“Personal Data,” as used in this Policy, refers to all types of personal information including:
“Personal Information” or any information in the possession of, or likely to come into the possession of Senti, from which the identity of an individual is apparent or can be reasonably and directly ascertained by Senti, or when put together with other information would directly and certainly identify an individual
“Sensitive Personal Information” or personal information: i) about an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations; ii) about an individual’s health, education, genetic or sexual life of a person, or to any proceeding for any offense committed or alleged to have been committed by such individual, the disposal of such proceedings, or the sentence of any court in such proceedings; iii) issued by the government agencies peculiar to an individual which includes, but is not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; and, iv) specifically established by an executive order or an act of Congress to be kept classified.
Senti is primarily engaged in the business of providing artificial intelligence solutions and services. In order to do so, Senti relies in the data collected from persons accessing its Website (the “Website Visitors”), persons using the Services (the “Customers”), persons authorized or allowed by Customers to use the Services (the “Authorized Users”), and data publicly available online (the “Third Party Content”).
Personal Data Collected
Customer – In order to provide the Services, Senti requires its Customers to provide certain contact information (name and email address, mailing address, phone number, title) as well as financial/billing information (billing name and address, credit card numbers).
Third Party Content – Finally, the Services collect, process and store information, that may include personal information (name, address, contact information, educational information, employment history), from a variety of publicly available online sources, such as social networking sites, blogs and news websites. This information is sourced only from content that has been made publicly available on the internet and is used solely to provide the Services. The only parts of this Policy that are applicable to Third Party Content are in contained in the Third Party Content section below.
Senti uses the technical information about the Website Visitors in order to tailor your experience at the Website, to deliver content that Senti thinks you might be interested in, to display the content according to your preferences and to improve the Website.
Senti uses contact information from Website Visitors in order to fulfil your requests (for example, to provide you with additional information about the Services). If you are a Customer, Senti uses your contact information in order to provide you with the Services. For example, your contact information is used to provide support and account management services and to alert you to system outages. Senti also uses contact information from the Website Visitors and Customers for marketing purposes to send you information about the company, its affiliates and its products and services. You can opt out of receiving such mailings by clicking on the unsubscribe link in any email and following the instructions.
Senti uses financial/billing information to evaluate the Customers’ creditworthiness and to collect payment of the fees for the Services.
Data Protection Measures
Senti has in place industry standard security measures to protect against the loss, misuse or alteration of the personal information under its control, including through the use of physical, organizational, and technological measures and appropriate training of employees. However, it is possible that any information transmitted via the Internet may be intercepted by unknown third parties. It is therefore encouraged that you carefully ensure security through virus screening software, browser settings, the setting of passwords that are known only to you and are difficult to guess, and other security measures available to individuals and/or companies.
If you are an Authorized User or Customer, where Senti has given you (or where you have chosen) a password and/or user ID (including email address) (the “Credentials”) which enables you to access certain parts of the Website or the Services, you are responsible for keeping the Credentials confidential. You are encouraged not to share your Credentials with anyone. Senti store passwords of Authorized Users only in one-way encrypted form; they are not readable by any of its personnel.
Your personal information may be processed and stored on servers located in various countries around the world. As a consequence, your personal information may be accessed by the courts, law enforcement and national security authorities of those jurisdictions in accordance with applicable laws. By submitting your personal information or using our Services, you agree to this transfer, storing or processing. If you reside in the Philippines, the European Union or other jurisdictions that provide access rights under law, you may access your information or have it corrected or updated in accordance with applicable law by contacting us at the addresses set out in this Policy .
Disclosure and Transfers of Personal Data
Senti does not sell, trade, or otherwise transfer to outside parties personally identifiable information about the Website visitors or Customers or their Authorized Users. This does not include trusted third parties who assist Senti in operating the Website, conducting its business, or servicing you, so long as those parties agree to keep this information confidential and use such information only for purposes relating to their services for Senti .
If you are a Customer or Authorized User, Senti may share portions of your contact information and technical information with third party data provider partners, as required under the terms of Senti’s agreements with such providers.
Senti may also disclose your personal information, the contents of your communications and/or your contact and financial information if required to do so by law, with your consent or in Senti’s good faith belief that such action is necessary:
To conform to the edicts of the law or comply with a legal process served on Senti;
To protect and defend the rights or property of Senti or others;
To prevent fraud; or
To assist, under exigent circumstances, in the investigation of violations of applicable laws and regulations.
When the processing of Personal Data is outsourced by Senti to a third party, the processing will be subject to written agreements between it and the third party processing the Personal Data. These written agreements specify the rights and obligations of each party, and will provide that the third party has adequate security measures in place and that it will only process the Personal Data on the specific written instructions of Senti.
The following are the third parties to whom Personal Data may be disclosed:
Regulatory bodies, agencies, law enforcement authorities, and other legal bodies;
Stockholders and business partners; or
Potential investors or target companies in the context of an M&A dealIt is possible that as Senti continues to develop its business, Senti might be acquired. In such a transaction, Personal Data may be transferred to the acquiring entity or to entities conducting due diligence on Senti.
Personal information will be retained or stored for as long as the purposes for which they are being processed have not been satisfied. Senti will retain and use the personal information as necessary to comply with its legal obligations, resolve disputes, and enforce its agreements, after which the Personal Data shall be deleted or anonymized.
Rights of Data Subjects
Data subjects have the following rights under the Privacy Laws, which may be exercised at their discretion:
A. The right to access Personal Data
It is possible for individuals to request access to any of their Personal Data held by Senti, subject to certain restrictions. A request for disclosure of such information is called a subject access request. Any such requests should be addressed to the Data Protection Officer.
B. The right to make corrections to Personal Data
Privacy Laws require Senti to take reasonable steps to ensure that any Personal Data it processes is accurate and up-to-date. It is your responsibility as the data subject to inform Senti of any changes to the Personal Data that you have supplied to us during the course of your use of Senti’s Services.
C. The right to object to the processing of Personal Data
You have the right to object to the processing of your Personal Data, including processing for direct marketing, automated processing or profiling. You shall also be notified and be given an opportunity to withhold consent to the processing in case of changes or any amendment to the information supplied or declared to you in this Policy. Please note that some of the Personal Data provided Senti is necessary for it to comply with statutory and regulatory requirements, as well as with Senti’s administrative policies, and is thus mandatorily required to be collected and processed. Withholding of consent to the processing of certain personal information may prevent Senti from fulfilling certain obligations it may have to you, as well as preventing you from availing certain services from Senti.
D. The right to erasure or blocking of Personal Data
You have the right to suspend, withdraw or order the blocking, removal or destruction of your Personal Data from the filing system of Senti.
E. The right to be informed of the existence of processing of Personal Data
You have the right to be informed whether Personal Data pertaining to you shall be, is being, or have been processed, including the existence of automated decision-making and profiling.
F. The right to damages
Upon presentation of a valid decision, the Senti recognizes the right of data subjects to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of Personal Data, taking into account any violation of the rights and freedoms as a data subject.
G. The right to lodge a complaint before the applicable regulatory agencies
Changes to Our Policies
From time to time Senti will participate in conversations on social media platforms such as Twitter, LinkedIn or Facebook, where Senti has reason to believe individuals might be interested in its services because of their involvement in public relations, investor relations or related fields. Communications that are meant to be confidential in nature should be made through secure messaging options available within these third party websites/services. Questions about Senti’s social media policy should be forwarded to email@example.com.
Third Party Content
Senti’s Services collect, use, process and store information that has been made publicly available on the Internet (“Third Party Content”). In general, the Third Party Content can be found using a standard Internet search engine or by visiting the applicable websites directly. Senti does not have any ownership interest or control over the Third Party Content or any direct relationship with those persons who post such Third Party Content. Senti obtains Third Party Content through agreements with certain data providers, and through proprietary technology that collects RSS feeds. Senti does not attempt to gain unauthorized access to any information and does not circumstance any passwords or other technology protections. Senti only gather Third Party Content that is made available to the public by the site or by the individual.
The Services provide analytics that allow the Customers to aggregate and analyze the Third Party Content. The Services may also be used by Customers to collect certain personal information about individuals and their online activities, such as interactions with a Customer’s website and/or in relation to Customer’s products and services. We require the Customers to comply with all applicable legal requirements in using the Third Party Content, including any applicable privacy laws.
If you reside in the Philippines, the European Union or other jurisdictions that provide access rights under law, you may access your information or have it corrected or updated in accordance with applicable law by contacting us at the addresses set out in this Policy.
If you have any questions about this Policy or the practices of Senti, you can contact Senti at the postal address, phone number, fax number or email address listed below.
Senti TechLabs, Inc.
Unit 1114, Cityland Herrera Tower,
Rufino cor. Valero St., Makati City
Phone: +63 2 779 8529
Fax: +63 2 779 8529
Last updated: 2 September 2019