Effective Date: May 10, 2018
We are Sensei Labs, 175 Bloor St E, Toronto, Ontario. All references to “we”, “us”, or “our” shall be construed to mean Sensei.
When We Act as Controller and Processor
Sensei will be acting as the "Controller" of the personal data you provide directly to us via a “Contact Us” form, when creating an account, or via other contact methods. You are not required to provide your personal information for purposes of navigating through the public areas of our website.
If you are an employee or an authorized user of one of our customers which have entered into an agreement with us for the provision of our products or services, we will be acting as the "Processor" of your personal data transmitted by our customer. Our customer will be acting as Controller of your information. As processor, we do not own, control, or direct the use of any data provided to us by our customers which act as Controllers.
1. Information We Collect on Our Own Behalf.
(a) Our Service: We may collect personally identifiable information about you, such as your full name, phone number, email address, or similar, when you register for an account. When you use the SenseiOS® Service or if you visit our websites, we may receive certain information about you as described below. We do not send any promotional emails; however, we may send you service related emails related to your account. If you no longer wish to receive these emails, you may opt out of them by adjusting your user preferences.
We use Google Analytics, Application Insights, and Mixpanel to measure and evaluate access to and traffic on the website, and create user navigation reports for our Site administrators. These companies operate independently from us and have their own privacy policies, which we strongly suggest you review. They may use the information collected through their respective services to evaluate Users' and Visitors’ activity on our Site.
We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the Site and identify visitor preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Visitors or Users. For more information or to opt-out, please visit the respective website(s) of these vendors or contact us at firstname.lastname@example.org.
1.2. Information We Collect on Behalf of Our Customers.
(a) Our Service. We collect data on behalf of our customers who use the SenseiOS® Service on the behavior of visitors of our customers' websites or mobile applications. When you visit such websites or mobile applications, we may receive certain information about your user activity.
(b) Information Related To Data Collected For Our Customers: SenseiOS® collects information under the direction of its customers, and has no direct relationship with the individuals whose data it may process. If you are a client of one of our current customers and would no longer like to be tracked by such customer, please contact the respective customer directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our customers.
(c) Access And Retention Of Data Controlled By Our Customers: An individual who is an employee or client of a current or former SenseiOS® customer who seeks access or wishes to correct, amend or delete inaccurate data should direct his query to to the respective customer first and then, if no response is obtained or such response is not satisfactory, should contact email@example.com. If we receive a request under this provision, we will acknowledge it within seventy-two (72) business hours and handle it promptly.
We will retain personal data we process on behalf of our customers for as long as needed to provide our services. We will retain this personal information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
1.3. Information We Collect on Behalf of Third Parties.
Cookies And Tracking Technologies: Technologies such as: cookies, beacons, tags and scripts are used by our partners, affiliates, analytics or service providers. These technologies may be used in analyzing trends, administering the Sites, tracking your movements around the Sites and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by such companies on an individual as well as aggregated basis.
2. How We Use Your Information.
(a) If you give your consent, we use the information that we collect to operate and maintain our customer sites and the SenseiOS® Service and to respond to your questions and concerns. The legal basis is art. 6(1)(a) of the EU General Data Protection Regulation (GDPR).
(b) We also use the information that we collect to help our customers improve their website(s).
3. How We Share Your Information.
(a) Personally Identifiable Information: SenseiOS® will not rent or sell your personally identifiable information to others. We may store personal information in locations outside the direct control of SenseiOS® (for instance, on servers or databases co-located with hosting providers). Any personally identifiable information you elect to make publicly available on our customer sites or the SenseiOS® Service, such as posting comments, will be available to others. If you remove information that you have made public on our customer sites or the SenseiOS® Service, copies may remain viewable in cached and archived pages of our customer sites or the SenseiOS® Service, or if other users have copied or saved that information.
(b) Instances Where We Are Required To Share Your Information: SenseiOS® will disclose your information where required to do so by law, if subject to subpoena or other legal proceeding or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Service or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of SenseiOS®, our users or others.
4. Storage and Processing.
Your information collected through the SenseiOS® Service may be stored and processed in the United States. SenseiOS® may transfer information that we collect about you, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world.
5. How We Protect Your Information.
We take appropriate technical and organizational measures to protect your personal data against accidental loss and from unauthorized access, use, alteration or disclosure. However, Sensei Labs™ cannot guarantee that unauthorized third parties will never be able to defeat those measures or use Customer Content for improper purposes.
We make sure that personal data is only accessible by only those who need access to do their job, and that they are properly trained and authorised. That means we keep logs of who has access to personal data, we limit the amount of people that have access, and we make sure that personal data can only be read, copied, modified or removed by properly authorised staff.
We monitor internal activity to ensure the safety and accuracy of personal data. SenseiOS® staff is required to conduct themselves in a manner consistent with the company’s guidelines regarding confidentiality, ethics, and appropriate usage of data. Staff is required to execute a confidentiality agreement and are provided with proper training in online privacy and security. If you have any questions about security on the SenseiOS® service, you can contact us at firstname.lastname@example.org.
6. Compromise of Personal Information.
In the event that personal information is compromised as a breach of security, SenseiOS® will promptly notify our customers in compliance with applicable law.
7. Your Choices About Your Information.
For employees or users of current SenseiOS® customers, you can review, correct, update or delete inaccuracies to the information about you that SenseiOS® keeps on file by logging into your account to update your personal information. Alternately (for former employees or users SenseiOS® customers), you can contact us directly at email@example.com or you may submit a Data Subject Access Request using this link.
We will acknowledge your request within seventy-two (72) hours and handle it promptly.
Data protection law gives you a range of rights in connection with our processing of your personal data. In this regard, you have the right to request that we rectify or delete the personal data or restrict the processing of your personal data, if you think they are inaccurate. Furthermore, you have the right to object against the processing based on our legitimate interests as a legal basis. We are required to assess and act on your request.
Additionally, you also have the right to data portability if it should become relevant. You have a right to lodge a complaint with your local supervisory authority.
8. Our Retention Of Your Information.
If you have an account with SenseiOS®, we will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
9. Children’s Privacy.
Protecting the privacy of young children is especially important. For that reason, SenseiOS® does not knowingly collect or solicit personal information from anyone under the age of 13. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.
10. Notification Procedures.
It is our policy to provide notifications, whether such notifications are required by law or are for other business related purposes, to you via email, written or hard copy notice, or through conspicuous posting of such notice on the customer site, as determined by SenseiOS® in its sole discretion. We reserve the right to determine the form and means of providing notifications to you, provided that you may opt out of certain means of notification by logging into your account and updating your notification settings.
11. Links to Other Websites.
Attn: Privacy Officer
175 Bloor Street East
North Tower, 7th Floor
Toronto, Ontario M4W 3R8