Effective Date: 12 April 2020
Sentio Solutions Inc. (registered in the United States, 870 Market Street, San Francisco, CA 94102), and its affiliates (collectively Sentio, we, us or our) care about your privacy and are committed to protecting your Personal Data in accordance with fair information practices and applicable data privacy laws. The Greek branch of Sentio (Sentio Solutions Inc. Greek Branch, Skalidi 16-18, Katechaki, Athens 11525, Greece) is the controller of Personal Data collected from European Economic Area (“EEA”) residents.
Scope Of This Privacy Notice
This Privacy Notice (“Notice”) explains how we collect and use individuals’ Personal Data (“you” or “user”) in the course of our operations, including our websites, mobile applications, the Feel program, the Feel Relief Program and other services provided by us (collectively the “Services”). Personal Data is all information relating to an identified or identifiable individual, and does not include data whereby personally identifiable information has been removed (such as anonymous data).
Please read this Notice carefully. If you do not agree with this Notice or any part thereof, you should not access or use any part of the Services, or otherwise provide us with your Personal Data. If you change your mind in the future, you should stop using the Services and provide us with no further Personal Data.
We collect Personal Data in a variety of ways through our normal business activities, in both online and offline contexts. This includes, for example, when you place orders or purchase our products or Services, enter into agreements or communicate with us, or visit and use our website or our mobile app (“App”). We also receive Personal Data from our customers in order to perform Services on their behalf and from social networks, or third party partners such as analytics.
What Personal Data We Collect
Use of the Services is voluntary. To the extent you choose to use the Services, we may collect Personal Data about you directly from you or from third parties, as listed below:
How We Use Personal Data
We use personal data in the context of our normal business activities, which includes the following purposes:
When you visit our websites or otherwise request us to provide a service, we will notify you in those cases in which the information is required (i) to provide our Services or (ii) by law. Where your Personal Data is required, we may be unable to provide you with our Services unless you provide us with the relevant information.
IP Addresses and Cookies
Like other websites, our website uses your domain, IP address, device and browser information to administer the products and Services we offer to you, to improve our products and Services, and for security purposes.
We apply appropriate technical, physical and organizational measures that are reasonably designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, in particular where Personal Data is transferred over a network, and against all other unlawful forms of processing. Access to Personal Data is restricted to authorized recipients on a need-to-know basis. We maintain a comprehensive information security program that is proportionate to the risks associated with the processing. The program is continuously adapted to mitigate operational risks and to ensure the protection of Personal Data taking into account industry-accepted practices. We also use enhanced security measures (e.g. encryption) when processing sensitive Personal Data. However, the transfer of Personal Data through the internet carries its own inherent risks and we do not guarantee the security of your data transmitted through the internet. You make any such transfer at your own risk.
We may use third parties, such as our partners and service providers, to provide or perform Services and functions on our behalf. We may make Personal Data concerning individuals available to these third parties, as necessary, to perform these Services and functions. Any access to such Personal Data will be limited to the purpose for which the information was provided.
We may also make Personal Data concerning individuals available to public or judicial authorities, law enforcement personnel and agencies as required by law. Where permitted by law, we may also disclose such information to third parties (including legal counsel) when necessary for the establishment, exercise or defense of legal claims or to otherwise enforce our rights, protect our property or the rights, property or safety of others, or as needed to support external audit, compliance and corporate governance functions.
Personal Data may be transferred to a party acquiring all or part of the equity or assets of Sentio or its business operation in the event of a sale, merger, liquidation, dissolution, or sale or transfer of the substantial assets of Sentio or any of its business operations. We may also transfer and share such information to our affiliates within the group, in compliance with applicable law.
We may disclose your Personal Data to third parties with your consent.
We are not responsible for the content or privacy and security practices and policies of third-parties or Services to which links or access are provided through our service. We encourage you to learn about third-parties’ privacy and security policies before providing them with your information.
Personal Data provided to Sentio will be processed by us inside the European Economic Area and will be accessed by our staff and third parties working for us for the purposes set forth in this notice or for other purposes subject to your approval. Your Personal Data may be also held, processed and accessed outside the European Economic Area to countries that have not been determined by the European Commission to provide an adequate level of data protection, for instance the United States. In any such transfer, Sentio will ensure that appropriate data protection safeguards (e.g. European Commission’s Standard Contractual Clauses) are in place. To obtain a copy of the relevant transfer mechanism or additional information on the transfers, please contact us using the contact information below.
Your Options and Rights
By providing Personal Data to us, you understand and agree to the collection, processing, international transfer and use of such information as set forth in this Privacy Notice. Where required by applicable law we will ask your explicit consent.
You may elect to opt-out of our Services at any time by providing Sentio with written or electronic notice. Upon receipt of such notice, we will cease contacting you and sharing information concerning you. Please note that if you withdraw your consent, we will be unable to provide you with our Services.
You may access the Personal Data that Sentio has on file for you and you may ask that we revise your Personal Data to ensure that it is current and correct. Please note that while any changes you make will be reflected in active user databases within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so under applicable law.
If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained in the email. You may also opt out from receiving commercial email from us and any other promotional communications that we may send to you from time to time, by contacting us via the contact details at the end of this Policy.
If you opt out of receiving commercial email from us or otherwise modify the nature or frequency of such emails, it may take up to ten business days for us to process your request. During that time, you may continue to receive promotional communications from us. If you opt out of receiving commercial messages from us, you will still receive administrative messages from us regarding our Services.
If you are located in the EEA, you may exercise these additional rights in relation to your Personal Data that we hold:
Please contact us if you wish to exercise any of these rights. Before processing your requests, we will ask for your identification to ensure you are the requestor. In certain situations, and subject to applicable law, we may not be able or obliged to grant part or all of your individual requests. We also have the right to refuse and/or charge a monetary fee for requests which are manifestly unfounded or excessive, for example because of their repetitive character. You have the right under applicable data protection law to lodge a complaint with a Supervisory Authority.
We will retain your Personal Data for so long as necessary for the purposes for which they were collected. When determining the retention period, we take into account various criteria, such as the type of products and Services requested by or provided by you, possible re-enrolment with our Service and the impact on the Services we provide you if we delete some information from or about you. We will also retain your Personal Data as required under applicable retention policies or as permitted by applicable law.
The Services are not directed to children, and we do not knowingly collect Personal Data from anyone under the age of 18. If you learn that a child has provided us with Personal Data in violation of this Policy, please contact us as indicated below.
Updates to our Privacy Notice
This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our Personal Data practices. We will post a prominent notice on our website to notify you of any significant changes to our Privacy Notice and indicate when it was most recently updated. You should also check this page from time to time to ensure that you are happy with any changes..
How to Contact Us
We welcome all requests, suggestions and questions concerning our use of your information. All such communication should be directed to firstname.lastname@example.org. You can also write to us at: 870 Market Street, Suite 1166, San Francisco, CA, 94102, USA.