Privacy Policy

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PRIVACY NOTICE

Last updated September 18, 2020

Thank you for choosing to be part of our community at SentiSpec ApS ("Company", "we",
"us", "our"). We are committed to protecting your personal information and your right to
privacy. If you have any questions or concerns about this privacy notice, or our practices
with regards to your personal information, please contact us at [email protected].

When you visit our website http://www.sentispec.com (the "Website"), use our mobile
application, as the case may be (the "App") and more generally, use any of our services
(the "Services", which include the Website and App), we appreciate that you are trusting us
with your personal information. We take your privacy very seriously. In this privacy notice,
we seek to explain to you in the clearest way possible what information we collect, how we
use it and what rights you have in relation to it. We hope you take some time to read
through it carefully, as it is important. If there are any terms in this privacy notice that you do
not agree with, please discontinue use of our Services immediately.

This privacy notice applies to all information collected through our Services (which, as
described above, includes our Website and App), as well as, any related services, sales,
marketing or events.

Please read this privacy notice carefully as it will help you understand what we do
with the information that we collect.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?


2. HOW DO WE USE YOUR INFORMATION?
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
4. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
5. HOW LONG DO WE KEEP YOUR INFORMATION?
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
7. DO WE COLLECT INFORMATION FROM MINORS?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO WE MAKE UPDATES TO THIS NOTICE?
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
13. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE
COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?


Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser
and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use or navigate the Services.
This information does not reveal your specific identity (like your name or contact
information) but may include device and usage information, such as your IP address,
browser and device characteristics, operating system, language preferences, referring
URLs, device name, country, location, information about how and when you use
our Services and other technical information. This information is primarily needed to
maintain the security and operation of our Services, and for our internal analytics and
reporting purposes.

The information we collect includes:

▪ Log and Usage Data. Log and usage data is service-related, diagnostic, usage and
performance information our servers automatically collect when you access or use
our Services and which we record in log files. Depending on how you interact with
us, this log data may include your IP address, device information, browser type and
settings and information about your activity in the Services (such as the date/time
stamps associated with your usage, pages and files viewed, searches and other
actions you take such as which features you use), device event information (such as
system activity, error reports (sometimes called 'crash dumps') and hardware
settings).

Information collected through our App

In Short: We collect information regarding your mobile device, push notifications, when
you use our App.

If you use our App, we also collect the following information:

▪ Mobile Device Data. We automatically collect device information (such as your


mobile device ID, model and manufacturer), operating system, version information
and system configuration information, device and application identification numbers,
browser type and version, hardware model Internet service provider and/or mobile
carrier, and Internet Protocol (IP) address (or proxy server). If you are using our App,
we may also collect information about the phone network associated with your
mobile device, your mobile device’s operating system or platform, the type of mobile
device you use, your mobile device’s unique device ID and information about the
features of our App you accessed.
▪ Push Notifications. We may request to send you push notifications regarding your
account or certain features of the App. If you wish to opt-out from receiving these
types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our App, for
troubleshooting and for our internal analytics and reporting purposes.

2. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business


interests, the fulfillment of our contract with you, compliance with our legal obligations,
and/or your consent.

We use personal information collected via our Services for a variety of business purposes
described below. We process your personal information for these purposes in reliance on
our legitimate business interests, in order to enter into or perform a contract with you, with
your consent, and/or for compliance with our legal obligations. We indicate the specific
processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

▪ To facilitate account creation and logon process. If you choose to link your
account with us to a third-party account (such as your Google or Facebook account),
we use the information you allowed us to collect from those third parties to facilitate
account creation and logon process for the performance of the contract.

▪ To post testimonials. We post testimonials on our Services that may contain


personal information. Prior to posting a testimonial, we will obtain your consent to
use your name and the content of the testimonial. If you wish to update, or delete
your testimonial, please contact us at [email protected] and be sure to include your
name, testimonial location, and contact information.

▪ Request feedback. We may use your information to request feedback and to


contact you about your use of our Services.

▪ To enable user-to-user communications. We may use your information in order to


enable user-to-user communications with each user's consent.

▪ To manage user accounts. We may use your information for the purposes of
managing our account and keeping it in working order.

▪ To send administrative information to you. We may use your personal


information to send you product, service and new feature information and/or
information about changes to our terms, conditions, and policies.

▪ To protect our Services. We may use your information as part of our efforts to keep
our Services safe and secure (for example, for fraud monitoring and prevention).
▪ To enforce our terms, conditions and policies for business purposes, to
comply with legal and regulatory requirements or in connection with our
contract.

▪ To respond to legal requests and prevent harm. If we receive a subpoena or


other legal request, we may need to inspect the data we hold to determine how to
respond.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provide you
with services, to protect your rights, or to fulfill business obligations.

We may process or share your data that we hold based on the following legal basis:

▪ Consent: We may process your data if you have given us specific consent to use
your personal information for a specific purpose.

▪ Legitimate Interests: We may process your data when it is reasonably necessary to


achieve our legitimate business interests.

▪ Performance of a Contract: Where we have entered into a contract with you, we


may process your personal information to fulfill the terms of our contract.

▪ Legal Obligations: We may disclose your information where we are legally required
to do so in order to comply with applicable law, governmental requests, a judicial
proceeding, court order, or legal process, such as in response to a court order or a
subpoena (including in response to public authorities to meet national security or law
enforcement requirements).

▪ Vital Interests: We may disclose your information where we believe it is necessary


to investigate, prevent, or take action regarding potential violations of our policies,
suspected fraud, situations involving potential threats to the safety of any person and
illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in
the following situations:

▪ Business Transfers. We may share or transfer your information in connection with,


or during negotiations of, any merger, sale of company assets, financing, or
acquisition of all or a portion of our business to another company.

4. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?


In Short: We may transfer, store, and process your information in countries other than your
own.

Our servers are located in. If you are accessing our Services from outside, please be aware
that your information may be transferred to, stored, and processed by us in our facilities and
by those third parties with whom we may share your personal information (see "WILL
YOUR INFORMATION BE SHARED WITH ANYONE?" above), in and other countries.

If you are a resident in the European Economic Area, then these countries may not
necessarily have data protection laws or other similar laws as comprehensive as those in
your country. We will however take all necessary measures to protect your personal
information in accordance with this privacy notice and applicable law.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined
in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes
set out in this privacy notice, unless a longer retention period is required or permitted by law
(such as tax, accounting or other legal requirements). No purpose in this notice will require
us keeping your personal information for longer than 90 days.

When we have no ongoing legitimate business need to process your personal information,
we will either delete or anonymize such information, or, if this is not possible (for example,
because your personal information has been stored in backup archives), then we will
securely store your personal information and isolate it from any further processing until
deletion is possible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational


and technical security measures.

We have implemented appropriate technical and organizational security measures designed


to protect the security of any personal information we process. However, despite our
safeguards and efforts to secure your information, no electronic transmission over the
Internet or information storage technology can be guaranteed to be 100% secure, so we
cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third
parties will not be able to defeat our security, and improperly collect, access, steal, or
modify your information. Although we will do our best to protect your personal information,
transmission of personal information to and from our Services is at your own risk. You
should only access the Services within a secure environment.

7. DO WE COLLECT INFORMATION FROM MINORS?


In Short: We do not knowingly collect data from or market to children under 18 years of
age.

We do not knowingly solicit data from or market to children under 18 years of age. By using
the Services, you represent that you are at least 18 or that you are the parent or guardian of
such a minor and consent to such minor dependent’s use of the Services. If we learn that
personal information from users less than 18 years of age has been collected, we will
deactivate the account and take reasonable measures to promptly delete such data from
our records. If you become aware of any data we may have collected from children under
age 18, please contact us at [email protected].

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time.

If you are a resident in the European Economic Area and you believe we are unlawfully
processing your personal information, you also have the right to complain to your local data
protection supervisory authority. You can find their contact details
here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are a resident in Switzerland, the contact details for the data protection authorities are
available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a
Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference
not to have data about your online browsing activities monitored and collected. At this stage
no uniform technology standard for recognizing and implementing DNT signals has been
finalized. As such, we do not currently respond to DNT browser signals or any other
mechanism that automatically communicates your choice not to be tracked online. If a
standard for online tracking is adopted that we must follow in the future, we will inform you
about that practice in a revised version of this privacy notice.

10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding
access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our
users who are California residents to request and obtain from us, once a year and free of
charge, information about categories of personal information (if any) we disclosed to third
parties for direct marketing purposes and the names and addresses of all third parties with
which we shared personal information in the immediately preceding calendar year. If you
are a California resident and would like to make such a request, please submit your request
in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with a
Service, you have the right to request removal of unwanted data that you publicly post on
the Services. To request removal of such data, please contact us using the contact
information provided below, and include the email address associated with your account
and a statement that you reside in California. We will make sure the data is not publicly
displayed on the Services, but please be aware that the data may not be completely or
comprehensively removed from all our systems (e.g. backups, etc.).

11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated
by an updated "Revised" date and the updated version will be effective as soon as it is
accessible. If we make material changes to this privacy notice, we may notify you either by
prominently posting a notice of such changes or by directly sending you a notification. We
encourage you to review this privacy notice frequently to be informed of how we are
protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection
Officer (DPO), Andreas Claudi, by email at [email protected], by phone at 40822222, or
by post to:

SentiSpec ApS
Andreas Claudi
Strandvejen
Vejle 7120
Denmark

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM
YOU?

Based on the applicable laws of your country, you may have the right to request access to
the personal information we collect from you, change that information, or delete it in some
circumstances. To request to review, update, or delete your personal information,
please submit a request form by clicking here. We will respond to your request within 30
days.

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