Privacy Policy

Sailthru, Inc. and its affiliates worldwide (“we” or “us”) assists its customers and clients (“Customers”) in managing their own applications or software (“Customer Apps”). We collect information through the use of these Customer Apps that integrate our software or services (“ Software”). Our Customers may also separately collect information through these Customer Apps, but we do not have control over information collected by our Customer or Customer Apps. In most cases, the information we process is provided directly to us from our Customers, who have an obligation to inform you of their privacy practices and to obtain your consent for the use of your information.

This privacy policy describes our collection and use of information from end users (“you” or “users”) of Customer Apps and from visitors to our website at (the “Site”). This privacy policy applies to information collected by us online, not offline.

This privacy policy does not govern any collection or use of information by third parties, including our Customers. Our Customers each should have their own separate privacy policy that also applies to your use of their Customer Apps that utilize our Software. You are responsible for also reviewing any such separate privacy policies that might apply to you and your use of any Customer App.

The Software, our website, and any other products or services that may collect your data, are referred to herein as the “Services”.

Updates to this Policy

This policy was last updated on April 20, 2016. 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.

Safe Harbor

Sailthru, Inc. complies with the U.S.-E.U. and U.S.-Swiss Safe Harbor frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from the European Union and Switzerland. To view the Carnival, Inc. (now Sailthru, Inc.) certification on the Safe Harbor list or to learn more about the Safe Harbor program’s principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement, please visit

If you have questions or concerns regarding our compliance with the U.S. E.U. and U.S. Swiss Safe Harbor framework, you should first contact us at If you do not receive acknowledgement of your inquiry in 30 days, or your inquiry has not been satisfactorily addressed, you should contact ICDR/AAA, our Safe Harbor Dispute Resolution provider as described below.

Personal Data

Personally Identifiable Information (“Personal Data”) is information about you that you provide to us that is personally identifying, such as your name, email address, or telephone number, and that is not otherwise publicly available. The definition of Personal Data or Personally Identifiable Information depends on your physical location and may include other types of information. Only the definition that applies to your physical location will apply to you under this Privacy Policy. We will retain your Personal Data as long as necessary to conduct our business.

100% Opt-In

Providing Personal Data by registering on our Site, emailing us, signing up for email updates, and using our Services is entirely voluntary and is by opt-in only. If you do not opt-in you will not have access to our Services or a Free Trial, and we will have no way of contacting you to respond to your inquiries or requests for information. By opting in you are providing your express consent to the collection, use, retention, processing, transfer, and disclosure, including cross-border disclosure, of your Personal Data as explained in this Privacy Policy.

Collection and use of Your Information on our Site

You may browse our Site and read our blog without providing any information directly to us. We collect certain information directly from you if you log on to our Site, contact us, or register for our email list.

When you log in to our Site we collect your email address and a password. We use this information to identify you as a Software Customer user and ensure the security of your account.

If you contact us through the Contact page on our Site, we collect your name, phone number, email address, company name and title.

If you request a case study through the Case Studies page on our Site, we collect your name, job title, company name and email address.

If you join our email list for special updates, we collect your name and email address.

Collection and use of Your Information Through Our Services

When you use our Services, we collect or receive information about your interactions with us. Depending on how you use our Services, your information may include:

Your information may be supplemented with additional information from other companies such as publicly available information, information supplied to us by our Customers, and other information that we may append or match to your information.

We may also receive or collect certain technical information when you use our Services. This 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 referring websites or services (websites you used immediately prior to using our websites or other Services; existing websites or services (immediately after using our website or other Services); and data relating to malfunctions or problems occurring when you use our Services. Additionally, we may collect information about other software on your device for the limited purpose of protecting your security or improving your online experience.

How Your Information is Used

Your information is used for purposes that include:

We may use cookies, web beacons or other technologies in combination with your information to enhance and personalize your experience. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. However, it’s important to remember that many of our Services may not function properly if your cookies are disabled.

Do We Use Cookies?

When you visit the Site, we use session “cookies” — a piece of information stored on your computer — to allow us to uniquely identify your browser while you are logged in and to enable us to process your online transactions. We do not link the information we store in cookies to any Personal Data you submit while on our Site. Session cookies also help us confirm your identity and are required in order to login into your account. uses persistent cookies that only we can read and use, to identify you as a customer and make it easier for you to log into your account. Users who disable their web browsers’ ability to accept cookies will be able to browse our Site, but will not be able to access or take advantage of the Services.

How to delete and block our cookies

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our Site.

Changing your cookies settings

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.

Google Analytics

The Site uses Google Analytics. For more information about Google analytic cookies, please see Google’s help pages and privacy policy:


The Site uses HubSpot software to manage and provide the Services. To learn about HubSpot’s use of cookies and other navigational information and to view HubSpot’s privacy policy, please go to:

Sharing of Your Information

We do not rent or sell your personally identifiable 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 Policy.

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 ownership of us was to change as a result of a merger, acquisition, or transfer to another company, your information may be transferred. 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.

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 Policy. 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 Policy.

If you wish to opt out and withdraw your consent, you may do so at any time by contacting us at: 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.

Our Commitment to Security

We will take reasonable precautions to protect Personal Data 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 take advantage of 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. We will retain and use this Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.


Our Services are intended for a general audience and are not directed to children under the age of thirteen. As such we do not knowingly collect information from users under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at the email address provided below, and we will delete the information.

Our Site may contain links to other websites that are independent, are not owned or operated by us, are not covered by this Privacy Policy and which may incorporate Third Party Information. These third party sites have separate and independent privacy policies. If you access other sites using the links provided, the operators of these sites may collect information from you, which will be used by them in accordance with their privacy policy, which may differ from ours. We therefore have no responsibility or liability for the content and activities of other websites, even if they are linked to our Site.

Social Media Features

Our Site includes 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 Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

International or Cross-Border Transfer of Your Personal Data and Your Express Agreement

Given that the Internet operates in a global environment and that, if you operate outside of the United States, transfer of your data is necessary for you to use our Services or request information from us, using the Internet to collect and process Personal Data necessarily involves the transmission of data on an international, or cross-border, basis. By registering for the Site or accessing the Services, and/or communicating with us by email, you acknowledge and expressly consent to our processing and disclosure of your Personal Data in this way.

For users who are located outside the United States, Personal Data will be transferred outside of customer’s country to the United States where our servers are located and where it will be processed and stored on services owned and operated by Amazon Web Services (“AWS”), which participates in the EU-US Safe Harbor program. You may view the AWS privacy policy at The U.S. does not provide an adequate level of protection according to EU data protection regulations, for the purpose of providing the Services. We will take all steps reasonably necessary to ensure that Personal Data is treated securely and in accordance with this Privacy Policy in respect of such transfer, but will not otherwise take steps to ensure compliance with applicable laws in each customer’s country of residence. By registering for the Site, by subscribing for Services and/or by emailing us, you expressly agree to such transfer and disclosure.

California Do Not Track Disclosures and Other Disclosures under CalOppa

We currently do not honor Do Not Track signals. Personal Data collected by us as described in this Privacy Policy is not maintained in personally identifiable form in combination with any identifier collected by cookies, web beacons, or other technologies.

Access to Your Information

You may access, review, change, update or delete your Personal Data by emailing us at (“Data Controller” and “Data Recipient”). When updating your personal information, we may ask you to verify your identity before we can act on your request.

If you wish to unsubscribe from any of our emails, please click on the “unsubscribe” feature on the email you receive from us.

Contact Us About Complaints, Questions, Comments, or Notices relating to this Privacy Policy

In compliance with the US-EU and US-Swiss Safe Harbor Principles, Sailthru, Inc. commits to resolving complaints about your privacy and our collection or use of your Personal Data. Users with a need to provide a Notice to us under this Policy or our Terms of Use, or European Union or Swiss residents with inquiries or complaints regarding this Privacy Policy should first contact Sailthru, Inc.:

Sailthru, Inc. has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the International Center for Dispute Resolution/American Arbitration Association (ICDR/AAA), operated by the American Arbitration Association. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Sailthru, Inc., please visit the AAA EU SAFE HARBOR website at to obtain more information or to file a complaint.

Terms of Service

Please also visit our Terms of Service section establishing the use, disclaimers, and limitations of liability governing the use of our website.