Privacy Policy

‍THE SENTR PRIVACY POLICY

‍Your privacy is very important to us. This privacy policy explains how Sentr uses your personal data. Please take time to read this carefully.

We believe in making it easier for our users by being clear and open about how we use your personal information. We know that there’s nothing more off putting than having to read lots of small print, so we’ve written our privacy policy in plain English.

We never lose sight of the fact that your personal information is your personal information.

We hope you find it easy to read and helpful but if you have any concerns or questions, or wish to submit a subject access request, please feel free to contact us at support@sentr.app.

This privacy policy was updated in August 2024. We will change it from time to time and if we make any changes that could affect you, we will let you know before they happen.

Our Privacy Policy

We are a "controller" under the General Data Protection Regulation (the GDPR) and other applicable data protection legislation (Data Protection Law). This means we are responsible for deciding how we use the personal data that we collect about you and, in accordance with the Data Protection Law, we will ensure that the personal data we hold about you is, at all times: 1. used fairly, lawfully, and transparently; 2. collected for limited, specific purposes only; 3. adequate, relevant to and limited to what is necessary for those purposes;4. kept accurate and up-to-date; 5. not kept for longer than is necessary; 6. held securely.

Information we collect from you

Sentr collects personal information about you whenever you use our service/app. Some of it is information you give us directly when, for example, you register for an account. Other information is collected as you interact with us, such as the match information you enter. We may also collect information about the way you access, view, share, contribute to and communicate with our service.Registration DataTo access our services you must create an account, by providing us with the information which is identified on the relevant registration page: name, email, year of birth. We will also collect a username and password.

Please note that our services will not be available if you do not provide the required information. We may also ask or allow you to submit other optional information, including your social media handles.

Contact Data

When we want to communicate with you, or you with us, we use your email address, telephone numbers. User Data We collect your usage and preference details related to your use of the services such as game statistics, scores, time spent playing, survey responses, feedback and other data that you provide to us as part of your account.

Marketing and/or Communications Data

We retain your preferences in receiving marketing messages from us.

Technical Data

Certain data is automatically generated and collected by us when you use the Services such as your IP address, MAC address and other device identifiers; your clickstream to, through and from the Services (including date and time); pages you viewed or searched for; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); methods used to browse away from the page.

Information we get via Cookies

Cookies are small text files stored in your web browser that enable us to recognise your computer when you visit one of our websites. Cookies are essential to keep certain parts of our websites functioning correctly and securely. We also use them to make things quicker, easier and more personal to you, and to help us understand how our website is used. They can also be used to present you with more tailored advertising content. To do all these things, cookies collect some personal information about you whenever you use our website. You can choose whether to accept or reject some or all types of cookies and control this through your device's browser settings.

How and Why We Use Your Personal Data

There are certain things we have to do in order to be able to provide you with our products and services. As you would expect, we use your personal information to enable you to use our app, to set up your account, respond to queries, and contact you to provide you with customer service. We use technical information about your device, such as operating system, browser version and location to present you with the correct version of our app and keep it functioning securely and correctly. We will only use your personal data where Data Protection Law allows us to.

Data Protection Law says we can collect and use personal data on the following bases: 1. it is necessary for us to be able to perform an agreement with you. 2. it is necessary for our legitimate interests (and your interests and fundamental rights do not override those interests); 3. if we have your consent (which you can withdraw at any time); 4. to comply with a legal obligation e. rules laid down by courts, statute or regulation.

Accordingly, we lawfully use your personal data in the following ways:

Delivering the Services
We use the Registration Data, User Data and Communications Data so that we can deliver the Services to you in an effective, efficient and accurate way. Without it we would not be able to deliver a tailored service to you or respond to issues with these Services that are identified by us or you, or ensure you get the most out of your experience. Therefore, we use this data on the basis that it is necessary for us to be able to perform our agreement with you (i.e. the terms and conditions of the relevant Services) and for our legitimate interests of delivering the Services in this way.

Operating the Services
We use the Technical Data in order to operate and administer the Services including as necessary for testing, analysis, maintenance, support, reporting and hosting of data. Therefore we use this data on the basis that it is necessary for our legitimate interests of operating the Services in this way.

Business insights
We carry out basic analytics to help us understand how, when, where and why people are using our service. This helps us develop better products and services. We do this analysis in a way that does not identify individual customers, so that there is no impact on the privacy of any one person. Like any business we need to keep a close eye on how our business is performing and whether we’re meeting the needs or our users. As we do this in a way that does not identify you as an individual, there is no impact on your privacy. We cannot provide you with our products and services without carrying out these activities and if you don’t want your data used in this way your option is to not use our services and close your account. You can close your account by emailing us at support@sentr.app.

Marketing Communications
We use the identity data and contact data to inform you of news, offers, events, competitions and promotions by specified media which may be of interest to you and/official commercial partners so that they can do this. We give you the option of providing opt-in consent to receive different kinds of direct marketing communications from us or these third parties or deciding not to do so.
OPT-ING OUT: You can withdraw your consent and opt-out of marketing communication from us at any time by following the instructions provided to you by the relevant communication (for example, the unsubscribe link in email). Alternatively you can contact us at support@sentr.app. We may still need to send you service emails to you from time to time.

Disclosure of your Personal Data
‍We may disclose or share your personal data in the following circumstances: Third Party Service Providers We engage third party businesses to provide services to us or to you on our behalf, such as support for the internal operations of our services, data storage and delivering communications. In providing their services, they may access, receive, maintain or otherwise use personal data on our behalf. Our service providers only use your personal data in accordance with our strict instructions to provide the relevant services and are not permitted to use your personal data for their own purposes unless authorised by us to do so. Where this is the case you will be notified by us and provided with their privacy policies so that you can understand how they will treat your data.

Commercial Partners
We may also disclose your personal data to our commercial partners where you have consented or requested that we do so. For example, when you enter a competition which is a joint promotion, or you request to receive certain marketing communications. You will be given clear information in each case before we share your personal data.

Legally Required
We may also disclose your personal data if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes. Notwithstanding anything else in the privacy policy we may share aggregate or de-identified information with third parties for research, marketing, analysis and other purposes.

Transferring your personal data outside the EU
Some countries outside of the European Union (EU) do not have laws that protect privacy rights and laws that protect privacy rights and personal data as extensively as the UK and other countries within the EU. We do not generally or routinely transfer personal data outside of the EU but some of the organisations to which we disclose personal data may be situated outside of the EU. If we do transfer your personal data outside of the EU, we will ensure that your personal data is protected to a similar degree, in accordance with Data Protection Law.We do this by ensuring one of the specific safeguards approved by the European Commission is in place. You can find further information about these safeguards at https://ec.europa.eu/info/law/law-topic/data-protection_en. If you would like further information on the specific mechanism used by us when transferring your personal data out of the EU you can contact us using the details provided above.

How long do we keep your information?
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We retain information as long as it is necessary to provide the Services to you and others, subject to any legal obligations to further retain such information. Information associated with your account will generally be kept until it is no longer necessary to provide the Services or until you ask us to delete it or your account is deleted whichever comes first. We hold your personal information only as long as we have a valid legal reason to do so, which includes providing you with the services you have requested, resolving disputes and enforcing our agreements. The length of time for which we keep different types of information can vary depending on why we originally obtained them and the reason we process them.To fulfill our requests, some of your personal information will need to be retained for a period of time after you cease to be a customer. When we no longer need to fulfill the above requirements we will delete it securely. Where we wish to retain any information for analysis purposes, we first anonymise it to the standards approved by the UK Information Commissioner's Office (which, as we are based in the UK, is our legal regulator on matters relating to data protection) so that it can no longer be linked back to the individual.

Your Rights
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Under Data Protection Law, you have certain rights (depending on the circumstances) in connection with your personal data, which include:- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are using it lawfully, provided that this does not adversely affect the rights and freedoms of other people;- Request correction of the personal data that we hold about you. Where any of the information we hold about you is incorrect or incomplete we will act promptly to rectify this, including where you have requested us to do so. Users of the Sentr Product can update their information any time via their account preferences;- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to use it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to our use (see below);- Object to use of your personal data where we are relying on our legitimate interests (see above) and there is something about your particular situation which makes you want to object to our use on this ground; - Withdraw your consent to our use of your personal data where we do so in reliance on your consent. Once we have received notification that you have withdrawn your consent, we will no longer use your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law; - Request the restriction of use of your personal data. This enables you to ask us to suspend the use of personal data about you, for example if you want us to establish its accuracy or the reason for using it;- Request the transfer of the personal data you have provided, on the basis of consent or for a contract with us, to you or a third party where technically feasible.We are committed to respecting your rights. You may action your rights (as may be applicable) by contacting us using the details provided above and we will comply with your requests within a reasonable period unless we have a lawful reason not to do so. Requests should be made in writing and to ensure that personal data is dealt with carefully and confidentially we will require the requestor to provide verification of their identity.

‍Updated 15 August 2024