Last modified April 16, 2018
1. Websites covered
2. Information collected
When expressing an interest in obtaining additional information about the related applications and Services offered by Sentient Technologies or registering to use the Services, Sentient Technologies may require you to provide personal contact information, such as name, company name, address, phone number, and email address. Sentient Technologies may also ask you to provide additional information, such as company annual revenues, number of employees, or industry. The information described in this paragraph is referred to collectively as “Website User Data.”
In addition, when you visit the Websites, Sentient Technologies and its partners may collect certain information by automated means, such as cookies or similar technologies (“Website Navigational Information”). A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. We also may use third-party website analytics tools (such as Omniture or Google), that collect information about visitor traffic on our sites. The information we may collect by automated means includes: standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on Websites (such as the Web pages viewed and the links clicked) to analyze trends in the aggregate and administer the site.
3. Use of information collected
Sentient Technologies uses Website User Data to perform the services requested. For example, if you fill out a “Contact Me” Web form, Sentient Technologies will use the information provided to contact you about your interest in the Services.
Sentient Technologies may also use Website User Data for marketing purposes. For example, Sentient Technologies may use information you provide to contact you to further discuss your interest in the Services and to send you information regarding Sentient Technologies and its partners, such as information about promotions or events.
Sentient Technologies uses credit card information solely to check the financial qualifications of prospective Customers and to collect payment for the Services.
Sentient Technologies uses Website Navigational Information to operate and improve the Websites. Sentient Technologies may also use Website Navigational Information alone or in combination with Website User Data to provide personalized information about Sentient Technologies usage.
We also use your personal data for secondary purposes such as internal audits, physical and information security and other monitoring activities to ensure security and compliance with local laws and regulations.
4. Website Navigational Information
Cookies and IP Addresses
Sentient Technologies uses commonly-used information-gathering tools, such as cookies or similar technologies, to collect Website Navigational Information. This section describes the types of Website Navigational Information that may be collected on the Websites and how this information may be used.
Cookies – When you visit the Websites, Sentient Technologies’ servers send a cookie to your computer. Standing alone, cookies do not personally identify you; they merely recognize your Web browser.
If you have chosen to identify yourself to Sentient Technologies, Sentient Technologies uses session cookies containing encrypted information to be able to uniquely identify you. Each time you log into the Services, a session cookie containing an encrypted, unique identifier that is tied to your account is placed your browser. These session cookies allow Sentient Technologies to uniquely identify you when you are logged into the Services and to process your online transactions and requests. Session cookies are required to use the Services.
Sentient Technologies uses persistent cookies that only Sentient Technologies can read and use to identify browsers that have previously visited the Websites. When you purchase the Services or provide Sentient Technologies with personal information, a unique identifier is assigned you. This unique identifier is associated with a persistent cookie that Sentient Technologies places on your Web browser. Sentient Technologies is especially careful about the security and confidentiality of the information stored in persistent cookies. For example, Sentient Technologies does not store account numbers or passwords in persistent cookies. If you disable your Web browser’s ability to accept cookies, you will be able to navigate the Websites, but you will not be able to successfully use the Services.
Sentient Technologies may use information from session and persistent cookies in combination with Website User Data to provide you with information about Sentient Technologies and the Services.
To learn how to opt out of certain cookies using your browser settings click here.
IP Addresses – When you visit the Websites, Sentient Technologies collects your IP addresses to track and aggregate non-personal information. For example, Sentient Technologies uses IP addresses to monitor the regions from which Customers and Visitors navigate the Websites.
Do Not Track – Currently, various browsers – including Internet Explorer, Firefox, and Safari – offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to Websites visited by the user about the user’s browser DNT preference setting. Sentient Technologies does not currently commit to responding to browsers’ DNT signals with respect to the Websites, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. Sentient Technologies takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.
5. Sharing of Information Collected
Sentient Technologies uses third parties who provide services on our behalf to help with our business activities such as managing our credit card processing. Our contracts with these companies prohibits them from using your information for any other purpose.
Sentient Technologies reserves the right to use or disclose information provided if required by law, such as to comply with a subpoena, or if Sentient Technologies reasonably believes in good faith that use or disclosure is necessary to protect Sentient Technologies’ rights, protect your safety or the safety of others and/or to comply with a judicial proceeding, court order, government request or legal process.
Sale to a Third Party
If Sentient Technologies, or substantially all of its business or assets, is acquired by a third party, Website User Data would be one of the assets that is transferred or acquired by the successor or acquirer. You will be notified via email and/or a prominent notice on our website of any change in (i) ownership; (ii) uses of your personal information; and (iii) choices you may have regarding your personal information.
6. International transfer of information collected
To facilitate Sentient Technologies’ global operations, Personal Data collected on our websites may be stored and processed in the United States and any other country in which Sentient Technologies or its affiliates or joint ventures maintains facilities or has operations, including countries which may not have data protection laws similar to the laws in the country from which you initially provided the information. By choosing to use our websites and to provide data to them, you consent to any such transfer of information outside of your country.
Sentient Technologies participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov.
Sentient Technologies is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Sentient Technologies complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Sentient Technologies is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
7. Communications preferences
Sentient Technologies offers Customers and Visitors who provide contact information a means to choose how Sentient Technologies uses the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of Sentient Technologies’ marketing emails. Additionally, you may send a request specifying your communications preferences to firstname.lastname@example.org. Customers cannot opt out of receiving transactional emails related to their account with Sentient Technologies or the Services.
8. Correcting, updating, and deleting your information
At any time, you can request access to your personal information, request that any inaccuracies be corrected, and request that comments or explanations be added to records about you.
You can also ask about:
- whether and why we have your personal information;
- how we got your personal information;
- what we have done with your personal information;
- to whom we have communicated your personal information;
- where your personal information has been stored, processed or transferred;
- how long we will retain your personal information, or how that retention period will be determined; and
- the safeguards in place to protect your information when it is transferred to third parties or third countries.
Finally, you can ask us not to collect or use your personal information for certain purposes, you can ask us to delete your personal information, or you can ask us to provide your personal information to a third party.
Depending on which laws apply to your personal information, we will explain your legal rights, the reason for our refusal and any recourse you may have.
We will respond to your request without undue delay within 30 days. Sentient Technologies reserves the right to take reasonable steps to verify customer identity prior to granting access or processing changes or corrections.
9. Right to Complain to Supervisory Authority
If you have any complaint about the way in which your personal information has been handled, you may raise the matter with your immediate line manager. If your complaint relates to your immediate line manager, or is something which does not relate to your immediate work area, you may raise the matter with either the appropriate HR representative or the next level of leadership (above your immediate line manager). Complaints should be made in writing and copied to an appropriate HR representative. You may also contact the Central Data Privacy Team at email@example.com.
We commit to investigating and resolving complaints about our collection or use of your personal information. To make a complaint, contact us at firstname.lastname@example.org.
Clearly state the following to help us address the issue effectively:
- The specific data privacy complaint (please provide as much detail as possible including country, Sentient Technologies company/ brand, your understanding of the data privacy infringement and issues, redress requested);
- Your full name and how we can contact you;
- Any previous correspondence on this specific data privacy issue.
For European Union Residents
If you are in the EU, you should contact email@example.com to resolve your complaint, regardless of which of our companies the complaint is about. If you are not satisfied with our resolution of your complaint, you may complain to the Dutch Data Authority located at https://autoriteitpersoonsgegevens.nl/en/contact-dutch-dpa/contact-us We commit to cooperating with the panel established by the EU data protection authorities (DPAs) or the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by the panel or the FDPIC with regard to personal information transferred from the EU or Switzerland. For the Federal Trade Commission. In some conditions, you may be able to invoke binding arbitration to resolve your complaint where your personal information has been transferred to and processed in the United States.
For United States residents
If you are not satisfied with our resolution of your complaint, you can make a privacy complaint to the Federal Trade Commission or you can make a consumer reporting complaint to the Consumer Financial Protection Bureau.
For Canadian residents
If you are not satisfied with our resolution of your complaint, you may be able to make a complaint to one of the following regulatory agencies. Upon resolution of your complaint, we will let you know which of these, if any, may apply to your situation.
- Office of the Privacy Commissioner of Canada
- Office of the Information and Privacy Commissioner of Alberta
- Office of the Information and Privacy Commissioner for British Columbia
- Commission d’accès à l’information du Québec
We aim to resolve all issues in a timely manner, or as mandated by local law, but if this is not possible because a more detailed investigation is required, we will keep in regular contact with you to ensure that you are kept informed of the resolution of your matter.
10. Data retention
Sentient Technologies will retain the information we receive as described in this Privacy Statement for as long as your account is active or as needed to provide you services and to fulfill the purposes for which the data was collected. Sentient Technologies will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
11. Customer Data
As part of using our Services, Customers may submit electronic data or information to the Services (“Customer Data”) which may include personal information. The use of information collected through our Services shall be limited to the purpose of providing the service for which the Customer has engaged Sentient Technologies. Sentient Technologies generally has no direct relationship with the individuals to whom Customer Data may pertain, which we process on the behalf of our Customers. Any uses of Customer Data by Sentient Technologies are done so pursuant to Sentient Technologies’ Master Services Agreement (MSA). If personal information pertaining to you as an individual has been submitted to us by a Customer as Customer Data and you wish to exercise any rights you may have to access, correct, amend, or delete such data, please inquire with the Customer (or his/her organization) directly. If an authorized Customer requests that we update or remove the data in question and the Customer has no ability to do so via use of the Services, we will acknowledge their request within 30 days. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Customers.
We will retain personal data we process on behalf of our Customers for as long as needed to provide services to our Customer. Sentient Technologies will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
The security, integrity and confidentiality of your information are extremely important to us. Sentient Technologies uses commercially reasonable administrative, technical, and physical security measures that are designed to protect Website User Data, but unfortunately, no security measures are perfect or impenetrable. If you have any questions about the security of your personal information, you can contact us at firstname.lastname@example.org.
13. Children’s Guidelines
This site is a general audience site, although it contains information that may be of interest to children. However, Sentient Technologies does not knowingly collect information from children under the age of 16. If Sentient Technologies becomes aware that it has collected information from a child, it will immediately delete that information.
15. Automated Processing
We do not make decisions about you, automated or otherwise, and do not attempt to analyze or predict your behavior, preferences, interests, health or other personal characteristics. However, we may carry out automated processing on our client’s instructions. For more information about automated processing of personal information on behalf of a client, please contact the client.
16. Changes to this Privacy Statement
Sentient Technologies reserves the right to change this Privacy Statement. Sentient Technologies will provide notification of the material changes to this Privacy Statement through the Websites at least thirty (30) business days prior to the change taking effect. We encourage you to periodically review this page for the latest information on our privacy practices.
17. Contacting Us
If you have questions or suggestions regarding this privacy statement or our handling of personal data, please contact by email, or by mail at Sentient Technologies Privacy, 1 California St, Suite 2300, San Francisco, CA 94111.
Europe: European Data Protection Officer David White, email@example.com