Revenue Operations Manager

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

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

This Privacy Policy does not apply to any Personal Information or other data we process on behalf of our enterprise customers (“Enterprise Data”). Our processing of Enterprise Data is governed by contracts we have in place with our enterprise customers, not this Privacy Policy and our enterprise customers’ respective privacy policies govern their collection and use of Personal Information. Any questions or requests relating to the privacy practices of any of our enterprise customers should be directed to the applicable customer. This Privacy Policy also does not apply to Sardine workers or job applicants. Details about how we process your Personal Information if you apply for a job at Sardine or work for us are covered in our Applicant and Worker Privacy Notice.

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

A. Personal Information You Provide to Us Directly

We may collect Personal Information that you provide to us directly when you interact with our Services.

• Account Creation. If you create an account to register or transact with us as a transacting user, we will collect Personal Information including your full legal name, date of birth, email address, phone number, government identifying information, and payment information. We may also require you to provide additional Personal Information as required by law or for compliance purposes, as a condition for continuing use of aspects of our Services, for example to confirm your identity and your purpose in using the Services.
• Transactions. We collect Personal Information and details associated with transacting users’ transactions, including payment information.
• Your Communications with Us. We may collect Personal Information, such as email address, phone number, or mailing address when you request information about our Services, register for email or other messages from us, contact customer service, request technical support, or otherwise communicate with us.
• Surveys and Questionnaires. We may contact you to participate in surveys, request that you complete a questionnaire or otherwise seek your input. If you decide to participate, we may collect Personal Information from you in connection with your feedback or other responses.
• Promotional Activities. We may sponsor or make promotional offers from time to time as part of our marketing and awareness-raising activities. If you elect to participate in such promotions, such as sweepstakes or contests, we may collect your Personal Information to administer the offer, event or activity. In some jurisdictions, we may be legally required to disclose Personal Information about winners of certain types of promotions.
• Interactive Features. We and others who use our Services may collect Personal Information if you elect to use any of our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you may elect to provide using any public sharing features of the Services will be considered “public,” unless otherwise required by applicable law, and is not subject to the provisions of this policy.
• Conferences, Trade Shows, and Other Events. We may collect Personal Information from individuals when we attend or host conferences, trade shows, and other events.
• Business Development and Strategic Partnerships. We may collect Personal Information from individuals and third parties to assess and pursue potential business opportunities.

B. Personal Information Collected Automatically

We may collect Personal Information automatically when you use our Services.

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

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

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

C. Personal Information Collected from Other Sources

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

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

A. Provide Our Services

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

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

B. Administrative Purposes

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

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

C. Marketing and Advertising our Products and Services

We may use Personal Information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. If you have any questions about our marketing practices or if you would like to opt out of the use of your Personal Information for marketing purposes, please see Your Privacy Choices and Rights or Contact Us at any time.

D. With Your Consent

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

E. Other Purposes

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

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

A. Disclosures to Provide our Services

The categories of third parties with whom we may disclose your Personal Information are described below. To the extent we provide Personal Information to our affiliates or service providers, we do so to enable them to process such Personal Information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures. With respect to onward transfers under the Data Privacy Framework, the Data Privacy Framework requires that Sardine remain liable for onward transfers of Personal Information in a manner inconsistent with the Data Privacy Framework Principles as outlined in our Data Privacy Framework Statement.

• Service Providers. We work with third-party service providers and vendors that assist us with the provision of our Services. This includes service providers and vendors that provide us with IT support, hosting, payment processing, settlement services, fraud detection, identity verification providers, and related services. When we disclose information with third-party service providers in this capacity, we require them to use your information on our behalf in accordance with our instructions and terms and only process your personal information as necessary to provide the Services to you pursuant to the terms of a binding contract between them and Sardine. We may disclose your information with payment processing companies to process and settle payments transacting users initiate when using our Services. If you are a transacting user, we will also disclose