SENTILINK PRIVACY POLICY

Last updated: May 11, 2020

Welcome to the Website of SentiLink Corp., a Delaware corporation ("SentiLink," "we," or "us"). This privacy policy describes our collection of personal information from users of our Website at www.sentilink.com ("Website" or "Site"), as well as all related applications, widgets, software, tools, and other services provided by us (collectively, together with the Website, our "Service"). This policy may be supplemented by additional privacy statements, terms or notices provided to you. This policy also describes our use and disclosure of such information. By using our Service, including accessing our Website, you consent to the collection and use of personal information in accordance with this policy.

  1. PERSONAL INFORMATION

"Personal information," as used in this policy, is information that  identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. Such personal information includes an individual’s name, social security number, telephone number, or e-mail address, information about an individual’s activities, including about his or her activity on the Site or credit history, and demographic information, including date of birth, gender, address, geographic area, and preferences.

Personal information does not include aggregate or deidentified information or other non-personally identifiable information. Aggregate information is information that we collect about a group or category of products, services, or users that cannot be linked back to any particular individual(s) . We may use and disclose aggregate information, deidentified information and other non-personally identifiable information, for various purposes.

  1. COLLECTION OF INFORMATION

From the first moment you interact with us, we are collecting personal information about you. Sometimes we collect personal information automatically when you interact with our services and sometimes we collect the personal information directly from you. At times, we may collect personal information about you from other sources and third parties, even before our first direct interaction.

  1. Passive Information Collection

When you use the Service, some information may be automatically collected, such as your IP address, browser type, system type, the content and pages that you access on the Site, the "referring URL" (i.e., the page from which you navigated to the Site), the site you visit immediately after leaving the Site, as well as the time you spend on the Site.

We collect this information passively using technologies such as standard server logs, cookies (see below for additional information), and clear GIFs (also known as "web beacons"). We use passively-collected information to administer, operate, and improve the Services and our other services and systems, and to provide services and content that are tailored to you. If we link or associate any information gathered through passive means with personal information, we treat the combined information as personal information under this policy. Otherwise, we use information collected by passive means in non-personally identifiable form only.

We and our third-party providers may use (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect this personal information. For example, our websites use Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to collect and view reports about the traffic on our websites. More information about the use of Google Analytics for these analytical and non advertising purposes can be obtained by visiting Google’s privacy policy and Google’s currently available opt-out options are available here.

To manage cookies, an individual may change their browser settings to: (i) notify them when they receive a cookie, so the individual can choose whether or not to accept it; (ii) disable existing cookies; or (iii) automatically reject cookies.  Please note that doing so may negatively impact an individual’s experience using our websites, as some features and offerings may not work properly or at all.  Depending on an individual’s device and operating system, the individual may not be able to delete or block all cookies. In addition, if an individual wants to reject cookies across all browsers and devices, the individual will need to do so on each browser on each device they actively use. An individual may also set their email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether they have accessed our email and performed certain functions with it.

Also, please be aware that third parties may set cookies on your hard drive or use other means of passively collecting information about your use of their services or content. We do not have access to, or control over, these third-party means of passive data collection.

  1. Collection of Voluntarily Provided Information

We may collect personal information that our users provide to us in a variety of ways through our Service. For instance, when you request information about our Service or otherwise communicate with us, we collect the personal information that is provided to us. We may collect personal information such as name, telephone number, mailing address, e-mail address, city, state, country, other demographic information, and your interests and preferences in these manners.

  1. Information from Other Sources and Third Parties

We may receive information about you, including personal information, from third parties, and may combine this information with other personal information we maintain about you. If we do so, this policy governs any combined information that we maintain in personally identifiable format. We receive personal information related to you from third parties, including, but not limited to, consumer reporting agencies, publicly-available sources and data suppliers, businesses with which you interreact with or otherwise seek to obtain services from, businesses with which we offer co-branded services, service providers retained to perform Services on our behalf, and social media providers.

  1. Use of Personal Information

We use personal information to provide services and information that you request; to enhance, improve, operate, and maintain the Site and Service, our programs, services, website, and other systems; to prevent fraudulent use of our Site and Service; to tailor your user experience; to maintain a record of our dealings with you; to conduct research and analytics to understand our customers; to develop new products; to ensure internal quality control; to communicate about customer accounts and activities; to comply with regulatory and legal requirements; to prevent, investigate or provide notice of fraud or unlawful or criminal activity, and enforce and carry out contracts and agreements between us and you; to protect the safety of any person, to address fraud, security or technical issues; or to protect our rights or property; and for other administrative and internal business purposes.

For marketing purposes, we may analyze and use personal information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. We may provide you with these materials by phone, postal mail, email, as permitted by applicable law. We allow you to opt-out from receiving marketing communications from us as described in the "Choice" section below.

We may also use aggregate information, deidentified information or other non-personally identifiable information that does not personally identify you in order to understand better how our visitors use the Services, research our visitors’ demographics, interests, and behavior, improve the Services, provide visitors with customized services and information, and for other similar purposes. We may share this information with others for information or promotional purposes, and may use such information in any manner permitted by law.

  1. Disclosure of Personal Information

We will not disclose your personal information to third parties without your consent, other than as described in this policy. We may disclose personal information to vendors and service providers: (i) in connection with the provisioning of IT and related services or as otherwise required to assist us in our work; (ii) to provision information and Services you have requested; (iii) in connection with customer service activities; (iv) for fraud prevention purposes; (v) for analytics services; and/or (vi) in connection with the provisioning of the Services. We limit the personal information provided to these service providers to that which is reasonably necessary for them to perform their functions.

We may share personal information about you if we reasonably believe that disclosing the information is needed to: (i) comply with any valid legal process, governmental request, or applicable law, rule, or regulation; (ii) investigate, remedy, or enforce potential violations of any agreement you or a third party may have with us; (iii) protect the rights, property, and safety of us, our customers, or others; or (iv) detect and resolve any fraud or security concerns. We may also disclose personal information if otherwise permitted by applicable law.

In addition, information about our users, including personal information, may be disclosed as part of any merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which personal information could be transferred to third parties as one of our business assets.

  1. CHOICE

If you receive commercial emails from us and would like to opt out of such communications, you may do so by replying to your SentiLink point-of-contact expressing these sentiments, emailing privacy@sentilink.com with such sentiments, or, if available, unsubscribing by following the instructions contained within the email.

  1. LINKS

For your convenience, the Site may contain links to other websites, products, or services that we do not own or operate. If you choose to visit or use any third-party products or services, please be aware that this policy will not apply to your activities or any information you disclose while using third-party products or services or otherwise interacting with third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.

  1. CHILDREN

Children’s safety is important to us, and we encourage parents and guardians to take an active interest in the online activities of their children. Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If you are under the age of 13, please do not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.

  1. INTERNATIONAL VISITORS

Our Site and Service is hosted in the United States and is generally intended for United States visitors. If you visit from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please be aware that you are transferring personal information to the United States. The United States does not have the same data protection laws as the European Union and some other regions. By providing personal information to us, you consent to the transfer of it to the United States and the use of it in accordance with this policy.

  1. SECURITY

We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our Service.  However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%.  In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate and required, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

  1. UPDATES TO THIS POLICY

We may occasionally update this policy. When we do, we will also revise the "last updated" date at the beginning of the policy. Your continued use of this Service after such changes will be subject to the then-current policy. We encourage you to periodically review this policy to stay informed about how we collect, use, and disclose personal information.

  1. CONTACTING US

If you have any questions, comments, concerns, or complaints about this privacy policy or your personal information, please contact us at privacy@sentilink.com.

  1. SUPPLEMENTARY NOTICES

  1. California Privacy Rights

If you are a resident of the State of California in the United States, please click here for additional California-specific privacy disclosures.  


CALIFORNIA PRIVACY NOTICE

Last Updated: May 11, 2020

Scope of Disclosures

This California Privacy Notice (the “CA Disclosures”) supplements the information contained in our privacy policy and applies solely to individual residents of the State of California ("consumers" or "you"). These CA Disclosures describe how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (CCPA).  Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our privacy policy or as otherwise defined the CCPA.  

Personal Information Disclosures

When we use the term “personal information” in these CA Disclosures, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

For the purposes of these Disclosures, personal information does not include:

  • Publicly available information from government records.
  • Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.
  • Information excluded from the CCPA's scope, such as:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
  • Information relating to our job applicants, employees, contractors and other personnel.

Collection and Use of Personal Information

We collect various categories of personal information in connection with our Services. Please review the privacy policy to learn more about the personal information we collect.

In the last 12 months, we have collected the following categories of personal information:

Category of Personal Information Collected

Collected

Categories of Sources

Identifiers, such as your name, address, phone number, email address, date of birth or other similar identifiers.

  • Directly from you
  • Our business partners and affiliates
  • Third parties you direct to share information with us
  • Social networks
  • Data sellers

California Customer Records (Cal. Civ. Code § 1798.80(e))

  • Directly from you
  • Our business partners and affiliates
  • Third parties you direct to share information with us
  • Social networks
  • Data sellers

Protected Classification Characteristics

Commercial Information

  • Directly from you

Biometric Information

Internet/Network Information

  • Your browser or device

Geolocation Data

  • Your browser or device

Sensory Information

Profession/Employment Information

  • Directly from you
  • Third parties you direct to share information with us

Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99)

Other Personal Information

  • Directly from you
  • Your device

Inferences

  • Your browser or device
  • Information generated or derived from your online browsing and usage activity

Purposes for Collecting Personal Information

We collect personal information from and about you for a variety of purposes. To learn more about the types of personal information we collect, the sources from which we collect or receive personal information, and the purposes for which we use this information, please refer to the privacy policy.

Disclosure of Personal Information

We do not sell personal information and will not sell personal information unless we provide proper notice to consumers and, in the case of personal information collected prior to that notice, we obtain explicit consent for the sale of personal information relating to those individuals we previously interacted with.  

Recipients of Personal Information

As described in our privacy policy, we share personal information with third parties for business purposes or we may sell your personal information to third parties, subject to your right to opt out of those sales (see The Right to Opt-Out of Personal Information Sales below).

We disclose your personal information to the following categories of third parties:

  • Our service providers: We engage a number of third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, customer service, email delivery services, marketing and advertising services, and other similar services, subject to contractual terms restricting the collection, use and disclosure of your personal information for any other commercial purpose.  
  • Third parties at your request. We share your personal information with third parties with your consent or at your direction.
  • SentiLink’s Customers. We may share personal information with SentiLink customers who have engaged us to provide services, subject to those businesses obtaining your consent where they are required by law to do so.
  • Businesses as needed to provide Services. We may share personal information with third parties you engage with through our Service, or as needed to fulfil your request or transaction, including, for example, order fulfilment, payment processing, or delivery or shipping services.
  • Security providers. We may share your personal information with third-party security providers, for example, to detect, prevent, or otherwise address actual or suspected fraud, harassment, security or technical issues, violations of any law, rule or regulation;
  • Business partners. We may disclose personal information to third parties with whom we partner to provide contests, joint promotional activities or co-branded services, and such disclosure is necessary to fulfil your request or application;
  • Other third parties. From time to time, we may disclose your personal information to third parties who use this information to market to you, to perform analytics and conduct research, or for other purposes, in accordance with their own privacy policies and terms;
  • Analytics providers. We work with third party analytics providers to better understand the demographics of our users and visitors, and to personalize, enhance and improve our Service;
  • Social networks. We may disclose personal information, such as a unique identifier, hashed email address, or information automatically collected through tracking technologies, to social networks for the purpose of displaying personalized advertising and content on those social networks;
  • Law enforcement and third parties pursuant to legal request. From time to time, we may disclose personal information as reasonably necessary to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
  • Third parties in the context of a corporate transaction. We may disclose personal information as reasonably necessary to evaluate, negotiate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about consumers is among the assets transferred or is otherwise relevant to the evaluation, negotiation or conduct of the transaction.

Your California Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):

The Right to Know

You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:

  • The specific pieces of personal information we have collected about you;
  • The categories of personal information we have collected about you;
  • The categories of sources of the personal information;
  • The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
  • The categories of personal information we have sold and the categories of third parties to whom the information was sold; and
  • The business or commercial purposes for collecting or selling the personal information.

The Right to Request Deletion

You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.

The Right to Opt Out of Personal Information Sales

You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future.

If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.

The Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising these rights.

However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

“Shine the Light”

California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83).

How to Exercise Your California Consumer Rights

To Exercise Your Right to Know or Right to Deletion

To exercise your Right to Know and/or your Right to Deletion, please submit a request by:

  • Emailing privacy@sentilink.com with the subject line “California Rights Request,” or
  • Calling 877-6-SNTLNK (877-6-76-8565)

We will need to verify your identity before processing your request, which may require us to request additional personal information from you. We will only use personal information provided in connection with a Consumer Rights Request to review and comply with the request.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

Minors Under Age 16

We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the "Right to Opt In") from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.  Please contact us at privacy@sentilink.com to inform us if you, or your minor child, are under the age of 16.  

California’s “Shine the Light” Law

In addition to the rights described above, California's "Shine the Light" law (Civil Code Section §1798.83) permits California residents that have an established business relationship with us to request certain information regarding our disclosure of certain types of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year.

To make such a request, please send an email to privacy@sentilink.com .

Financial Incentives

We do not offer financial incentives or price or service differences to consumers in exchange for the retention or sale of a consumer’s personal information:

Updates to These CA Disclosures

We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the "Last Updated" date at the beginning of these Disclosures. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us

If you have any questions or requests in connection with this Notice or other privacy-related matters, please send an email to privacy@sentilink.com