Notice for Residents of Certain Other States, which is found in section 9 of this document.

1. Scope

This Privacy Policy applies to personal information we process. “Personal information” in this Policy means information about you, including your identity, and online behavior.  

This Privacy Policy does not apply to any personal information or other data we process on behalf of our enterprise customers (“Enterprise Data”). Our processing of Enterprise Data is governed by contracts we have in place with our enterprise customers, not this Privacy Policy and our enterprise customers’ respective privacy policies govern their collection and use of personal information. Any questions or requests relating to the privacy practices of any of our enterprise customers should be directed to the applicable customer.

Personal Information We Collect

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below. For residents of certain states, additional disclosures about the information we collect is available in our supplemental disclosure below.

A. Personal Information You Provide to Us Directly

We may collect personal information that you provide to us directly when you interact with our Services.

• Account Creation. If you create an account to register or transact with us as a transacting user, we will collect personal information including your full legal name, date of birth, email address, phone number, government identifying information, and payment information. We may also require you to provide additional personal information as required by law or for compliance purposes, as a condition for continuing use of aspects of our Services, for example to confirm your identity and your purpose in using the Services.
• Transactions. We collect personal information and details associated with transacting users’ transactions, including payment information.
• Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for email or other messages from us, contact customer service, request technical support, or otherwise communicate with us.
• Surveys and Questionnaires. We may contact you to participate in surveys, request that you complete a questionnaire or otherwise seek your input. If you decide to participate, we may collect personal information from you in connection with your feedback or other responses.
• Interactive Features. We and others who use our Services may collect personal information if you elect to use any of our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you may elect to provide using any public sharing features of the Services will be considered “public,” unless otherwise required by applicable law, and is not subject to the provisions of this policy.
• Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events. 
• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities. 
• Job Applications. We may post job openings and opportunities on our websites. If you respond to one of these postings, your personal information will be handled as disclosed during the application process and as described in our Applicant and Worker Privacy Notice.

B. Personal Information Collected Automatically

We may collect personal information automatically when you use our Services.

• Automatic Collection of Personal Information. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), domain server, and Internet service provider. For transacting users using our Services we may also automatically collect information regarding your use of the Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, such as how you type on a keyboard, move a mouse, tap a touch screen or otherwise interacts with a device, and other information about how you use our Services.
• Cookie Policy (and Other Technologies). We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, and other technologies (collectively, “Technologies”) to automatically collect information through your use of our Services. 
• Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of these Technologies fall into the following general categories: 

• Strictly Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our Services;
• Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
• Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
• ‍Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize our Services. For example, one of our analytics partners includes FullStory (Session Replay Analytics). We use FullStory’s session replay analytics services, including for fraud prevention. This allows us to record and replay an individual’s interaction with the Services in certain cases. For more information about how FullStory uses your personal information, please visit FullStory’sPrivacy Policy. To learn more about how to opt out of FullStory’s use of your information, please click here.
• Social Media Platforms. Our Services may contain social media buttons, such as Twitter and LinkedIn, which might include widgets such as the “share this” button or other interactive mini programs. These features may collect personal information such as your IP address and which page you are visiting on our Services and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.
• Biometric Information. We may collect your biometrics, including facial imagery, in order to verify your identity as a transacting user when using certain of our Services, and for fraud prevention purposes. In such cases, we use third-party technology from our service providers to collect information about you, including biometric information, a selfie and government identification (collectively “Biometric Information”). This Privacy Policy as well our service providers’ privacy policies will apply to the collection, use and sharing of your Biometric Information, should you elect to provide it to us as a transacting user of the Services. 

C. Personal Information Collected from Other Sources

Third-Party Services and Sources. We may obtain personal information about you from other sources, including through third-party services and organizations.  For example, if you are a visitor accessing our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect personal information about you from that third-party application that you have made available via your privacy settings. If you are a transacting user, we may also obtain personal information from third-parties that you may use to connect and share your financial information with our Services. For example, you may elect to authorize Plaid, Inc. to share certain banking information with our Services, in which case both the Plaid Privacy Policy, and this Privacy Policy, would apply. 

3. How we use your personal information

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

A. Provide Our Services

We use your information to provide you with our Services, such as:

• Fulfill our contract with you if you are a transacting user;
• Managing your information and transacting user account;
• Providing access to certain areas, functionalities, and features of our Services;
• Answering requests for customer or technical support; 
• Communicating with you about your transacting user account, transactions, and activities on our Services, including providing you with information about policy changes;
• Processing your financial information and other payment methods when transacting with the Services as a transacting user;
• Processing applications if you apply for a job we post; and
• Allowing you to register for events.

B. Administrative Purposes

We use your information for various administrative purposes, such as:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest and engagement in our Services; 
• Improving, upgrading, or enhancing our Services; 
• Developing new products and services;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;
• Debugging to identify and repair errors with our Services;
• Auditing relating to interactions, transactions, and other compliance activities;
• Sharing personal information with third parties as needed to provide the Services;
• Enforcing our agreements and policies; and
• Carrying out activities that are required to comply with our legal obligations.

C. Marketing and Advertising our Products and Services

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. 

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.

D. With Your Consent

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

E. Other Purposes

We also use your personal information for other legitimate business purposes, as requested by you, for legal compliance, loss-prevention, anti-fraud purposes or as otherwise permitted by applicable law. For example, we may use personal information to create de-identified and/or aggregated information to improve the accuracy and security of our Services and to contribute to protecting the security of the broader payments ecosystem. Note however, if we create or receive de-identified information, we will not attempt to reidentify such information, except to comply with applicable law. 

4. How we disclose your personal information

We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below. 

A. Disclosures to Provide our Services

The categories of third parties with whom we may share your personal information are described below.

• Service Providers. We work with third-party service providers and vendors that assist us with the provision of our Services. This includes service providers and vendors that provide us with IT support, hosting, payment processing, settlement services, fraud detection, identity verification providers, and related services. When we disclose information with third-party service providers in this capacity, we require them to use your information on our behalf in accordance with our instructions and terms and only process your personal information as necessary to provide the Services to you pursuant to the terms of a binding contract between them and Sardine. We may disclose your information with payment processing companies to process and settle payments transacting users initiate when using our Services. If you are a transacting user, we will also disclose your personal information with our identity verification partners to prevent fraud by confirming your identity by comparing information you provide us to public records and third-party databases. In some cases, our service providers may process biometric data that can be used in connection with the provision of fraud prevention and identity verification services. In those  cases, transacting users will also need to agree to our service providers’ privacy policies to access the Services.
• Business Partners. We may disclose your personal information with business partners to provide you with a product or service you have requested. We may also disclose your personal information with business partners with whom we jointly offer products or services.
• Affiliates. We may share your personal information with our company affiliates for our administrative and business purposes, IT management, or for them to provide services to you or support and supplement the Services we provide.
• Professional Advisors, Industry Partners, Governmental Authorities and Regulators. In order to provide our Services, we may also disclose your information with our advisors, regulators, tax and other governmental authorities, governmental agencies, law enforcement agencies and industry partners to respond to applicable law or regulations, court orders, legal process or government requests; comply with our reporting and information sharing obligations with industry partners and regulatory authorities; detect, investigate, prevent, or address fraud and other illegal activity or security and technical issues; and protect the rights, property, and safety of you, Sardine or others, including to prevent imminent harm or injury to others.

B. Disclosures to Protect Ourselves or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

5. Your privacy choices and rights

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

• Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below. 
• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms of Service or this Privacy Policy). 
• “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications.

Your Privacy Rights. Depending on where you live, you may be entitled to exercise certain privacy rights related to your personal information. If you would like to exercise any privacy rights granted to you under applicable law, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws. Please note, to protect your privacy, we will take steps to reasonably verify your identity before fulfilling your request. These steps may involve asking you to provide information to allow us to reasonably verify you are the person about whom we collected personal information (or an authorized representative), or to answer questions regarding your account and use of our Services.

• Right to Access and Portability of Personal Information about you, including: (i) confirming whether we are processing your personal information, and (ii) obtaining access to, or a copy of personal information we may hold about you; 
• Right to Request Correction of your personal information where it is inaccurate, incomplete, or outdated. In some cases, we may provide self-service tools that enable you to update your personal information directly;
• Right to Request Deletion of your personal information when processing is based on your consent or when processing is unnecessary, excessive or noncompliant, subject to applicable law; 
• Right to Request Restriction of or Object to our processing of your personal information where the processing of your personal information is based on our legitimate interest or for direct marketing purposes including (i) the right to opt-out of the sharing of personal information, (ii) object to or restrict our use of or your sensitive personal information, including the right to opt-out of the sharing of sensitive personal information, and (iii) opt out of the processing of your personal information for purposes of (a) targeted advertising, and (b) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you; 
• Right to Non-Discrimination by us if you exercise privacy rights provided to you under law.
• Right to Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal. If you refrain from providing personal information or withdraw your consent to processing, you may not be able to use aspects of the Services;
• Right to Work with an Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To authorize an agent, provide written authorization signed by you and your designated agent and contact us as set forth in “Contact Us” below for additional instructions.
• Right to File a Complaint. If your personal information is subject to the certain data protection laws, you have the right to lodge a complaint with the competent supervisory authority or attorney general if you believe our processing of your personal information violates applicable law. Links to applicable data protection authorities are below:
  
  ‍EEA Data Protection Authorities (DPAs)
  Swiss Federal Data Protection and Information Commissioner (FDPIC)
  UK Information Commissioner’s Office (ICO)
  Virginia Attorney General

6. Security of your information

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.

7. International data transfers

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses. For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

8. Retention of personal information

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws, or based upon other criteria, including, but not limited to, the sensitivity and volume of such data.  Additionally, we endeavor to retain all such personal information in accordance with legal requirements.

9. Notice at collection and supplemental notice for California and residents of certain U.S. States

This Supplemental Policy is for residents of states that have adopted comprehensive privacy legislation and others that may come into effect from time to time, including, but not limited to, California, Connecticut, Colorado, Utah and Virginia (collectively, “Applicable State Laws”).

The following table describes the categories of personal information Sardine has collected and whether Sardine disclosed that personal information for a business purpose (e.g., to a service provider).

‍

As more fully described in the section titled Personal Information We Collect, the sources from which we collect personal information include directly from you when you interact with us, automatically from you when you use our sites and services (for example through cookies and other online technologies), from third parties (for example, if you access our services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect personal information about you from that third-party application that you have made available via your privacy settings), and through referrals from others. The business purposes for which we collect personal information are described in more detail in the section titled, How We Use Your Personal Information and include:

• To provide our Services to you;
• For our Administrative purposes;
• With your consent, and
• To comply with law.

Our full Privacy Policy can be accessed here.

"Sales" of Personal Information under the CCPA

For purposes of Applicable State Laws, we do not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of persons under 18 years of age as the term “sell” is commonly understood.

California Shine the Light. The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. Sardine does not disclose personal information to third parties for their direct marketing purposes.

10. Children’s information

The Services are not directed to persons under 18, and we do not knowingly collect personal information from children.  Protecting children’s privacy online is very important to us. If you are a parent or guardian and believe your child has provided us with their personal information you may contact us as described in “Contact Us” below. We will delete any personal information we have collected in violation of applicable law unless we have a legal obligation to keep it.

11. Changes to our privacy policy

We may revise this Privacy Policy from time to time at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

12. Contact us

Sardine is the controller of the personal information we process under this Privacy Policy. If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:

SardineAI Corp
382 NE 191^st St, #58243
Miami, Florida
33179-3899
dataprotection@sardine.ai

13. U.S. Consumer privacy notice

14. Important privacy choices for consumers

You have the right to control whether we share some of your personal information. Please read the following information carefully before you make your choices below.

SardineAI Corp. (“Sardine”, “we”, or “us”) provides this California Customer Privacy Notice to you as required by the California Financial Information Privacy Act, to the extent you are a California resident to whom we provide a financial product or service.  

Your Rights

You have the right to restrict the sharing of personal and financial information with our affiliates (companies we own or control) and outside companies with whom we do business, as described below. Nothing in this form prohibits Sardine from sharing information necessary for us to follow the law, as permitted by applicable law, or to service your accounts with us.

Your Choices

Restrict Information Sharing With Companies We Own or Control (Affiliates):  Unless you say “No”, we may share personal and financial information about you with our affiliated companies.

□ NO, please do not share my personal and financial information with your affiliated companies.

Restrict Information Sharing With Other Companies We Do Business With To Provide Financial Products And Services: Unless you say “No”, we may share your personal and financial information with outside companies with whom we contract to provide financial products and services to you.

□ NO, please do not share my personal and financial information with outside companies you contract with to provide financial products and services.

Time Sensitive Reply

You may exercise your privacy choice(s) at any time.  Your choice(s) will remain unless you notify us otherwise.  If we do not hear you, we may share some of your information with affiliated companies and other companies with whom we have contracts to provides products and services.

Name:

Account or Policy Number(s):                      [to be filled in by consumer]

Signature: