Last Updated:

24 July 2025

Last Updated:

24 July 2025

S.AI.L's Cookie Policy

  1. Introduction and scope

  2. What are cookies and similar technologies

  3. How we use cookies on our website

  4. Types of cookies used on S.AI.L's website

  5. Detailed cookie inventory

  6. Your choices and consent

  7. Managing your cookie preferences

  8. Third party cookies and services

  9. International transfers of cookie data

  10. Data retention period for cookies

  11. Your rights regarding cookies

  12. How to contact us and complaint handling

  13. Changes to this cookie policy

  14. Jurisdiction specific information

  1. Introduction and scope

SAIL UKS02 Ltd ("S.AI.L," "we," "us," or "our") is committed to protecting your privacy and being transparent about how we use cookies and similar technologies on our website www.sail.legal. This Cookie Policy explains what cookies are, how we use them, the types of cookies we use, and how you can manage your cookie preferences

S.AI.L advises organisations on how to utilise artificial intelligence ("AI") to advance their strategic priorities. S.AI.L builds cloud-native AI solutions within its clients' cloud tenant. in We are committed to maintaining the highest standards of transparency and data protection while delivering exceptional value to our clients and stakeholders through our digital platforms

This Cookie Policy applies to all users of our website www.sail.legal and should be read in conjunction with our Privacy Policy. By using our website, you acknowledge that you have read and understood this Cookie Policy and consent to our use of cookies in accordance with the terms set out below, subject to your right to manage your preferences as described in this policy

This policy complies with the requirements of the European Union's General Data Protection Regulation (GDPR) and ePrivacy Directive, the United Kingdom's Privacy and Electronic Communications Regulations (PECR) and Data Protection Act 2018, and the Dubai International Financial Centre's Data Protection Law No. 5 of 2020. We have designed our cookie practices to meet the highest standards across all applicable jurisdictions to ensure consistent protection for all our users regardless of their location

  1. Introduction and scope

  2. What are cookies and similar technologies

  3. How we use cookies on our website

  4. Types of cookies we use

  5. Detailed cookie table

  6. Your choices and consent

  7. Managing your cookie preferences

  8. Third party cookies

  9. International transfers of cookie data

  10. Data retention for cookies

  11. Your rights regarding cookies

  12. How to contact us and complaint handling

  13. Changes to this cookie policy

  14. How to contact us and complaint handling

  15. Jurisdiction specific information

  1. Introduction and scope

SAIL UKS02 Ltd ("SAIL," "we," "us," or "our") is committed to protecting your privacy and being transparent about how we use cookies and similar technologies on our website www.sail.legal. This Cookie Policy explains what cookies are, how we use them, the types of cookies we use, and how you can manage your cookie preferences.

SAIL advises organisations on how to utilise artificial intelligence ("AI") to advance their strategic priorities. SAIL builds cloud-native AI solutions within its clients' cloud tenant. in We are committed to maintaining the highest standards of transparency and data protection while delivering exceptional value to our clients and stakeholders through our digital platforms.

This Cookie Policy applies to all users of our website www.sail.legal and should be read in conjunction with our Privacy Policy. By using our website, you acknowledge that you have read and understood this Cookie Policy and consent to our use of cookies in accordance with the terms set out below, subject to your right to manage your preferences as described in this policy.

This policy complies with the requirements of the European Union's General Data Protection Regulation (GDPR) and ePrivacy Directive, the United Kingdom's Privacy and Electronic Communications Regulations (PECR) and Data Protection Act 2018, and the Dubai International Financial Centre's Data Protection Law No. 5 of 2020. We have designed our cookie practices to meet the highest standards across all applicable jurisdictions to ensure consistent protection for all our users regardless of their location.

2. What are cookies and similar technologies

  1. Our data protection obligations

Cookies are small text files that are placed on your computer, smartphone, tablet, or other device when you visit a website. They are widely used to make websites work more efficiently and to provide information to website owners about how users interact with their sites. Cookies contain information that is transferred to your device's hard drive and stored there. They allow a website to recognize your device and store some information about your preferences or past actions

Types of Technologies Covered

This Cookie Policy covers the following technologies:

  • HTTP Cookies: Traditional cookies that are stored in your browser and sent back to the server with each request. These can be session cookies (deleted when you close your browser) or persistent cookies (remain on your device for a set period or until manually deleted)

  • Local Storage: HTML5 local storage allows websites to store larger amounts of data locally on your device. Unlike cookies, this data is not automatically sent to the server with each request but can be accessed by JavaScript running on the website.

  • Session Storage: Similar to local storage but data is only stored for the duration of your browser session and is deleted when you close the browser tab or window

  • Web Beacons and Pixels: Small, often invisible images embedded in web pages or emails that can track whether content has been viewed and collect information about your device and browser

  • Fingerprinting Technologies: Techniques that collect information about your device configuration, browser settings, and other characteristics to create a unique identifier for tracking purposes

  • Software Development Kits (SDKs): Third-party code libraries that may collect information about your device and usage patterns when integrated into websites or applications

How Cookies Work

When you visit our website, our server sends a cookie to your browser, which stores it on your device. The cookie contains a unique identifier and may include additional information such as expiration dates, domain restrictions, and security flags. When you return to our website or navigate to different pages, your browser sends the cookie back to our server, allowing us to recognise your device and provide a personalised experience

Cookies can be set by the website you are visiting (first-party cookies) or by third-party services integrated into the website (third-party cookies). First-party cookies are generally used for essential website functionality and user preferences, while third-party cookies are often used for analytics, advertising, and social media integration

Legal Basis for Cookie Processing

Under applicable data protection laws, we must have a legal basis for processing personal data through cookies. The legal bases we rely on include:

  • Consent: For non-essential cookies, we obtain your explicit consent before placing them on your device. This consent must be freely given, specific, informed, and unambiguous

  • Legitimate Interests: For certain cookies that are necessary for our legitimate business interests, such as website security and fraud prevention, we may rely on legitimate interests as the legal basis, provided this does not override your fundamental rights and freedoms

  • Contractual Necessity: Some cookies are necessary to provide services you have requested or to fulfil our contractual obligations to you

  • Legal Obligation: In some cases, we may be required by law to use certain cookies, such as those necessary for regulatory compliance or security purposes

We are committed to protecting your personal data and respecting your privacy rights. SAIL UKS02 Ltd, a company registered in England and Wales with company number 16535629, acts as the data controller for the personal data we process about you.

As a data controller, we are obliged to comply with applicable data protection laws, including the European Union's General Data Protection Regulation (GDPR), the United Kingdom's Data Protection Act 2018 and UK GDPR, and the Dubai International Financial Centre's Data Protection Law No. 5 of 2020.

This privacy policy explains how we collect, use, store, and protect your personal data when you interact with our services, apply for employment with us, or engage with us as a client or business partner. We are committed to processing your personal data in accordance with the principles of lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, confidentiality, and accountability.

2. Who we are and how to contact us

Data Controller: SAIL UKS02 Ltd

Company Registration Number: 16535629

Registered Address: Office 60 Tottenham Court Road, Office 80, Fitzrovia, London, W1T 2EW, United Kingdom

Email: compliance@sail.legal

Website: www.sail.legal

3. How we use cookies on our website

We use cookies on www.sail.legal for several important purposes that enhance your browsing experience, improve our website functionality, and help us understand how our services are used. Our cookie usage is designed to provide you with a seamless and personalized experience while respecting your privacy choices and complying with applicable data protection laws

Essential Website Functionality

We use strictly necessary cookies to enable core website functionality that you have requested or that is essential for the website to operate properly. These cookies are exempt from consent requirements under applicable laws because they are necessary for the basic operation of our website and cannot be disabled without significantly impairing your ability to use our services

Essential cookies on our website enable functions such as secure login areas, shopping cart functionality (if applicable), form submission, security features that protect against cross-site request forgery and other security threats, load balancing to ensure optimal website performance, and basic navigation features that remember your progress through multi-page processes

These cookies do not track your browsing behavior across other websites and are limited to the specific functionality they enable on our website. They typically expire when you close your browser session or after a short period necessary to maintain the functionality they support

Performance and Analytics

We use performance cookies to collect information about how visitors use our website, including which pages are visited most often, how long users spend on different pages, and any error messages that occur. This information helps us improve our website's performance, identify technical issues, and enhance the user experience for all visitors

Our analytics cookies collect aggregated and anonymized data about website usage patterns, including page views, session duration, bounce rates, traffic sources, and user flow through our website. This information is essential for understanding how our content and services are being used and for making data-driven decisions about website improvements and content development

We may use both first-party analytics tools and third-party services such as Google Analytics to collect this information. When using third-party analytics services, we ensure that appropriate data processing agreements are in place and that data is processed in accordance with applicable privacy laws

Personalisation and User Experience

We use preference cookies to remember your choices and settings to provide a more personalised experience when you return to our website. These cookies may remember your language preferences, display settings, form data you have entered, and other customisation options you have selected

Personalisation cookies help us tailor our content and services to your interests and needs, making your interactions with our website more relevant and efficient. For example, these cookies may remember your preferred communication methods, content topics of interest, or accessibility settings you have configured

Marketing and Communications

With your consent, we may use marketing cookies to deliver relevant advertisements and promotional content based on your interests and browsing behavior. These cookies help us understand which of our services and content are most relevant to different user segments and allow us to provide more targeted and useful communications.

Marketing cookies may track your interactions with our website content, including which pages you visit, how long you spend reading different articles, and which resources you download. This information helps us understand your professional interests and allows us to provide more relevant content recommendations and service offerings.

We may also use cookies to measure the effectiveness of our marketing campaigns, including email marketing, social media advertising, and other promotional activities. This helps us optimize our marketing efforts and ensure that we are providing valuable content and services to our audience.

Social Media Integration

Our website may include social media features and widgets that allow you to share content, follow our social media accounts, or interact with our content on social media platforms. These features may use cookies to track your interactions and provide personalised social media experiences

Social media cookies are typically set by the social media platforms themselves (such as LinkedIn, Facebook, Instagram or Bluesky) and are subject to those platforms' privacy policies and cookie practices. We encourage you to review the privacy policies of any social media platforms you interact with through our website

Security and Fraud Prevention

We use security cookies to protect our website and users from malicious activities, including cross-site scripting attacks, cross-site request forgery, and other security threats. These cookies help us detect and prevent unauthorised access, protect user accounts, and maintain the integrity of our website and services

Security cookies may collect information about your device, browser, and network connection to identify potentially suspicious activity and protect against automated attacks or unauthorised access attempts. This information is processed solely for security purposes and is not used for marketing or other commercial purposes

4. Types of cookies used on S.AI.L's website

We categorise the cookies used on our website into several distinct types based on their purpose, duration, and the entity that sets them. This classification helps you understand the different ways cookies are used and make informed decisions about your cookie preferences

By Purpose

Strictly Necessary Cookies: These cookies are essential for the basic functionality of our website and cannot be disabled without significantly impairing your ability to use our services. They include cookies that enable secure areas of the website, remember items in a shopping cart, enable form submission, and provide basic security features. These cookies do not require your consent under applicable laws because they are necessary for the services you have requested

Performance Cookies: These cookies collect information about how you use our website, such as which pages you visit and how long you spend on each page. They help us understand user behavior patterns and identify areas for improvement. All information collected by these cookies is aggregated and anonymised, and they do not identify you personally

Functionality Cookies: These cookies enable enhanced functionality and personalization features on our website. They may remember your preferences, language settings, and other choices you have made to provide a more personalized experience. While not strictly necessary for basic website operation, they significantly enhance your user experience

Marketing Cookies: These cookies are used to deliver relevant advertisements and promotional content based on your interests and browsing behavior. They may track your activity across our website and other websites to build a profile of your interests and deliver targeted advertising. These cookies require your explicit consent

Analytics Cookies: These cookies help us understand how our website is performing and how users interact with our content. They collect information about page views, session duration, traffic sources, and user flow patterns. This information is used to improve our website and services

By Duration

Session Cookies: These cookies are temporary and are deleted when you close your browser. They are used to maintain your session state as you navigate through our website and do not persist beyond your current browsing session

Persistent Cookies: These cookies remain on your device for a specified period or until you manually delete them. They are used to remember your preferences and settings across multiple visits to our website. The retention period for persistent cookies varies depending on their purpose, ranging from a few days to several years

By Origin

First-Party Cookies: These cookies are set directly by our website (www.sail.legal) and are used for essential functionality, analytics, and personalisation features that we control directly

Third-Party Cookies: These cookies are set by external services integrated into our website, such as analytics providers, social media platforms, or advertising networks. While we control which third-party services are integrated into our website, the cookies themselves are managed by the third-party providers

Detailed Cookie Categories

Authentication and Security Cookies: These cookies verify your identity when you log into secure areas of our website and protect against unauthorized access. They may include session tokens, CSRF protection tokens, and other security identifiers necessary for maintaining secure communications

Load Balancing Cookies: These technical cookies ensure that your requests are routed to the appropriate server and that our website performs optimally under varying traffic conditions. They are essential for maintaining website availability and performance

Preference and Settings Cookies: These cookies remember your choices regarding website functionality, such as language preferences, accessibility settings, display options, and other customisation features you have selected

Form Data Cookies: These cookies temporarily store information you have entered into forms on our website to prevent data loss if you navigate away from a page or experience a connection interruption

Analytics and Measurement Cookies: These cookies collect detailed information about your interactions with our website, including page views, click patterns, scroll behavior, and time spent on different sections. This data helps us optimise our content and user experience

Conversion Tracking Cookies: These cookies help us measure the effectiveness of our marketing campaigns by tracking when users complete desired actions, such as downloading resources, subscribing to newsletters, or contacting us for services

Retargeting and Remarketing Cookies: With your consent, these cookies enable us to show relevant advertisements to users who have previously visited our website when they browse other websites or social media platforms

The following tables provide a comprehensive inventory of all cookies that may be set on our website. This inventory is regularly updated to reflect changes in our cookie usage and third-party integrations. Each cookie is categorised by type, purpose, and retention period to help you make informed decisions about your cookie preferences

Necessary

  1. Name: cookieyes-consent. Duration: 1 year. Purpose: CookieYes sets this cookie to remember users' consent preferences so that their preferences are respected on subsequent visits to this site. It does not collect or store any personal information about the site visitors


Analytical

  1. Name: _ga_* cookieyes-consent. Duration: 1 year 1 month 4 days. Purpose: Google Analytics sets this cookie to store and count page views

  2. Name: _ga. Duration: 1 year 1 month 4 days. Purpose: Google Analytics sets this cookie to calculate visitor, session and campaign data and track site usage for the site's analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognise unique visitors



Content

We respect your right to control how cookies are used on your device and provide you with clear choices about cookie consent. Under applicable data protection laws, including the GDPR, UK PECR, and DIFC Data Protection Law, you have the right to make informed decisions about which cookies you allow and to withdraw your consent at any time

Consent Requirements and Standards

Our cookie consent mechanism is designed to meet the highest standards required by applicable laws across all jurisdictions where our users are located. This means that consent must be freely given, specific, informed, and unambiguous. We achieve this through several key principles in our consent implementation

Freely Given Consent: Your consent must be given voluntarily without any coercion, deception, or significant imbalance of power. We do not make access to our website conditional on your consent to non-essential cookies, and you can refuse or withdraw consent without affecting your ability to use our basic services

Specific Consent: We provide granular consent options that allow you to choose which categories of cookies you want to accept. You can consent to some categories while rejecting others, giving you precise control over your privacy preferences.

Informed Consent: We provide clear, comprehensive information about each category of cookies, including their purpose, duration, and the types of data they collect. This information is presented in plain language that is easy to understand

Unambiguous Consent: We require positive action from you to indicate consent, such as clicking an "Accept" button or toggling specific cookie categories. We do not use pre-ticked boxes or assume consent from continued browsing

Cookie Consent Interface

When you first visit our website, you will be presented with a cookie consent banner that provides essential information about our cookie usage and allows you to make choices about your preferences. This banner includes:

Essential Information: A brief explanation of what cookies are and how we use them, with a link to this full Cookie Policy for detailed information

Granular Choices: Separate options for different categories of cookies, allowing you to accept or reject each category independently

Accept All/Reject All Options: Quick options to accept or reject all non-essential cookies if you prefer not to make individual choices

Manage Preferences: A link to our detailed cookie preference center where you can review and modify your choices at any time

The consent banner is designed to be prominent and noticeable without being overly intrusive or interfering with your ability to use our website. It remains visible until you make a choice about your cookie preferences

Cookie Preference Center

Our cookie preference center provides detailed control over your cookie settings and can be accessed at any time through a link in our website footer or by clicking the "Manage Preferences" option in our consent banner. The preference center includes:

Detailed Cookie Information: Comprehensive descriptions of each cookie category, including specific cookies used, their purposes, retention periods, and data processing details

Granular Controls: Individual toggles for each cookie category, allowing you to enable or disable specific types of cookies according to your preferences

Third-Party Information: Details about third-party services that set cookies on our website, including links to their privacy policies and opt-out mechanisms

Consent History: A record of your previous consent choices and when they were made, providing transparency about your privacy decisions

Easy Updates: Simple mechanisms to change your preferences at any time, with immediate effect on future cookie placement

Withdrawal of Consent

You have the right to withdraw your consent for cookie processing at any time, and withdrawal is as easy as giving consent initially. You can withdraw consent through several methods:

Preference Center: Use our cookie preference center to modify or withdraw your consent for specific cookie categories

Browser Settings: Configure your browser settings to block or delete cookies, though this may affect website functionality

Contact Us: Contact our Data Protection Officer directly to request withdrawal of consent or assistance with managing your cookie preferences

Automated Tools: Use browser extensions or privacy tools that automatically manage cookie consent according to your preferences

When you withdraw consent, we will stop using the relevant cookies for future processing, though some data may be retained for legitimate purposes such as legal compliance or security. We will also take reasonable steps to inform third-party services of your consent withdrawal where technically feasible

Impact of Cookie Choices

We want you to understand how your cookie choices may affect your experience on our website so you can make informed decisions about your preferences

Essential Cookies: These cannot be disabled as they are necessary for basic website functionality. Blocking these cookies may prevent you from using certain features or accessing secure areas of our website

Performance Cookies: Disabling these cookies will not affect your ability to use our website, but it may limit our ability to improve the website based on usage analytics and performance monitoring

Functionality Cookies: Rejecting these cookies may result in a less personalised experience, and you may need to re-enter preferences or settings each time you visit our website

Marketing Cookies: Declining these cookies will not affect your website experience, but you may see less relevant advertisements and promotional content

We strive to ensure that our website remains fully functional and user-friendly regardless of your cookie choices, though some enhanced features may not be available if you choose to limit cookie usage

Special Considerations for Different Jurisdictions

European Union Users: Under the GDPR and ePrivacy Directive, we obtain explicit consent for all non-essential cookies and provide detailed information about data processing, including international transfers and retention periods.

United Kingdom Users: In compliance with PECR and UK GDPR, we ensure that consent meets the required standards and provide clear information about your rights and how to exercise them

DIFC Users: For users in the Dubai International Financial Centre, we apply enhanced transparency standards and ensure compliance with DIFC Data Protection Law requirements for consent and data processing

Other Jurisdictions: We apply the highest applicable standards to ensure consistent protection for all users regardless of their location

We provide multiple ways for you to manage your cookie preferences, ensuring that you have full control over how cookies are used on your device. These options range from our built-in preference management tools to browser-level controls and third-party privacy tools

Using Our Cookie Preference Center

Our Customise Consent Preferences menu bar is the most comprehensive tool for managing your cookie settings on our website. It can be accessed through "Manage Preferences" option in our consent banner when you visit www.sail.legal or by clicking the 'Consent Preferences' icon on the bottom-left hand corner of your browser

Accessing the Customise Consent Preferences: The customise consent preferences menu bar is available 24/7 and can be accessed from any page on our website. You do not need to create an account or provide personal information to use these controls

Category-Based Controls: The customise consent preferences menu organises cookies into clear categories (Necessary, Functional, Analytics, Performance and Advertisement) with detailed explanations of each category's purpose and the specific cookies included

Individual Cookie Management: For users who want granular control, the customise consent preferences menu allows you to view and manage individual cookies within each category, including information about their purpose, duration, and data collection practices.

Real-Time Updates: Changes made in the customise consent preferences menu take effect immediately, and you will see confirmation of your updated preferences. New cookies will only be set according to your current preferences

Preference History: The customise consent preferences menu maintains a record of your consent choices and when they were made, providing transparency about your privacy decisions over time

Browser-Based Cookie Management

All modern web browsers provide built-in tools for managing cookies, and these settings apply across all websites you visit. While browser settings provide broad control, they may be less precise than our website-specific preference center

Google Chrome: On your computer: go to Settings ► Privacy and security ► Cookies and other site data. Options let you: allow all cookies; block third‑party cookies; block all cookies; and set site‑by‑site rules via “Sites that can always use cookies” or “Sites that can never use cookies”. As of the date of this policy, Google provides an official help page with further details on how to manage your cookie preferences

Mozilla Firefox: In the menu: select Settings (or Preferences on macOS) ► Privacy & Security ► Cookies and Site Data. Under Enhanced Tracking Protection, choose Standard, Strict, or Custom. In Custom mode, you may block all cross‑site (third‑party) cookies, though Strict also blocks them by default. As of the date of this policy, Mozilla offers a support page with additional guidance on setting and managing cookie preferences

Safari (macOS): From the menu bar choose Safari ► Settings (or Preferences on older macOS) ► Privacy. Available options include Prevent cross‑site tracking (Safari’s Intelligent Tracking Prevention or ITP) and Block all cookies. You can also manage site-specific data via Manage Website Data. As of the date of this policy, Apple publishes up-to-date instructions on managing cookies and tracking settings within Safari's in-built Safari User Guide. Click on the Safari Navigation Bar ► Help ► Safari Help

Microsoft Edge: Go to Settings and more (⋯) ► Settings ► Cookies and site permissions ► Manage and delete cookies and site data. Here you can toggle Allow sites to save and read cookie data (first‑party cookies), enable Block third‑party cookies, or disable all cookies entirely. You may also add site-specific Allows or Blocks under exceptions. For broader control, navigate to Settings ► Privacy, search, and services ► Tracking prevention, where you select a protection level: Basic, Balanced, or Strict, with the ability to add exclusion lists. As of the date of this policy, Microsoft maintains a help page explaining how to adjust cookie settings and tracking preferences in Edge

Mobile Browsers

  • Safari on iPhone/iPad (iOS / iPadOS): Use Settings ► Safari ► Privacy & Security to toggle Prevent Cross‑Site Tracking and Block All Cookies; ITP is automatically applied. As of the date of this policy, Apple publishes an up-to-date user guide listing instructions on managing cookies and tracking settings on devices running iOS and iPadOS

  • Chrome and Firefox on Android or iOS: Open the in‑app menu Settings ► Privacy & security, then find Cookies or Site settings to enable or disable cookies and third‑party cookies. Note that site‑specific exception lists may be limited compared to desktop versions. As of the date of this policy, Google publishes provides an official help page with further details on how to manage your cookie preferences on Android and iOS running Chrome

Browser Extensions and Privacy Tools

Several browser extensions and privacy tools can help you manage cookies automatically according to your preferences:

Privacy Badger: Automatically blocks trackers and third-party cookies that don't respect Do Not Track signals

uBlock Origin: A comprehensive ad and tracker blocker that can prevent many types of cookies from being set

Ghostery: Provides detailed information about trackers and cookies on websites and allows you to block them selectively.

CookieBot: Offers automatic cookie consent management and can block cookies until you provide consent

DuckDuckGo Privacy Essentials: Blocks trackers and provides enhanced privacy protection across websites

Mobile Device Settings

Mobile devices often include system-level privacy controls that can affect cookie behaviour in mobile browsers and apps:

iOS: Settings > Safari > Privacy & Security includes options for preventing cross-site tracking and blocking all cookies

Android: Chrome settings include cookie controls, and Android's privacy settings may include additional tracking protection options

App-Specific Settings: If you access our website through mobile apps or social media platforms, check those apps' privacy settings for additional cookie and tracking controls

Do Not Track Signals

Some browsers and privacy tools send "Do Not Track" signals to websites, indicating that users prefer not to be tracked. While there is no universal standard for how websites should respond to these signals, we respect user privacy preferences and provide clear opt-out mechanisms for tracking cookies.

Browser Do Not Track Settings: Most browsers allow you to enable Do Not Track signals in their privacy settings. When enabled, your browser will send a signal to websites indicating your tracking preference

Our Response to Do Not Track: We recognise Do Not Track signals and provide information about how to opt out of tracking cookies through our preference center and this Cookie Policy

Global Privacy Control: We also recognise Global Privacy Control (GPC) signals, which provide a standardised way for users to communicate their privacy preferences to websites.

Third-Party Opt-Out Tools

Many third-party services that set cookies on our website provide their own opt-out mechanisms:

Google Analytics Opt-Out: Google provides a browser add-on that prevents Google Analytics from collecting data: https://tools.google.com/dlpage/gaoptout

Managing Consent Across Devices

If you use multiple devices to access our website, you will need to set your cookie preferences on each device separately, as consent is stored locally on each device. To maintain consistent preferences across devices:

Repeat Preference Settings: Use our cookie preference center on each device where you access our website to ensure consistent privacy settings

Browser Sync: Some browsers can sync privacy settings across devices when you're signed into your browser account

Regular Review: Periodically review your cookie settings on all devices to ensure they still reflect your preferences

Troubleshooting Cookie Issues

If you experience issues with cookie functionality or preference management:

Clear Browser Cache: Sometimes clearing your browser's cache and cookies can resolve issues with preference settings

Disable Browser Extensions: Temporarily disable privacy extensions to determine if they're interfering with our preference center

Check Browser Settings: Ensure your browser settings aren't overriding our website's cookie preferences

Contact Support: If you continue to experience issues, contact our Data Protection Officer for assistance with managing your cookie preferences

  1. Third-party cookies and services

Our website integrates with various third-party services to provide enhanced functionality, analytics, and user experience features. These integrations may result in third-party cookies being set on your device, and it's important that you understand how these services operate and how they handle your personal data

Third-Party Service Integration

We carefully select third-party services based on their privacy practices, security standards, and compliance with applicable data protection laws. All third-party integrations are subject to data processing agreements that ensure appropriate protection for your personal data and compliance with our privacy obligations

Service Selection Criteria: We evaluate third-party services based on their privacy policies, security measures, compliance certifications, data processing practices, and alignment with our privacy principles. We only integrate services that meet our high standards for data protection

Data Processing Agreements: We maintain comprehensive data processing agreements with all third-party services that process personal data on our behalf. These agreements specify the purposes of processing, types of data involved, security requirements, and obligations for data protection compliance

Regular Review: We regularly review our third-party integrations to ensure they continue to meet our privacy and security standards. We may discontinue services that no longer align with our privacy principles or fail to maintain appropriate data protection standards.

Analytics and Performance Services

Google Analytics: We use Google Analytics to understand how users interact with our website and to improve our content and user experience. Google Analytics collects information about your browsing behavior, including pages visited, time spent on site, and traffic sources. This data is processed by Google under their privacy policy and data processing terms

Google Analytics uses cookies to distinguish unique users and sessions, track user interactions, and provide insights into website performance. The data collected is primarily aggregated and anonymised, though it may include IP addresses and other identifiers that could be considered personal data under applicable laws

You can opt out of Google Analytics tracking through our cookie preference center or by using Google's opt-out browser add-on. Google also provides detailed information about their data practices and privacy controls at https://policies.google.com/privacy

Social Media Integration

LinkedIn Integration: Our website includes LinkedIn social media features that allow you to share content and connect with our professional network. LinkedIn may set cookies to track your interactions with these features and to provide personalised social media experiences

LinkedIn's cookies are subject to LinkedIn's privacy policy and cookie practices. If you interact with LinkedIn features on our website, LinkedIn may collect information about your visit and use it for their own analytics and advertising purposes

Bluesky: If we include Bluesky social media widgets that allow you to share content and follow our social media accounts. Bluesky may set cookies to track your interactions with these features and to provide personalised content and advertising

Facebook Integration: If we include Facebook social media features, Facebook may set cookies to track your interactions and provide personalised experiences across Facebook's platform and partner websites

Email Marketing and Communication Services

Common Ninja: We use Common Ninja widgets to manage forms and newsletter management. If you subscribe to our newsletter or marketing communications, CommonNinja may set cookies to track email engagement, manage subscription preferences, and provide analytics about email campaign performance

Common Ninja's cookies help us understand which email content is most engaging and allow us to provide more relevant communications to our subscribers. This data is processed under CommonNinja privacy policy and our data processing agreement with them

Advertising and Marketing Services

Google Ads: If we use Google Ads for advertising, Google may set cookies to track ad performance, measure conversions, and provide insights into advertising effectiveness. These cookies may also be used for retargeting purposes to show relevant ads to users who have previously visited our website

LinkedIn Ads: We may use LinkedIn's advertising platform to reach professional audiences with relevant content and service offerings. LinkedIn may set cookies to track ad interactions and provide analytics about campaign performance

Retargeting Services: With your consent, we may use retargeting services that allow us to show relevant advertisements to users who have previously visited our website when they browse other websites or social media platforms

Third-Party Privacy Controls

Individual Service Opt-Outs: Most third-party services provide their own privacy controls and opt-out mechanisms. We provide links to these controls in our cookie preference center and encourage you to review the privacy policies of any third-party services you interact with

Industry Opt-Out Tools: Several industry organisations provide centralised opt-out tools for advertising and analytics services. These include the Network Advertising Initiative (NAI), Digital Advertising Alliance (DAA), and European Interactive Digital Advertising Alliance (EDAA)

Browser-Based Controls: Your browser's privacy settings can block many third-party cookies automatically. Most modern browsers include options to block third-party cookies while allowing first-party cookies necessary for website functionality

Data Transfers and International Processing

Many third-party services process data internationally, which may involve transferring your personal data to countries outside your jurisdiction. We ensure that all such transfers are protected by appropriate safeguards:

Adequacy Decisions: We prioritise services that process data in countries with adequacy decisions from relevant data protection authorities

Standard Contractual Clauses: For transfers to countries without adequacy decisions, we ensure that appropriate standard contractual clauses or other approved transfer mechanisms are in place

DFP and Successor Frameworks: We monitor developments in international transfer frameworks and ensure our third-party services maintain appropriate certifications and compliance measures

Monitoring and Compliance

Regular Audits: We regularly audit our third-party integrations to ensure they continue to meet our privacy and security standards and comply with applicable data protection laws

Incident Response: We have procedures in place to respond to data breaches or privacy incidents involving third-party services, including notification requirements and remediation measures

Contract Management: We maintain active oversight of our data processing agreements with third-party services and update them as necessary to reflect changes in law or business practices

When you use our website, some of the cookies and data collected may be transferred to and processed in countries outside your jurisdiction. We are committed to ensuring that all international transfers of personal data collected through cookies are protected by appropriate safeguards and comply with applicable data protection laws

Legal Framework for International Transfers

GDPR Requirements: Under the GDPR, transfers of personal data to countries outside the European Economic Area (EEA) require either an adequacy decision from the European Commission or appropriate safeguards such as standard contractual clauses, binding corporate rules, or approved certification mechanisms

UK Data Protection Act: The UK maintains similar requirements for international transfers, with the ICO responsible for adequacy decisions and oversight of transfer mechanisms for data leaving the UK

DIFC Data Protection Law: The DIFC Data Protection Law includes provisions for international transfers that align with international best practices, requiring appropriate safeguards for transfers to countries without adequate protection

Countries and Regions Where Data May Be Processed

United States: Some of our third-party services, including Google Analytics and other technology providers, may process cookie data in the United States. We ensure that appropriate safeguards are in place for these transfers, including standard contractual clauses and adherence to relevant privacy frameworks

European Union: We prioritize processing within the EU/EEA where possible, particularly for users located in these regions. Many of our services are designed to keep EU user data within EU borders

United Kingdom: For UK users, we aim to process data within the UK where feasible, and ensure that any international transfers comply with UK data protection requirements.

Other Jurisdictions: Depending on the third-party services we use, cookie data may be processed in other countries with appropriate data protection frameworks, such as Canada, Switzerland, or other countries with adequacy decisions.

Safeguards for International Transfers

Standard Contractual Clauses (SCCs): We use the European Commission's standard contractual clauses for transfers to countries without adequacy decisions. These clauses provide contractual guarantees that personal data will be protected according to EU standards regardless of where it is processed

Adequacy Decisions: Where possible, we use services that process data in countries with adequacy decisions from relevant data protection authorities, ensuring that these countries provide essentially equivalent protection to EU/UK standards

Binding Corporate Rules: Some of our third-party providers operate under binding corporate rules approved by data protection authorities, providing additional guarantees for international data protection

Certification and Codes of Conduct: We may rely on approved certification mechanisms and codes of conduct that demonstrate compliance with data protection requirements for international transfers

Transfer Impact Assessments

We conduct transfer impact assessments to evaluate the level of protection provided in destination countries and to identify any additional safeguards that may be necessary:

Legal Environment Assessment: We evaluate the legal framework in destination countries, including surveillance laws, data access requirements, and judicial oversight mechanisms

Practical Safeguards: We assess the technical and organisational measures implemented by our service providers to protect data during international transfers

Additional Measures: Where necessary, we implement additional safeguards such as encryption, pseudonymisation, or data minimisation to enhance protection for international transfers

Specific Third-Party Transfer Arrangements

Google Services: Google provides detailed information about their international data transfers and the safeguards they implement. They use standard contractual clauses and maintain certifications under various privacy frameworks to protect data during international transfers

Other Analytics Providers: We ensure that all analytics providers we use have appropriate mechanisms in place for international transfers, including contractual safeguards and technical measures to protect data

Social Media Platforms: Social media integrations may involve international transfers to the platforms' global infrastructure. We provide information about these transfers and ensure that appropriate safeguards are in place

Your Rights Regarding International Transfers

Information Rights: You have the right to receive information about international transfers of your personal data, including the countries involved and the safeguards in place

Objection Rights: In certain circumstances, you may have the right to object to international transfers of your personal data, particularly where you believe adequate protection is not provided

Complaint Rights: If you have concerns about international transfers of your data, you can lodge a complaint with the relevant data protection authority in your jurisdiction.

Monitoring and Compliance

Regular Review: We regularly review our international transfer arrangements to ensure they continue to provide adequate protection and comply with evolving legal requirements

Legal Updates: We monitor changes in international transfer frameworks and update our arrangements as necessary to maintain compliance with applicable laws

Incident Response: We have procedures in place to respond to any issues with international transfers, including mechanisms to suspend transfers if adequate protection cannot be ensured

Minimising International Transfers

Data Localisation: Where possible and practical, we implement data localisation measures to keep personal data within the jurisdiction where it was collected

Regional Processing: We work with service providers that offer regional data processing options to minimise the need for international transfers

Technical Measures: We implement technical measures such as encryption and pseudonymisation to reduce the risks associated with international transfers when they are necessary

  1. Data retention for cookies

We maintain clear policies regarding how long we retain data collected through cookies, ensuring that personal data is not kept longer than necessary for the purposes for which it was collected. Our retention practices comply with applicable data protection laws and are designed to balance legitimate business needs with privacy protection

General Retention Principles

Purpose Limitation: We only retain cookie data for as long as necessary to fulfill the specific purposes for which it was collected. Once these purposes are no longer relevant, we delete or anonymise the data

Legal Requirements: Some data may be retained for longer periods to comply with legal obligations, such as regulatory requirements, tax laws, or litigation holds

Legitimate Interests: In some cases, we may retain data for legitimate business interests, such as security monitoring or fraud prevention, provided this does not override your fundamental rights and freedoms

Data Minimisation: We regularly review our data retention practices to ensure we are not retaining more data than necessary and that retention periods remain appropriate for their intended purposes

Cookie-Specific Retention Periods

Session Cookies: These cookies are automatically deleted when you close your browser session. No long-term retention applies to session cookies as they are designed to be temporary

Essential Cookies: Retention periods for essential cookies vary based on their function, typically ranging from session-only to one year. These periods are set to the minimum necessary for the cookies to fulfll their essential functions

Analytics Cookies: Data collected through analytics cookies is typically retained for 26 months, which is the default retention period for Google Analytics. This period allows for year-over-year comparisons and trend analysis while limiting long-term data accumulation

Marketing Cookies: Marketing cookie data is generally retained for shorter periods, typically 30-90 days, reflecting the shorter-term nature of marketing campaigns and the need to provide timely, relevant advertising

Preference Cookies: User preference data may be retained for up to one year to provide a consistent user experience across visits while ensuring that preferences remain current and relevant

Automated Deletion Processes

Scheduled Deletion: We implement automated processes to delete cookie data when retention periods expire, ensuring consistent application of our retention policies without manual intervention

Regular Audits: We conduct regular audits of our data retention practices to identify any data that should be deleted and to ensure our automated processes are functioning correctly

Exception Handling: We have procedures in place to handle exceptions to standard retention periods, such as legal holds or ongoing investigations, while ensuring these exceptions are properly documented and reviewed

Third-Party Data Retention

Service Provider Agreements: Our agreements with third-party service providers include specific provisions regarding data retention, ensuring that they apply appropriate retention periods and deletion practices

Independent Retention Policies: Third-party services may have their own retention policies that apply to data they collect directly. We provide information about these policies and encourage you to review them

Data Processing Instructions: Where we act as a data controller for third-party processing, we provide specific instructions regarding retention periods and deletion requirements

User-Initiated Deletion

Immediate Deletion: When you withdraw consent for specific cookie categories through our preference center, we immediately stop collecting new data through those cookies and begin the deletion process for existing data.

Account Deletion: If you have an account with us and request account deletion, we will delete associated cookie data in accordance with our standard retention periods unless longer retention is required by law.

Right to Erasure: You can exercise your right to erasure (right to be forgotten) to request deletion of cookie data before standard retention periods expire, subject to certain legal exceptions

Retention for Legal Compliance

Regulatory Requirements: Some cookie data may be retained for longer periods to comply with regulatory requirements, such as financial services regulations or tax obligations

Litigation Holds: In the event of actual or anticipated litigation, we may suspend normal deletion processes and retain relevant data until the matter is resolved

Law Enforcement Requests: We may retain data in response to valid law enforcement requests or court orders, in accordance with applicable legal procedures

Data Anonymisation and Pseudonymisation

Anonymisation Processes: Where possible, we anonymise cookie data after initial processing periods, removing personal identifiers while retaining aggregate insights for legitimate business purposes

Pseudonymisation Techniques: We may use pseudonymisation to reduce the privacy impact of longer retention periods while maintaining the ability to provide services or comply with legal requirements

Aggregate Reporting: Much of our long-term data retention involves aggregate, anonymised reporting that cannot be linked back to individual users

Retention Schedule Management

Documentation: We maintain detailed documentation of our retention schedules, including the legal basis for each retention period and the processes used to implement deletion

Regular Review: Retention periods are reviewed annually to ensure they remain appropriate for their intended purposes and comply with current legal requirements

Updates and Changes: When we update retention periods, we provide notice through this Cookie Policy and ensure that changes are applied consistently across all relevant systems

Cross-Border Retention Considerations

Jurisdictional Requirements: Different jurisdictions may have varying requirements for data retention, and we ensure compliance with the most stringent applicable requirements

Data Localisation: Where required by law, we implement data localisation measures that may affect retention practices and deletion procedures

International Coordination: For data processed across multiple jurisdictions, we coordinate retention and deletion activities to ensure consistent application of our policies

Technical Implementation

System Integration: Our retention policies are integrated into our technical systems to ensure automatic enforcement of deletion schedules and retention limits.

Backup Management: We ensure that our backup and disaster recovery systems also comply with retention requirements, including secure deletion of expired data from backup systems

Audit Trails: We maintain audit trails of data deletion activities to demonstrate compliance with retention policies and legal requirements

11. Your rights regarding cookies

Under applicable data protection laws, including the GDPR, UK Data Protection Act, and DIFC Data Protection Law, you have several important rights regarding how we process your personal data through cookies. We are committed to facilitating the exercise of these rights and providing clear information about how to use them.

Right to Information and Transparency

You have the right to receive clear, comprehensive information about how we use cookies and process your personal data. This Cookie Policy fulfills our transparency obligations by providing detailed information about:

Cookie Purposes: Clear explanations of why we use different types of cookies and what data they collect

Legal Basis: Information about the legal basis for each type of cookie processing, whether consent, legitimate interests, or other lawful grounds

Data Recipients: Details about third-party services that may receive cookie data and their privacy practices

Retention Periods: Specific information about how long different types of cookie data are retained

Your Rights: Comprehensive information about all your rights and how to exercise them

This information is provided in plain language and is easily accessible through our website. We regularly review and update this information to ensure it remains accurate and comprehensive

Right to Consent and Consent Management

Granular Consent: You have the right to provide or withhold consent for different categories of cookies. Our consent mechanism allows you to make specific choices about which types of cookies you want to accept

Informed Consent: We ensure that you have all the information necessary to make informed decisions about cookie consent, including clear descriptions of what each category of cookies does and what data they collect

Withdrawal of Consent: You can withdraw your consent at any time, and withdrawal is as easy as giving consent initially. You can use our cookie preference center to modify your consent choices at any time

Consent Records: We maintain records of your consent choices, including when consent was given or withdrawn, to demonstrate compliance with legal requirements and to honor your preferences

Right of Access

You have the right to access personal data we have collected about you through cookies. This includes:

Confirmation of Processing: We will confirm whether we are processing your personal data through cookies and provide details about the processing activities

Access to Data: Where technically feasible, we can provide you with access to the specific personal data collected through cookies, though much cookie data is automatically deleted after short periods

Processing Information: We will provide information about the purposes of processing, categories of data, recipients, retention periods, and your rights

Source Information: Where cookie data was not collected directly from you (such as through third-party services), we will provide information about the source of the data

To exercise your right of access, contact our Data Protection Officer at compliance@sail.legal with specific details about the information you are requesting

Right to Rectification

If you believe that personal data collected through cookies is inaccurate or incomplete, you have the right to request rectification:

Correction of Inaccurate Data: We will correct any inaccurate personal data without undue delay

Completion of Incomplete Data: You can request that incomplete personal data be completed, including by providing supplementary information

Third-Party Notification: Where we have shared cookie data with third parties, we will inform them of any rectifications unless this proves impossible or involves disproportionate effort

Most cookie data is automatically generated and updated, so rectification requests are less common for cookie data than for other types of personal information

Right to Erasure (Right to be Forgotten)

You have the right to request erasure of personal data collected through cookies in certain circumstances:

Consent Withdrawal: When you withdraw consent for cookie processing and there is no other legal ground for continued processing

No Longer Necessary: When the personal data is no longer necessary for the original purposes for which it was collected

Unlawful Processing: If the processing has been unlawful or violates applicable data protection laws

Legal Obligation: When erasure is required to comply with a legal obligation

We will respond to erasure requests without undue delay and will inform third-party recipients of the erasure where appropriate.

Right to Restriction of Processing

You can request restriction of cookie data processing in specific circumstances:

Accuracy Disputes: While we verify the accuracy of personal data following a challenge from you

Unlawful Processing: When processing is unlawful but you prefer restriction rather than erasure

Legal Claims: When we no longer need the data but you require it for legal claims

Objection Pending: While we verify whether our legitimate grounds override your objection to processing

When processing is restricted, we will only process the data with your consent or for specific legal purposes

Right to Object

You have the right to object to cookie processing in certain circumstances:

Legitimate Interest Processing: You can object to processing based on legitimate interests, including profiling based on such processing

Direct Marketing: You have an absolute right to object to processing for direct marketing purposes, including profiling related to direct marketing

Public Interest or Official Authority: You can object to processing for tasks carried out in the public interest or in the exercise of official authority

When you object to processing, we will stop processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms

Right to Data Portability

Where cookie processing is based on consent or contract and carried out by automated means, you have the right to data portability:

Structured Format: You can request to receive your personal data in a structured, commonly used, and machine-readable format

Transmission to Another Controller: You can request that we transmit your data directly to another controller where technically feasible

No Adverse Effect: Exercising data portability rights will not adversely affect your other rights, including the right to erasure

Data portability is most relevant for user preference data and other information that you have actively provided rather than automatically generated cookie data

Rights Related to Automated Decision-Making

If we use cookies for automated decision-making, including profiling, you have specific rights:

Information Rights: You have the right to receive meaningful information about the logic involved in automated decision-making and its significance and consequences

Human Intervention: You have the right to obtain human intervention in automated decision-making processes

Express Views: You can express your point of view regarding automated decisions and challenge them

Contest Decisions: You have the right to contest automated decisions and request review by human operators

Exercising Your Rights

Contact Methods: You can exercise your rights by contacting our Data Protection Officer at compliance@sail.legal or khaled@sail.legal

Identity Verification: We may request proof of identity to ensure that rights requests are made by the appropriate person and to protect against fraudulent requests

Response Timeframes: We will respond to rights requests within one month of receipt, though this may be extended by up to two months for complex requests

No Fees: We will not charge fees for responding to rights requests unless they are manifestly unfounded or excessive

Limitations and Exceptions

Legal Obligations: Some rights may be limited where processing is necessary to comply with legal obligations or for the establishment, exercise, or defense of legal claims.

Technical Limitations: The technical nature of some cookie processing may limit our ability to provide certain information or take specific actions.

Third-Party Rights: Your rights may be limited where exercising them would adversely affect the rights and freedoms of others

Proportionality: We will balance your rights against other legitimate interests and legal requirements in responding to rights requests

Complaints and Remedies

If you are not satisfied with how we handle your rights requests or have concerns about our cookie practices, you have several options:

Internal Complaints: Contact our Data Protection Officer to raise concerns or complaints about our cookie practices

Supervisory Authorities: You can lodge complaints with relevant data protection authorities, including the ICO (UK), your local EU data protection authority, or the DIFC Commissioner of Data Protection

Judicial Remedies: You may have the right to seek judicial remedies for violations of your data protection rights

Compensation: You may be entitled to compensation for material or non-material damage resulting from violations of data protection law

12. Cookies and similar technologies

12. How to contact us and complaint handling

We are committed to transparency and accessibility in all matters related to cookie usage and data protection. If you have questions, concerns, or requests regarding our cookie practices, we provide multiple ways to contact us and ensure that your inquiries are handled promptly and professionally

Primary Contact Information

Data Controller: SAIL UKS02 Ltd
Company Registration Number: 16535629 (England and Wales)
Registered Address: 60 Tottenham Court Road, Office 80, Fitzrovia, London, W1T 2EW, United Kingdom
Website: www.sail.legal
General Enquiries: compliance@sail.legal

Data Protection Officer

We have appointed a qualified Data Protection Officer (DPO) to oversee our data protection compliance and serve as your primary point of contact for all privacy and cookie-related matters.

Data Protection Officer: Khaled Shivji
Email: compliance@sail.legal
Alternative Email: khaled@sail.legal
Postal Address: 60 Tottenham Court Road, Office 80, Fitzrovia, London, W1T 2EW, United Kingdom

Our Data Protection Officer is responsible for: Monitoring compliance with data protection laws and our internal privacy policies, Providing advice on data protection matters, including cookie usage and consent management, Acting as a contact point for data protection authorities and individuals, Privacy impact assessments and data protection audits, Providing training and guidance to our staff on data protection matters

Response Times and Service Standards

Acknowledgment: We will acknowledge receipt of your inquiry within 2 business days.

Initial Response: We aim to provide an initial substantive response within 5 business days for general inquiries

Rights Requests: We will respond to data subject rights requests within one month of receipt, as required by applicable data protection laws. In complex cases, this may be extended by up to two months, and we will inform you of any extension and the reasons for it.

Urgent Matters: For urgent privacy or security matters, please mark your communication as "URGENT" and we will prioritise your inquiry accordingly

Business Hours: Our standard business hours are Monday through Friday, 9:00 AM to 6:00 PM (UK time), though we monitor communications outside these hours for urgent matters

Types of Inquiries We Handle

Cookie Questions: General questions about our cookie usage, purposes, and data collection practices.

Consent Management: Assistance with managing your cookie preferences, withdrawing consent, or understanding your consent choices.

Rights Requests: Processing requests to exercise your data protection rights, including access, rectification, erasure, restriction, objection, and data portability.

Technical Issues: Help with technical problems related to our cookie preference center or consent management tools

Complaints: Handling complaints about our cookie practices or data protection compliance

Third-Party Services: Questions about third-party services integrated into our website and their cookie practices

Information to Include in Your Communication

To help us respond to your inquiry efficiently, please include the following information when contacting us:

Contact Details: Your full name, email address, and preferred method of communication for our response

Specific Request: A clear description of your question, concern, or request, including any specific cookies or services you're asking about

Website Interaction: Information about when and how you interacted with our website, if relevant to your inquiry

Browser and Device: Details about your browser, device, and any technical issues you may be experiencing

Previous Communications: Reference to any previous communications with us about the same matter

Proof of Identity: For rights requests, we may require proof of identity to ensure we're responding to the appropriate person

Alternative Contact Methods

Postal Mail: You can send written communications to our registered address. Please mark correspondence as "Data Protection Inquiry" to ensure proper routing

Website Contact Form: We may provide a contact form on our website for privacy-related inquiries, which will be routed directly to our Data Protection Officer

Phone Support: While we primarily handle privacy inquiries through email for documentation purposes, we may provide phone support for urgent matters or complex issues that benefit from direct discussion

Language and Accessibility

Language Support: We primarily communicate in English, but we can arrange for translation services if needed for data protection matters

Accessibility: We are committed to making our communications accessible to all users. If you require information in alternative formats or have accessibility needs, please let us know and we will accommodate your requirements

Plain Language: We strive to communicate about privacy and cookie matters in plain, understandable language, avoiding unnecessary technical jargon

Escalation and Complaints

If you are not satisfied with our initial response to your inquiry, you have several options for escalation:

Internal Escalation: Request that your matter be escalated to senior management or our legal team for further review

External Complaints: Lodge a complaint with the relevant data protection authority in your jurisdiction (see the section 'Data Protection Authority Contacts' for specific authority contact information)

Legal Advice: Seek independent legal advice about your rights and options for addressing privacy concerns

Data Protection Authority Contacts

United Kingdom: Information Commissioner's Office (ICO)
Website: https://www.ico.org.uk
Phone: 0303 123 1113
Email: Via online form at ico.org.uk

European Union: Contact your local data protection authority. A complete list is available at https://edpb.europa.eu/about-edpb/board/members_en

DIFC: Commissioner of Data Protection
Email: commissioner@dp.difc.ae
Phone: +971 4 362 2222
Website: https://www.difc.com/business/registrars-and-commissioners/commissioner-of-data-protection

Record Keeping

We maintain records of all privacy and cookie-related communications to ensure consistent service and to demonstrate our compliance with data protection obligations. These records are kept confidential and are only accessed by authorized personnel involved in handling your inquiry

Communication Records: We keep records of all communications related to privacy matters, including emails, letters, and phone calls

Rights Request Tracking: We maintain detailed records of data subject rights requests, including the nature of the request, our response, and any follow-up actions taken

Complaint Handling: We document all complaints and their resolution to identify patterns and improve our privacy practices

Continuous Improvement

We regularly review our communication processes and response procedures to ensure they meet the needs of our users and comply with evolving legal requirements. Your feedback about our privacy communication and cookie practices helps us improve our services and better protect your privacy rights

We may update this Cookie Policy from time to time to reflect changes in our cookie practices, legal requirements, or business operations. We are committed to keeping you informed about any changes and ensuring that you always have access to current, accurate information about our cookie usage

Reasons for Updates

Legal Changes: Updates to data protection laws, regulations, or guidance from supervisory authorities may require changes to our cookie practices and this policy

Technology Changes: New technologies, cookie types, or tracking methods may necessitate updates to our policy to ensure comprehensive coverage

Business Changes: Changes to our services, website functionality, or third-party integrations may require corresponding updates to our cookie practices

Best Practice Evolution: As privacy best practices evolve, we may update our policies to incorporate enhanced protections or improved user controls

User Feedback: We may make changes based on user feedback or questions to improve clarity and usefulness of our policy

Types of Changes

Material Changes: Significant changes that affect your rights or how we process your personal data through cookies, such as new cookie categories, extended retention periods, or additional third-party services

Non-Material Changes: Minor updates such as clarifications, formatting improvements, contact information updates, or corrections that don't substantially affect your rights or our practices

Technical Updates: Changes to reflect new cookie technologies, updated browser capabilities, or enhanced privacy controls

Legal Updates: Changes required to maintain compliance with new or amended data protection laws and regulations

Notification Process

Advance Notice: For material changes, we will provide advance notice through multiple channels to ensure you have time to review the changes and adjust your preferences if desired

Website Notice: We will post a prominent notice on our website announcing significant changes to this Cookie Policy

Email Notification: If you have provided an email address for communications, we may send notification of material changes directly to your email

Consent Re-collection: For significant changes that affect the legal basis for cookie processing, we may request renewed consent through our cookie preference center

Policy Versioning: We maintain version numbers and effective dates for all policy updates to provide clear tracking of changes over time

Review and Approval Process

Internal Review: All policy changes undergo internal review by our legal, privacy, and technical teams to ensure accuracy and compliance

Legal Validation: Material changes are reviewed by qualified legal counsel to ensure compliance with applicable data protection laws

Stakeholder Input: We may seek input from relevant stakeholders, including users, business partners, and privacy advocates, for significant policy changes

Management Approval: All policy changes require approval from senior management and our Data Protection Officer before implementation

Implementation Timeline

Effective Date: All policy changes include a clear effective date when the new provisions take effect

Transition Period: For material changes, we may provide a transition period during which both old and new practices operate to ensure smooth implementation

System Updates: We ensure that our technical systems, including cookie management tools and consent mechanisms, are updated to reflect policy changes

Staff Training: Our staff receive training on policy changes to ensure consistent implementation and accurate responses to user inquiries

Historical Versions

Archive Maintenance: We maintain archives of previous policy versions to provide transparency about how our practices have evolved over time

Access to Previous Versions: Upon request, we can provide access to previous versions of this Cookie Policy for reference or compliance purposes

Change Documentation: We maintain detailed documentation of all policy changes, including the reasons for changes and their implementation dates.

User Rights During Changes

Continued Rights: Your data protection rights continue to apply during policy transitions, and you can exercise these rights under either the current or updated policy terms

Preference Updates: You can update your cookie preferences at any time during policy transitions through our cookie preference center

Withdrawal Rights: You retain the right to withdraw consent for cookie processing at any time, regardless of policy changes

Information Rights: You can request information about how policy changes affect your personal data and privacy rights

Monitoring and Compliance

Compliance Monitoring: We monitor the implementation of policy changes to ensure they are applied consistently and in compliance with legal requirements

User Impact Assessment: We assess the impact of policy changes on users and their privacy rights to ensure that changes enhance rather than diminish privacy protection

Feedback Collection: We actively seek feedback from users about policy changes and their implementation to identify areas for improvement

Regular Review: We conduct regular reviews of our Cookie Policy to ensure it remains current, accurate, and aligned with best practices.

Emergency Updates

Security Updates: In cases of security incidents or urgent privacy concerns, we may implement immediate policy updates with subsequent notification to users

Legal Compliance: If required by law or regulatory order, we may implement immediate changes to ensure compliance, with notification provided as soon as practicable

Incident Response: Policy updates related to data breaches or privacy incidents will be implemented according to our incident response procedures and legal notification requirements

Communication Preferences

Notification Preferences: You can indicate your preferences for receiving notifications about policy changes through our communication preference settings

Opt-Out Options: While we recommend staying informed about policy changes, you can opt out of non-essential policy notifications while still receiving legally required notices

Multiple Channels: We use multiple communication channels to ensure that important policy changes reach all affected users

Questions About Changes

If you have questions about changes to this Cookie Policy or need clarification about how changes affect your rights or our practices, please contact our Data Protection Officer at compliance@sail.legal. We are committed to providing clear explanations and assistance with understanding policy updates

  1. Jurisdiction-specific information

If you have any questions, concerns, or complaints about this privacy policy or our data protection practices, please contact us using the following details:

  • Email: compliance@sail.legal

  • Data Protection Officer: Khaled Shivji

  • Alternative DPO Email: khaled@sail.legal

We take all privacy concerns seriously and will investigate any complaints promptly and thoroughly. We aim to respond to all enquiries within one month of receipt

14.1 Right to Complain to Supervisory Authorities

If you are not satisfied with our response to your complaint or believe that we are processing your personal data in a way that is not lawful, you have the right to lodge a complaint with the relevant supervisory authority. The supervisory authority you can complain to may depend on where you live, where you work, or where you believe the infringement took place

For complaints in the United Kingdom:

Information Commissioner's Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF | Telephone: 0303 123 1113 | Website: https://www.ico.org.uk/makeacomplaint

For complaints in the European Union:

You can find details of your local supervisory authority at: https://edpb.europa.eu/aboutedpb/board/members_en

For complaints in the DIFC:

DIFC Commissioner of Data Protection, Dubai International Financial Centre Authority, Level 14, The Gate Building | Telephone: +971 4 362 2222 | Email: commissioner@dp.difc.ae