Sentinence Privacy Policy

Introduction

This Privacy Policy applies to the website and online services offered by Sentinence (hereinafter “the Company” through this website or other forms used by the Company, including any mobile application or version of the site (collectively, the “Site “), and explains the types of information collected through the Site, and how such information may be processed, utilized, or shared. By using the Site, you, the user, agree to the terms of this Privacy Policy.  If you do not agree with this Privacy Policy, you cannot use, and must discontinue, any use of the Site.

Commitment

The Company is committed to maintaining the confidentiality and security of any personally identifiable information (“Personal Information”) of yours which has been obtained through the use or access of our website. This includes any personal identifiable information we have gathered or which you have provided to us when becoming a client of ours, through marketing and/or any other communications.

This Privacy Policy describes how Personal Information is collected and processed by Sentinence in relation to its operating activities.

This Privacy Policy does not cover Personal Information given to social media or third-party payment providers. For example, any interactions we may have with you through LinkedIn or any other social media provider result in your personal information being shared with those providers and not us and is therefore not included as part of our Privacy Policy. Likewise, information shared directly with third party payments providers would be covered under their own privacy policy and not ours.

This Privacy Policy is intended to meet the requirements under Personal Information Protection and Electronic Documents Act (PIPEDA).

What Personal Information We Collect

We may collect personal data directly from individuals and the parties with which we do business, including prospects. These may include parties that interact with us directly, parties to which we provide services (such as clients, MSBs or financial institutions, merchants, and individuals) (collectively, “clients”), parties that provide services to us (such as vendors) (collectively, “service providers”), and other parties with whom we offer or provide products and services (such as independent sales organizations) (collectively, “partners”).

We may collect information from these parties in a variety of contexts, such as when completing one of our online forms, making an application for one of our products or services, interacting with us on social media, or corresponding with us. The types of information we obtain in these contexts include:

• Contact information of the business entity and its personnel who interact with us, such as name, job title, address, telephone number, and email address

• Profile information, such as username and password that an individual may establish on one of our websites or mobile applications, along with any other information that an individual enters into their account profile

• Demographic details, such as date of birth, country of citizenship and/or country of residence

• Information about individuals’ affiliation with a legal entity, such as an individual’s role, and whether he or she is a beneficial owner or authorized signatory

• Government-issued identification numbers (to the extent permitted under applicable law), such as a national identification number (e.g., a Social Security Number, tax identification number, or passport number), state or local identification number (e.g., a Driver’s License or other government-issued identification number), and a copy of your government-issued identification card

• Feedback and correspondence, such as information you provide when you request information from us, receive customer support, or otherwise correspond with us, including by interacting with our pages on social networking online sites or services

• Financial account information, such as payment card or bank account details

• Information related to the use of Sentinence services, such as account information, budgets, compliance planning records

• Marketing information, such as your preferences for receiving marketing communications and details about how you engage with our marketing communications

• Other information supplied by job applicants, such as professional credentials and skills, educational and work history, and other information of the type included on a resume or curriculum vitae

Information that we collect about individuals who do not interact with us directly

We may receive personal data about individuals who do not interact with us directly. For example, our clients, service providers, and partners may provide us with information about individuals other than themselves when using our services. In addition, due to the unique nature of Sentinence’s business, in many cases, Sentinence obtains personal data from third parties such as transaction analytics firms. The types of information we receive about third parties includes:

  • Information about the personnel of our clients, service providers, or partners, such as the business contact information that our clients, service providers, or partners provide to us in the context of our contractual relationships with them

  • Information about potential job candidates, such as when a recruiter contacts us about an individual who may become a candidate for a job at Sentinence

  • Information about customers of our clients that our clients send to us or allow us to collect in the context of the services that Sentinence performs, such as information related to compliance audits and services initiated by the customer, account registrations, and in some cases information needed to verify a customer’s identity and details of services purchased, and as otherwise stated in an applicable specific privacy notice for a Sentinence product or service.

Information we collect from private and publicly accessible sources

We and our service providers may collect information about individuals that is publicly available, including by searching publicly accessible government lists of restricted or sanctioned persons (such as the Specially Designated Nationals And Blocked Persons List), public records databases (such as company registries and regulatory filings), and by searching media and the internet. We and or our third-party verification providers may also collect information from private or commercially available sources, such as by requesting reports or information from credit reference and fraud prevention agencies, to the extent permitted under applicable law.

We may also maintain pages for our company and our products and services on a variety of third-party platforms, such as LinkedIn, Facebook, Twitter, Google+, YouTube, Instagram, and other social networking services. When you interact with our pages on those third-party platforms, the third-party’s privacy policy will govern your interactions on the relevant platform. If the third-party platform provides us with information about our pages on those platforms or your interactions with them, we will treat that information in accordance with this Privacy Policy.

Why We Collect Personal Information

We collect, use, and disclose Personal Information for the following purposes:

For Business Purposes:

We only collect Personal Information when it relates directly to our engagement agreement with you to provide the agreed upon services.

The purposes for which we collect Personal Information will be identified before or at the time we collect the information. In certain circumstances, the purposes for which we collect information may be clear, and consent implied, such as when name, address, date of birth or payment information is provided as part of our due diligence KYC onboarding process.

Personal Information collected on customers of a client is collected so that we can perform compliance-related services for our client, such as ID verification, sanction list screening and compliance audits.

For Communication Purposes:

If you contact us, we may keep a record of that correspondence. If you engage with us to provide agreed up on services, we will maintain and retain our email communications with you as required by the applicable laws of both of our jurisdictions.

For Marketing Purposes:

We may use Personal Information to offer personalized advice or services or to send promotional emails. We will only send promotional emails if you have specifically agreed to receive them. For example, if you have indicated you would like information regarding a particular service after a webinar.

We collect and analyze data about web traffic and visits to our website, to help us understand how users utilize our website, further develop our service offerings, and improve our website.

We will not use information on customers of clients for marketing purposes or any purpose other than providing services to our client.

For Hiring Purposes:

We use Personal Information to identify job applicants, evaluate job applications and to contact applicants as needed.

Third Party Links

The Site may contain hyperlinks to websites of third parties. If users decide to follow such links, they must be aware that the Company does not take any responsibility for the third-party content or compliance of the third-party website with data privacy laws. This Privacy Policy does not apply to such third-party content or sites. Users are encouraged to make themselves aware of applicable privacy laws and policies before they submit personal information to third party websites.

Please choose from the third-party embeds to select which embeds you wish to load by default.

Collection of Personal Information

Limiting Collection

Any Personal Information collected will be limited to the details necessary for the purposes identified by us.

How and When Information is Collected

We collect Personal Information that is:

Given to us directly. For example, when we receive an email with a request for services or a job application, during registration for webinars and training sessions and from online forms completed on our website

From third party sources. This includes:

  • Our service providers for web analytics or ads.

  • Databases made publicly available by third parties.

  • Website/social media pages containing information made public by you.

  • Service providers that perform criminal background checks, as part of our hiring process.

  • Service providers for sanctions screening as part of our hiring and client onboarding due diligence.

From website information. We use cookies to track activities to infer your interests based on the pages that have been visited.

Cookies are files that a website automatically creates and stores on a user’s computer to collect information about web browsing activities. We may use this information to know what your interests are, and to promote services that may be most relevant to you.

Our website creates cookies that personalize our website, subscriptions, and emails for you or recognize you the next time you visit our website.

You may change your Internet browser settings to prevent your computer from accepting cookies or to notify you when you receive a cookie so that you may decline its acceptance. Please note, however, if you disable cookies, you may not experience optimal performance of our website.

We also use Google Ads, and other third-party cookies for marketing purposes. These allow us to analyze how well our ads perform for a specific user. Google Analytics makes the data anonymous by removing part of the IP address. Any cookies used by Google Analytics to collect data expire two years after the last time a user visits our website.

Storage and Use and Communication of Personal Information

Limiting Use

Personal Information may only be used or disclosed for the purposes for which it was collected, unless express consent is granted, or when it is required or permitted by law.

Personal information is never sold to a third party.

Where our service providers need access to your Personal Information, they are only permitted to do so to provide services on our behalf.

Limiting Communication

Personal Information is only shared with employees or representatives and service providers for their work or for the reasons why we collected the information in the first place.

We use service providers for the following:

  • Conducting web analytics.

  • Processing payments and collections.

  • Advertising our services.

  • Managing email delivery for communication or for newsletter notifications

  • Processing background checks.

  • Performing sanctions screening.

  • Distributing useful content

  • Marketing events and webinars.

Storage of Personal Information

Storage

We use third party service providers to store and process Personal Information. In most cases, servers are located within Canada. In all cases, we take all reasonable precautions to protect your Personal Information from any loss or unauthorized use, access, or disclosure.

Personal Information is protected by security safeguards that are appropriate to the sensitivity level of the information.

Retention

Personal Information is only be retained for the time required to fulfill the purpose for which we collected it or as may be required by law.

Security

We take appropriate measures to ensure that all personal data is kept secure including security measures to prevent personal data from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do Our best to protect your personal data, we cannot guarantee the security of your data transmitted through any online means, therefore any transmission remains at your own risk.

Children’s Privacy

The Company does not provide services to any minor child under the age of 13 and we do not knowingly collect, use, or disclose personal information from children under the age of 13. If you are a parent or guardian and You are aware that Your child has provided US personal identifiable information, please contact Us. If we become aware, that we have collected personal identifiable information form a minor child under the age of 13 without verification of Parental Consent, we take steps to remove that information from Our servers.

Consent and Openness

Consent

Knowledge and consent are required for the collection, use or disclosure of Personal Information except where required or permitted by law.

Whenever consent has been specifically given, it can also be revoked at any time. However, the decision not to provide certain information may limit our ability to provide services.

We will not require consent to the collection, use, or disclosure of information as a condition to the supply of a service, except as required by law or to be able to supply the service.

Consent can be limited in the following ways:

  1. An email to the address below to revoke consent.

  2. Requesting to be removed from upcoming webinar list, or newsletter subscriptions.

  3. Disabling cookies.

Openness

At any time, you may request access to your Personal Information.

Should you wish to submit a concern regarding the Personal Information we have collected from you, you may do so by emailing our Privacy Officer @ Latifah@sentinence.com.

You may ask to have your information deleted or ask to verify the accuracy and completeness of your Personal Information, and you may request that any errors found be amended. However, in certain circumstances permitted by law, we will be unable to disclose certain information to you. For example, we may not disclose information relating to you if other individuals are referenced or if there are legal, security or commercial proprietary restrictions.

You may direct any questions or inquiries with respect to our privacy policy or our practices by contacting us directly at info@sentinence.com

Revisions to this Privacy Policy

The Company reserves the right to change this privacy policy at any time whereby relevant changes take effect for the future. The applicable version of this privacy policy is available on the Site.  Please check this privacy policy regularly, and before you submit additional personal information via the Site.

The Company may amend this Privacy Policy at any time. Your continued use of the Site after any modification to the Privacy Policy will constitute your acceptance of the new terms.

The Company encourages you to periodically review this page for the latest information on the Company’s privacy practices. 

IF YOU DO NOT AGREE TO THIS PRIVACY POLICY OR TO THE FUTURE CHANGES TO THIS PRIVACY POLICY, YOU MUST STOP USING THE SITE AFTER THE EFFECTIVE DATE OF SUCH CHANGES.

Last updated February 22, 2021