Privacy Policy

Revised as of [May 28, 2024]

We respect your privacy.

Estuary Technologies, Inc. ("Estuary,” “we,” “us,” or “our”) welcomes you. Our collection and use of information from visitors of our Website and Customers of our Product and related services (collectively with the Website and Product, the “Services”) is subject to the following privacy policy (the “Privacy Policy”), which may be updated by us from time to time without notice to you.

By visiting our Website, visitors are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use.

By using the Website, or by signing up to access and use the Services, you acknowledge that you have read, understood and agree to be legally bound by the terms of this Privacy Policy and the accompanying Terms of Use. If you do not agree to (or cannot comply with) all of the terms of this Privacy Policy and the Terms of Use, you may not access or use the Services.

If you accept or agree to this Agreement on behalf of a company or other legal entity, you represent and warrant that you have the authority to bind that company or other legal entity to the Agreement and, in such event, “you” and “your” will refer and apply to that company or other legal entity and any Authorized Users.

Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use or the Master Software Agreement, as applicable.

THE INFORMATION WE COLLECT AND HOW WE USE IT

In the course of operating the Services, Estuary collects or receives the following types of information from you, which may include personal information:

Contact Information

We collect contact information through our Services; contact information typically includes your name, email address, and any information you provide in messages to us. We use such contact information for purposes such as providing you with information about the Services, responding to your inquiries, sending you email alerts (including marketing emails), registering you as an Authorized User of the Product, and providing you the Services.

Payment Information

If you purchase the Product, to process your payment you will be required to provide to us certain billing information, which may include providing a credit card number, expiration date, bank account information, billing address, activation code, and similar information (collectively, “Payment Information”). You authorize our third-party payment vendors including, without limitation, Stripe, to collect, process, and store such Payment Information in accordance with their respective privacy policies. We reserve the right to change our payment vendors at any time, or to use additional payment vendors, at our discretion, and will update this Privacy Policy from time to time accordingly. By purchasing the Product, you agree to be bound by Stripe’s terms and conditions and privacy policy, which are available at https://stripe.com/legal and https://stripe.com/us/privacy, respectively.

Activity Information

We will have access to any Customer Content that you submit to us for our portability services. Customer content includes: (i) the data that Customer, or its Client, as applicable, requests Estuary to transfer from one system to another, (ii) configuration information to connect to the relevant systems, such as passwords and user identifications, and (iii) other information provided to Estuary to help configure how and when the data transfer will occur, such as notification preferences. We only access and use the Customer Content to provide you the data portability services.

Server Log Information

Our servers and CookieFirst (discussed below) keep log files that record data each time a device accesses the servers. The log files contain the following items:

Your consent status or the withdrawal of consent
Your IP address
Information about your Browser
Information about your Device
The date and time you have visited our website, and the pages you’ve clicked on while on our Services and time spent on the Services
The webpage url where you saved or updated your consent preferences
The approximate location of the user that saved their consent preference
A universally unique identifier (UUID) of the website visitor that clicked the cookie banner
Other similar data about the nature of your access and how you use the Services

We may use these log files for purposes such as assisting in monitoring and troubleshooting errors and incidents, analyzing traffic, or optimizing the user experience.

We may collect information using “cookie” and other similar technologies. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive (or other storage medium) so that your computer will “remember” information about your use. We use both first and third party session cookies and persistent cookies. Below is a general primer on session and persistent cookies; information collected by cookies depends on its particular purpose. For more information, please see the information regarding analytics providers discussed further below.

Session Cookies: We use session cookies to make it easier for you to navigate our Services. A session ID cookie expires when you close the Services.
Persistent Cookies: A persistent cookie remains on your device for an extended period of time or until you delete them. Persistent cookies enable us to track and target the interests of our visitors to personalize the experience on our Services. Also, to the extent we provide a log-in portal or related feature on our Services, persistent cookies can be used to store your passwords so that you don’t have to enter it more than once.

To obtain and record your consent for the use and storage of cookies, we use a consent management platform: CookieFirst. This technology is provided by Digital Data Solutions BV, Plantage Middenlaan 42a, 1018 DH, Amsterdam, The Netherlands. Website: https://cookiefirst.com referred to as CookieFirst.

When you access our website, a connection is established with CookieFirst’s server and we seek consent from you regarding the use of certain cookies. If approved, CookieFirst then stores a cookie in your browser, which then activates only those cookies to which you have consented (and documents such activity accordingly). The data processed is stored until the predefined storage period expires or you request to delete the data. Certain mandatory legal storage periods may apply notwithstanding the aforementioned.

For the avoidance of doubt, CookieFirst is used to obtain the legally required consent for the use of cookies. The legal basis for this is article 6(1)(c) of the General Data Protection Regulation (GDPR).

We have concluded a data processing agreement with CookieFirst. This is a contract required by data protection law, which ensures that data of our website visitors is only processed in accordance with our instructions and in compliance with the GDPR.

Third-Party Analytics Providers

We use one or more third–party analytics services to evaluate your use of the Services, as the case may be, by compiling reports on activity (based on their collection of IP addresses, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, data and time, amount of time spent on particular pages, what sections of the Services you visit, number of links clicked, search terms and other similar data with respect to how you use the Services) and analyzing performance metrics. These third parties use cookies and other technologies to help collect, analyze, and provide us reports or other data.

By accessing and using the Services, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, including how to opt out from certain data collection, please visit the sites below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Services.

For Google Analytics, please visit: https://www.google.com/analytics

For Hotjar, please visit: https://www.hotjar.com/legal/policies/privacy/

For Mailchimp please visit: https://mailchimp.com/legal/privacy/

For HubSpot please visit: https://legal.hubspot.com/privacy-policy

Third-Party OAuth Providers

The use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Aggregate Data

In an ongoing effort to better understand our users and the Services, we might analyze data with respect to how you use the Services, including Usage Data, alone and in combination with other data (including anonymized elements of the Customer Content), and may use such combined data in an aggregate and anonymous manner to operate, maintain, manage, and improve the Services. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics to describe the Services to current and prospective business partners and to other third parties for other lawful purposes.

Onward Transfer to Third Parties

Like many businesses, we hire other companies to perform certain business-related services. We may disclose personal information to certain types of third party companies but only to the extent needed to enable them to provide such services. The types of companies that may receive personal information and their functions are: hosting services, technical assistance, database management/back-up services, usage analytics, email marketing platforms, customer service, collaboration services, authentication services, and authorization services.
To provide our Services and administer promotional programs, we may share your personal information with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs.
We may, from time to time, share and/or license personal information to other companies who may provide you information about the products and services they or their partners offer. However, to the extent required by law, you will be given the opportunity to opt out of such sharing.
We may share personal information and Customer Content with third party systems in connection with the Services and to enable use of the Product, such as when you use the Product to move data to or from one system to another.
We may also disclose personal information to our parent companies, subsidiaries, affiliates, joint ventures, or other companies under common control to support the marketing and sale of our products and services.

Business Transfers

In the event of a merger, dissolution, reorganization or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Policy. This policy shall be binding upon Estuary and its legal successors in interest.

Disclosure to Public Authorities

We are required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

OPT-OUT FOR DIRECT MARKETING; EMAIL MANAGEMENT

You may opt out at any time from the use of your personal information for direct marketing purposes by emailing the instructions to privacy@estuary.dev or by clicking on the “Unsubscribe” link located on the bottom of any Estuary marketing email and following the instructions found on the page to which the link takes you. Please allow us a reasonable time to process your request. You cannot opt out of receiving transactional e-mails related to the Services.

HOW WE PROTECT YOUR INFORMATION

Estuary takes very seriously the security and privacy of the personal information that it collects pursuant to this Privacy Policy. Accordingly, we implement reasonable security measures designed to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in processing and the nature of such data, and to comply with applicable laws and regulations. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share your information (as permitted herein), nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

CHILDREN

We do not knowingly collect personal information from children under the age of 13 through the Services. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide personal information without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us at privacy@estuary.dev, and we will endeavor to delete that information from our databases.

IMPORTANT NOTICE TO ALL NON-US RESIDENTS

Our servers are located in the US and elsewhere. Please be aware that your information may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your country of origin. If you are located outside the United States and choose to use the Services, you do so at your own risk.

CALIFORNIA PRIVACY RIGHTS

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact Estuary via email at privacy@estuary.dev.

DO NOT TRACK

Estuary does not respond to “Do Not Track” settings or other related mechanisms at this time.

NEVADA PRIVACY RIGHTS

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at privacy@estuary.dev with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.

LINKS TO EXTERNAL WEBSITES

The Services may contain links to third-party websites (“External Sites”). Estuary has no control over the privacy practices or the content of any such External Sites. As such, we are not responsible for the content or the privacy policies of such External Sites. You should check the applicable privacy policy and terms of use when visiting any such External Sites.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is effective as of the last updated date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time with or without notice to you. By accessing the Services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the information collected is governed by the Privacy Policy in effect at the time we collect the information. Please refer back to this Privacy Policy on a regular basis.

HOW TO CONTACT US

If you have questions about this Privacy Policy, please e-mail us at privacy@estuary.dev with “Privacy Policy” in the subject line.