Last update 24 May 2023
1. PRIVACY POLICY
Sensemitter Services LTD ("Company", "We", “Our” and “Us”) is responsible for the protection of the privacy and the safeguarding of the personal data of our Clients (our counterparties and having agreed to the Privacy Policy, hereinafter “you” and “your”). Please, read carefully this following document to find about our Privacy Policy. This Privacy Policy sets out our data processing practices and your options regarding the ways in which your personal information is used. Your privacy is important to us.
This Privacy Policy outlines how we manage the personal data we collect from your use of our Website (“Website”) sensemitter.com or the Website (“Services”), through your interaction with us on social media or your other dealings with us. When doing that we act as data processor in accordance to the principles contained in The General Data Protection Regulation (GDPR) (EU) 2016/679. The Company’s contact concerning any queries about Data protection will be the Compliance Officer, which can be contacted through email on
dpo@sensemitter.com.
2. SCOPE OF WEBSITE
This Privacy Policy applies to the Services, which includes all services and products offered on the Website.
3. ACCEPTANCE OF THIS PRIVACY POLICY
By using the Website and/or Services You express Your acceptance of this Privacy Policy, as such Policy may be amended from time to time. Each time you use the Website and/or the Services, you agree and expressly consent to our collection, use and disclosure of the information that you provide as described in this Policy. If You do not agree to be bound by this Privacy Policy then please do not access or use the Services or the Website.
4. PERSONAL INFORMATION WE COLLECT
For the purposes of this Privacy Policy personal information means information about You that is personally identifiable and includes Your email address or other information that is not otherwise publicly available and that is protected from disclosure under applicable laws.
5. COLLECTION AND USAGE OF PERSONAL INFORMATION
We do not rent, sell, or share any information about our users with any third parties, except as specifically described herein.
We will use Your information collected via the Website for the purposes of:
- providing and personalising the Services;
- dealing with Your enquiries and requests;
- sharing Your information with other websites, financial institutions, relevant authorities and/or any person or entity that has the legal right to such information, if We suspect that You have engaged or attempted to engage in fraudulent, unlawful, dishonest or improper activity while using Our services;
- contacting You by e-mail with information about Our products and services (providing You agree to receive information about such products and services);
- sharing Your information with third party organisations who offer products or services which We feel may be of interest to You (provided You agree to receive information about such products or services: in this case, details of these third party organisations that We have shared information with are available upon request to Us);
- sharing Your information with third party service providers to the extent that it is reasonably necessary to perform, improve or maintain the Services;
- sharing Your non-personally-identifiable information with interested third-parties to assist them in understanding the usage patterns for certain content, services, advertisements, promotions, and/or functionality on the Website.
We may contact you to send you messages about faults and service issues. Furthermore, we reserve the right to use email to notify you of any eventual claims related to your use of our software, websites and/or products, including without limitation claims of violation of third party rights.
We may also use the Website to keep you up to date with news about our software and products that you have purchased and/or to inform you about other Company’s products and related information.
6. DISCLOSURE OF PERSONAL INFORMATION
We will not disclose Your personal information to third parties. However, We may disclose Your personal information if it:
(a) is requested by any judicial, non-judicial state or supranational authority required by any applicable laws, regulation, edict, local acts;
(b) detects, prevents, or otherwise addresses fraudulent, unlawful, dishonest or improper activity (Section 6 (d) of this Privacy Policy);
(c) it is shared under Section 5 of this Privacy Policy;
(d) it is necessary for national security, law enforcement, or other issues of public importance that disclosure of information is necessary.
We may also share Your personal information if the Company is acquired, merged, divided, separated, consolidated or transformed to another legal form.
Hereby You give Us consent on Your Personal Information disclosure to third parties and use in cases provided in this Police. However, in order to disclose Your Personal Information to any third parties, in cases not indicated in the Policy, we will ask for Your prior consent.
7. STORAGE, RETENTION AND DELETION OF PERSONAL DATA
We are based in the Cyprus and comply with the applicable data protection laws. The information we collect from You may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”).
We limit access to personal information about You to employees who We believe reasonably need to come into contact with that information to provide Services to You or in order to fulfill their official duties. These employees are bound by confidentiality obligations and may be subject to liability, if they fail to meet these obligations.
You agree and acknowledge that personal information about You may also be processed by staff operating outside the EEA who works for Us or one of Our suppliers. Such staff may be engaged using Your information for the purposes listed above. By submitting Your information, You agree to this use. We will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy.
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of Your personal information, username, password, transaction information and data stored on Our servers.
The personal data is kept for the time necessary to provide the services to you and you can always request that the Data controller suspend or delete your personal data. If You wish to delete personal data we have collected during your use of the Application, You should send a request to our support team. The processing of your request will take some time to be in effect. Please note that changing or deleting your personal data will only change or delete the data in our database for purposes of future activities and for managing future communications. These changes and deletions will not change or delete emails or personal data the Application may have already forwarded to other users or credit card companies or any other third parties, all as provided above in this Privacy Policy. Further, if you delete your personal data from the Website, but continue to use our other websites/applications/services, you may receive emails from us regarding those websites/applications/services. However, we may elect to keep your personal data, subject to the requirements of the law and legitimate interests of the Data controller. In case of your request to delete all your personal data, you agree that your email will be stored in our database to avoid creation of duplicate accounts and for identification purposes. The email will not be used in marketing activities, nor forwarded to any partner Applications or Third parties.
Please note that, even after termination of membership and deletion of any personal data, termination of any license granted hereunder, some content may continue to exist because of cached internet pages beyond the control of Website.
8. USER RIGHTS
You have the right, at any time, to change or delete your personal data.
You may also send a request to our support team and they will guide you through the process.
You can decide which correspondence to receive from us in accordance with our policy on freedom of choice and opting out. To stop receiving correspondence you can click the unsubscribe link found at the bottom of each email you receive.
In addition to rights set out in this section of this Privacy Policy, if you are located in the European Union, as a data subject (a person whose personal information is collected, stored and processed) you have several rights under the GDPR:
You have the right to obtain confirmation if your personal information is being processed by us. If that is the case, you can access your personal information and the following information: (a) the purposes of the processing; (b) the categories of personal information; (c) to whom the personal information have been or will be disclosed; (d) the envisaged period for which the personal information will be stored, or the criteria used to determine that period.
If you would like to have a copy of your personal information from us, we will provide it based on if (1) you will prove your identity, (2) it will not adversely affect the rights and freedoms of others.
You have the right to demand that we erase your personal information, and we shall erase it without undue delay where one of the following grounds applies: (a) this personal information is no longer necessary in relation to the purposes for which they were processed; (b) you withdraw consent if the processing was based on your consent, and where there is no other legal ground for the processing; (c) you object to the processing and there are no overriding legitimate grounds; (d) your personal information have been unlawfully processed; (e) your personal information have to be erased for compliance with a legal obligation.
You have the right to receive your personal information which you provided us in a structured, commonly used and machine-readable format and have the right to transmit those data to another company, where: (a) the processing is based on your consent or on a contract; and (b) the processing is carried out by automated means.
You have the right to withdraw you consent for processing of your personal information at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal information infringes GDPR.
9. DISCLAIMER OF WARRANTY
Using the internet to collect and process personal data necessarily involves the transmission of data on an international basis. Therefore, by using Website and/or Services and communicating electronically with Us, You acknowledge and agree to Our processing of information in this way. Although we will do Our best to protect Your information, we cannot warrant the security of Your information transmitted to the Website; any transmission is at Your own risk. Once we have received Your information, we will use strict procedures and security features to try to prevent unauthorised access.
10. WEBSITES OF THIRD PARTIES
Our Website may, from time to time, contain links to other web sites which are outside Our control and are not covered by this Privacy Policy. If You access other sites using the links provided, the operators of these sites may collect information from You which will be used by them in accordance with their privacy policy, which may differ from Ours. We do not accept any responsibility or liability for these policies. Please check these policies before You submit any information to these websites.
11. OUR COMMITMENT
We will only collect and use your data where We have a legal basis to do so;
We will always be transparent and tell you about how we use your information;
When We collect your data for a particular purpose, We will not use it for anything else without your consent, unless other legal basis applies;
We will not ask for more data than needed for the purposes of providing our services;
We will adhere to the data retention policies and ensure that your information is securely disposed of at the end of such retention period;
We will observe and respect Your rights (in section 7 above) by ensuring that queries relating to privacy issues are dealt with promptly and transparently;
We will keep our staff trained in privacy and security obligations;
We will ensure to have appropriate technological and organizational measures in place to protect your data regardless of where it is held;
We will also ensure that all of our data processors have appropriate security measures in place with contractual provisions requiring them to comply with Our commitment;
We will obtain your consent and ensure that suitable safeguards are in place before personal data is transferred to other countries.
12. CHANGES TO THE PRIVACY POLICY
We will always notify you via email or otherwise should we update this privacy policy. We will update the "last modified" date at the bottom of this privacy policy to indicate the latest revision, as well as the changes made.
If we decide to make material changes to our Privacy Policy, we will notify you by placing a notice on our websites or by sending you, a notice to the e-mail address we have on file for you. We may supplement this process by placing notices in our Website. You should periodically check this privacy policy page for updates.
Your continued use of the Website, Services following the posting of changes to this Privacy Policy will be deemed Your acceptance of those changes.
If You have any requests concerning Your personal information or any queries with regard to this Privacy Policy please feel to contact through our Website or at
dpo@sensemitter.com.