1. Information we collect and its use
We collect the following types of information about you:
1.1 Information you provide us directly: We ask and obtain, with your permission, for certain information such as your username, first and last name, birthdate, phone number and email address and your group or brand name, if applicable, when you register for an SSI account, or if you correspond with us. We may also retain any messages you send through the APP, and may collect information you provide in User Content, you provide to or via the APP, and information accessed or collected or shared about or from your connected social media platforms. We use this information to operate, maintain, and provide you with the features and functionality of the APP.
1.2 Information we may receive from third parties: We will receive information about you from third parties. For example, if you access our APP through a third-party connection or log-in through Facebook, by “following,” “liking,” adding the SSI application, linking your account to the SSI APP, etc., that third party will pass certain information about your use of its service to SSI. This information could include, but is not limited to, the user ID associated with your account (for example, your Facebook UID), an access token necessary to access that service, any information that you have permitted the third party to share with us, and any information you have made public in connection with that service. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the SSI APP. You may also unlink your third-party account from the APP by adjusting your settings on the third-party service. If you unlink your third-party account, we will no longer receive information collected about you in connection with that service, but this may interfere with your use of the APP.
1.3 Analytics information: We may directly collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the APP. These tools collect information sent by your browser or mobile device, including the pages you visit and other information that assists us in improving the APP. We collect and use this analytics information in aggregate form such that it cannot reasonably be manipulated to identify any particular individual user.
1.4 Cookies information: When you visit the APP, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser and lets SSI help you log in faster and enhance your navigation through the APP. A cookie may also convey information to us about how you use the APP (e.g., the pages you view, the links you click and other actions you take on the APP), and allow us or our business partners to track your usage of the APP over time. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the APP may not function properly if the ability to accept cookies is disabled.
1.5 Log file information: Log file information is automatically reported by your browser or mobile device each time you access the APP. When you use our APP, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the APP, domain names, landing pages, pages viewed, and other such information.
1.6 Clear gifs/web beacons information: When you use the APP, we may employ clear GIFs (also known as web beacons) which are used to anonymously track the online usage patterns of our users. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. This information allows for more accurate reporting and improvement of the APP.
1.7 Device identifiers: When you access the APP by or through a mobile device (including but not limited to smartphones or tablets), we may access, collect, monitor and/or remotely store one or more “device identifiers,” such as a universally unique identifier (“UUID”). Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by SSI. A device identifier may convey information to us about how you browse and use the APP. A device identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the APP. Some features of the APP may not function properly if use or availability of device identifiers is impaired or disabled.
1.8 Location data: When you access the APP by or through a mobile device, we may access, collect, monitor and/or remotely store “location data,” which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device. Location data may convey to us information about how you browse and use the APP and how we can make the APP work best for you. Some features of the APP, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled.
1.9 Commercial and marketing communications: We use the information we collect or receive to communicate directly with you. We may send you emails containing newsletters, promotions and special offers. If you do not want to receive such email messages, you will be given the option to opt out or change your preferences. We also use your information to send you APP-related emails (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the APP, technical and security notices). You may not opt out of APP-related emails.
2. Sharing your information
We will not rent or sell your information to third parties outside SSI and its group companies (including any parent, subsidiaries, and affiliates) without your consent, except as noted in this Section 2: We will not share your personal information without your permission except as follows:
2.2 Who you may choose to share your User Content with: Any information or content that you voluntarily disclose for posting, with or without assistance from the APP, including all content (including User Content) to any platform becomes available to the public, as controlled by any applicable privacy settings. You are solely responsible for all such content, whether or not SSI assists or makes or provides suggested wording for your use. Subject to your profile and privacy settings in your social media platforms, any User Content that you make public is searchable by other Users. If you remove information that you posted to your platforms or in any media platform, copies may remain viewable in cached and archived pages of such platform, or if other users have copied or saved that information.
2.3 What happens in the event of a change of control: We may buy or sell/divest/transfer SSI (including any shares in SSI), or any combination of its products, services, assets and/or businesses. Your information such as customer names and email addresses, User Content and other user information related to the APP may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the SSI.
2.5 Sharing certain service type information we collect about you: We may share certain service type information, including information obtained through tools such as cookies, log files, device identifiers, location data and clear gifs (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with our third-party business partners for the purposes described in the section above on “Information We Collect and Its Use.” We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, anonymized data with third parties.
3. How we store and protect your data
3.1 Storage and Processing: Your information collected through the APP may be stored and processed in the United States or any other country in which SSI or its subsidiaries, affiliates or service providers maintain facilities. SSI 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.
3.2 Keeping your information safe: SSI cares about the security of your information and uses commercially reasonable safeguards to preserve the integrity and security of all information collected through the APP. To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from SSI, at all times. However, SSI cannot ensure or warrant the security of any information you transmit to SSI or guarantee that information on the APP may not be accessed, disclosed, altered, or destroyed. Your privacy settings may also be affected by changes to the functionality of third-party sites and services that you add to the SSI APP or use with the APP, such as social networks. SSI is not responsible for the functionality or security measures of any third party.
3.3 SSI is GDPR Compliant: SSI is vigilant and works tirelessly to ensure that data imported through the SSI APP is protected. What’s more, we are committed to transparency in communicating how your data is collected, processed and ported across borders.
In fact, SSI is compliant with the General Data Protection Regulation (GDPR), which will be effective on May 25, 2018. SSI has implemented processes and systems that are consistent with the data protection regulations across the EU, which include:
- SSI obtains consent of subjects for data processing
- SSI anonymizes collected data to protect privacy
- SSI will alert customers to data breaches in a timely manner
- SSI is required to safely handle the transfer of data across EU/USA borders
Failure to comply with the GDPR will not only result in substantial fines for SSI but would also result in a massive breach of trust with our customers.
4.Compromise of information
In the event that any information under our control is compromised as a result of a breach of security, SSI will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
4.1 Your choices about your information: You control your account information and settings. You may update your account information and email-communication preferences at any time by logging in to your account and changing your profile settings. You can also stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. As noted above, you may not opt out of APP-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the APP, technical and security notices). If you have any questions about reviewing or modifying your account information, you can contact us directly at email@example.com.
4.2 Opting out of the collection of your information for Tracking / Advertising: Please refer to your mobile device or browser’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. Depending on your type of device, it may not be possible to delete or disable tracking mechanisms on your mobile device. Note that disabling cookies and/or other tracking tools prevents SSI or its business partners from tracking your browser’s activities in relation to the APP and for use in targeted advertising activities by third parties. However, doing so may disable many of the features available through the APP. If you have any questions about opting out of the collection of cookies and other tracking/recording tools, you can contact us directly at firstname.lastname@example.org.
5. How long we keep your User Content
Following termination or deactivation of your User account, SSI may retain your profile information and User Content for a commercially reasonable time for backup, archival, or audit purposes.
5.1: Children’s privacy: SSI does not knowingly collect or solicit personal information from children under the age of 16 and the APP and its content are not directed at children under the age of 16. In the event that we learn that we have collected personal information from a child under age 16 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 16, please contact us at email@example.com.
6. Links to other websites and services
7. Third-party services
To support delivery of our Service Offering, the APP may engage and use data processors with access to certain customer data (each, a “Subprocessor”). Sensai’s Subprocessors include:
|ENTITY NAME||SUBPROCESSING ACTIVITIES||ENTITY COUNTRY|
|Amazon Web Services (S3)||Cloud file attachment storage services||United States|
|Stripe||Payment processing services||United States|
|Google Cloud Platform||Cloud service provider||United States|
|Google Analytics||User analytics service provider||United States|
|Google Stackdriver/BigQuery||Cloud-based log management services||United States|
|Hubspot, Inc.||Customer relationship management service provider||United States|
|Mixpanel, Inc.||User analytics service provider||United States|
|New Relic, Inc.||User analytics service provider||United States|
|SendGrid, Inc.||Cloud-based email notification services||United States|
|TABLEAU SOFTWARE||Internal reporting tool||United States|
Our Subprocessors may change as our product evolves. We will endeavor to provide customers with notices of any new Subprocessors and post such updates here.
8. How to contact us
Disclaimer: This document is provided for informational purposes only and represents Sensai’s current offerings as of the date of issue of this document, which is subject to change without notice. Customers are responsible for making their own independent assessment of the information in this document and any use of Sensai’s products or services, each of which is provided “as is” without warranty of any kind, whether express or implied. This document does not create any warranties, representations, contractual commitments, conditions or assurances from Sensai, its affiliates, suppliers or licensors. The responsibilities and liabilities of Sensai to its customers are controlled by Sensai agreements, and this document is not part of, nor does it modify, any agreement between Sensai and its customers.