Privacy Policy

Last updated: October 9, 2020

This Privacy Policy explains how Sentropy Technologies, Inc. (“Sentropy”, “we” or “us”) collects, uses, discloses, and otherwise processes information about you when you access or use our websites, applications, purchase and use our digital trust and safety services, and use our other online products and services that link to this Privacy Policy (collectively, the “Services”), contact our customer service team, or otherwise communicate with us as a current or prospective customer. This policy does not, however, apply to the information that we process on behalf of our customers, such as user profile data, content or messages posted on our customers’ accounts, platforms or properties.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access or use our Services to stay informed about our information practices and the choices available to you.

Collection of Information

Information You Provide to Us

We collect information about you when you access or use our Services, participate in a contest such as a hackathon, apply for a job, request customer support, or otherwise communicate with us. For example, we may collect your name, job title, company name, address, email address, phone number, payment information, social media profile information and contents where you choose to login to our Services through your social media account, and any other information you choose to provide.

Other Information We Collect When You Use our Services

When you access or use our Services, we automatically collect information about you, including:

• Log Information: We collect log data, such as information about the computer you use to access our Services, including the hardware model, operating system and version, unique device identifiers, the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to our Services.
• Usage Data: We collect data about your use of the Services, page views, which features you use, the links you click on, and other ways you interact with the Services.
• Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use different technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, and as part of our efforts to keep our website safe and secure in reliance on our legitimate interests in ensuring the security of our website. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see Your Choices below.

Information We Collect from Other Sources

We may also obtain information about you from other sources. For example, we may collect information about you from public databases or social media platforms. Additionally, if you create or log into your Sentropy account through a third-party platform, we will have access to certain information from that platform, such as your name, birthday, profile picture, lists of your friends or followers, the content you post, and the content that others post that mentions you, in accordance with the authorization procedures determined by such platform. This information may include the following: mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, LinkedIn URLs or custom profiles.

Use of Information

We use the information we collect about you to:

• Provide, maintain and improve our products and Services;
• Personalize and improve your experience on our Services;
• Send you technical notices, updates, security alerts, and support and administrative messages and to respond to your comments, questions, and customer service requests;
• Communicate with you about products, services, and events offered by Sentropy and others, and provide news and information we think will be of interest to you (see Your Choices below for information about how to opt out of these communications at any time);
• Facilitate contests, hackathons and similar initiatives;
• Monitor and analyze trends, usage, and activities in connection with our Services;
• Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Sentropy and others;
• Identify and repair errors in our Services;
• Comply with our legal and financial obligations; and
• Carry out any other purpose described to you at the time the information was collected.

Sharing of Information

We share information about you as follows or as otherwise described in this Privacy Policy:

• With vendors, service providers, and consultants that perform services for us, including processing payments, providing customer support, and hosting our infrastructure;
• With professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services they render to us;
• With other customers, to help you connect with each other;
• In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
• If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of Sentropy or others;
• In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
• Between and among Sentropy and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership; and
• With your consent or at your direction.

We may also share aggregated or de-identified information that cannot reasonably be used by those third parties to identify you.

Analytics Services Provided by Others

We may allow others to provide analytics services on our behalf across the web and in mobile applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by Sentropy and others to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.

Transfer of Information to the U.S. and Other Countries

Sentropy is based in the United States and we process and store information in the U.S. Therefore, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.

If you are in the European Economic Area, we provide adequate protection for the transfer of personal data to countries outside of the EEA through a series of intercompany agreements based on theStandard Contractual Clauses authorized under EU law. You are entitled to obtain a copy of these agreements by contacting us using the contact information below.

We comply with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union, the United Kingdom and/or Switzerland to the United States, respectively. Sentropy has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, we are committed to resolving complaints about our processing of your personal data. EU, UK and Swiss individuals with inquiries or complaints regarding our compliance with the Privacy Shield program should first contact us. We have further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit the JAMS website for more information or to file a complaint. The services of JAMS are provided at no cost to you.

Under certain conditions, you may be able to invoke binding arbitration to resolve your complaint. Sentropy is subject to the investigatory and enforcement powers of the Federal Trade Commission.

If we share personal data transferred to the U.S. under the Privacy Shield with a third-party service provider that processes such data on our behalf, then we will be liable for that third party’s processing in violation of the Privacy Shield Principles, unless we can prove that we are not responsible for the event giving rise to the damage.

Your Choices

Account Information

You may update certain account information you provide to us at any time by emailing us at privacy@sentropy.com. If you wish to delete your account, please email us at privacy@sentropy.com, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Promotional Information

You may opt out of receiving promotional emails from Sentropy by following the instructions in those emails or by emailing us at unsubscribe@sentropy.com. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

Additional Disclosures for Individuals in Europe

If you are located in the European Economic Area or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data. For purposes of the information about you discussed in this Privacy Policy, Sentropy Technologies, Inc. is the data controller.

Legal Basis for Processing

When we process your personal data, we will only do so in the following situations:

• We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the products or services you have requested).
• We have a legitimate interest in processing your personal data. For example, we may process your personal data to send you marketing communications, to communicate with you about changes to our products and Services, and to provide, secure, and improve our products and Services.
• To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).
• We find such processing is necessary to comply with our legal obligations.
• We have your consent to do so. When consent is the legal basis for our processing, you may withdraw such consent at any time.

Data Subject Requests

Subject to certain limitations, you have the right to request access to the personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, please see our Individual Rights Request form.

Questions or Complaints

If you have questions or concerns about our processing of personal data, please contact us or our authorized representative in the EEA by writing to sentropy@gdprrepresentative.eu. If we are not able to resolve your issue, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your Data Protection Authority, please see the EU's list of Data Protection Authorities, or for Swiss residents, see the FDPIC's contact page.

If you are located in the United Kingdom or the EEA, you may contact Achieved Compliance Advocacy, Ltd., our appointed representative in the UK and the EU, at the following addresses:

In the EU

Singel 250, 1016 AB, Amsterdam, Netherlands
sentropy@gdprrepresentative.eu

In the UK

Princess House, Princess House Way, Swansea, UK SA1 3LW
sentropy@privacyrep.co.uk

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Contact Us

If you have any questions about this Privacy Policy, please contact us at:

Sentropy Technologies, Inc.
Attn: Privacy Officer
380 Portage Ave
Palo Alto, CA 94306
Email: privacy@sentropy.com