Legal

Privacy Policy

Effective date: September 25, 2026

Sulaco AI, Inc. (“Sulaco,” “we,” “us,” or “our”) builds and deploys AI for travel and hospitality operators. We handle our clients' data with the same care we expect for our own. This policy explains what personal information we collect, how we use and share it, and the choices and rights you have.

1. Scope of This Policy

This Privacy Policy applies to personal information we collect through our website (sulaco.ai), our forms, workshops, free resources, and communications, and when we deliver our AI solutions — including agentic AI, AI prompting, process automation, API integration, AI model comparison, and training & support (together, the “Solutions”).

When we process data on behalf of a client as part of an engagement (“Client Data”), we act as a service provider or processor. In that case the client's own privacy notice governs, and our handling of that data is set out in the applicable services agreement, statement of work, or data processing agreement (each an “Engagement Agreement”). If an Engagement Agreement conflicts with this policy, the Engagement Agreement controls.

2. Information We Collect

Information you give us. When you contact us, register for a workshop, apply for a partnership, or engage us, we may collect:

  • Identifiers and contact details — name, email address, phone number, job title.
  • Business information — company name, company website, industry, and details about your goals, market, and timeline.
  • The contents of messages, questionnaires, and files you send us.
  • Billing and contract details for clients (payments are handled by our payment providers; we do not store full card numbers).

Information collected automatically. When you visit our website we and our providers may collect:

  • Device and usage data — IP address, browser type, operating system, referring URLs, pages viewed, and time on page.
  • Approximate location derived from IP address.
  • Cookie and similar-technology data (see Cookies and Tracking).

Information from third parties. We may receive business contact and company information from B2B data and sales-intelligence providers (such as Apollo.io), professional networks, event partners, and referral partners, and combine it with information we already hold.

3. How We Use Information

We use personal information to:

  • Respond to inquiries, schedule consultations, and deliver workshops, resources, and Solutions.
  • Prepare proposals, perform Engagement Agreements, invoice, and provide support.
  • Send business communications and marketing you can opt out of at any time.
  • Understand and improve our website, content, and services.
  • Protect the security and integrity of our systems and prevent fraud or misuse.
  • Comply with legal obligations and enforce our agreements.

We use Client Data only to provide the Solutions described in the relevant Engagement Agreement and as the client instructs. We do not use Client Data to market to anyone, and we do not use it to train general-purpose AI models.

4. AI Models and Third-Party AI Providers

Our Solutions may send data to third-party AI model and cloud providers (for example, providers of large language models, hosting, and vector storage) to generate outputs, automate workflows, or run integrations. When we do:

  • We prefer enterprise or API offerings whose terms do not permit the provider to train its models on submitted data, and we identify the providers used in each engagement on request.
  • We limit the data sent to what the task requires, and we can apply redaction, pseudonymization, or client-hosted deployments where the engagement calls for it.
  • Automated outputs are designed to support — not replace — human decision-making. We do not use your personal information for automated decisions that produce legal or similarly significant effects about you.

5. How We Share Information

We do not sell personal information, and we do not share it for cross-context behavioral advertising. We share it only with:

  • Service providers who help us operate — website hosting, email, CRM and sales tools, scheduling, payment processing, analytics, and AI and cloud infrastructure — under contracts that limit their use of the data.
  • Partners you ask us to work with, or co-host a workshop or event you register for.
  • Professional advisers such as lawyers, accountants, and insurers.
  • Authorities when required by law, or to protect the rights, property, or safety of Sulaco, our clients, or others.
  • A successor in a merger, acquisition, financing, or sale of assets, subject to this policy.

6. Cookies and Tracking

Our website uses cookies, pixels, and scripts that are strictly necessary to run the site, and analytics and sales-intelligence tools — including the Apollo.io website tracker — that help us understand visits and may identify the company associated with a visitor's IP address.

You can block or delete cookies through your browser settings, and many browsers let you send a Global Privacy Control (GPC) signal, which we treat as an opt-out request where the law requires it. Blocking cookies may affect how parts of the site work.

7. Data Retention

We keep personal information only as long as needed for the purposes above — generally for the length of our business relationship plus the period required for legal, tax, and accounting purposes. Client Data is retained and returned or deleted as the Engagement Agreement specifies. Inquiries that do not lead to a relationship are periodically reviewed and deleted.

8. Security

Security is core to how we work. We use administrative, technical, and physical safeguards appropriate to the sensitivity of the data — including encryption in transit, access controls based on least privilege, multi-factor authentication, and vendor security review. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. If a breach affects your personal information, we will notify you and the authorities as the law requires.

9. Your Privacy Rights

Depending on where you live (including California, Colorado, Connecticut, Texas, Virginia, and other U.S. states, the EU/EEA, and the UK), you may have the right to:

  • Know and access the personal information we hold about you.
  • Correct inaccurate information.
  • Delete your information.
  • Receive a portable copy of your information.
  • Opt out of marketing, targeted advertising, and any sale or sharing of personal information.
  • Object to or restrict certain processing, and withdraw consent where we rely on it.
  • Appeal our decision on your request, and complain to your data protection authority.

To exercise these rights, email info@sulaco.ai. We will verify your request and respond within the time the law requires. You may use an authorized agent, and we will not discriminate against you for exercising your rights. If your request concerns Client Data, we will direct it to — or help — the relevant client.

You can unsubscribe from marketing emails at any time with the link in the email.

10. International Visitors

Sulaco is based in the United States, and we process information in the U.S. and in other countries where our providers operate. For individuals in the EU/EEA or UK, our legal bases are performance of a contract, our legitimate interests in running and growing our business, compliance with legal obligations, and consent where required. Where we transfer personal data internationally, we rely on appropriate safeguards such as Standard Contractual Clauses.

11. Children

Our website and Solutions are intended for businesses and are not directed to children under 16. We do not knowingly collect personal information from children. If you believe a child has given us information, contact us and we will delete it.

13. Changes to This Policy

We may update this policy from time to time. We will post the updated version here with a new effective date, and where changes are material we will provide additional notice.

14. Contact Us

Questions or requests about this policy or your personal information: Sulaco AI, Inc., Fort Lauderdale, Florida, USA — info@sulaco.ai or +1 (970) 760-6021. You can also reach us through our contact page.