Privacy Policy - Senstone

SENSTONE PRIVACY POLICY

This Privacy Policy governs the manner in which Senstone, Inc. (“Senstone,” “we” or “us”) collects, uses, maintains, and discloses information (including personal information) collected fromusers(each, a "User" or "you") of our device (“Senstone”), mobile applications (“App”), our websites (“Site”) and other services provided by Senstone or any of its subsidiaries (“Other Services”) (collectively, “Services”).

It is important that you read this privacy policy regarding specific occasions when we are collectingor processing personal data about you so that you are fully aware of how any why we areusingyour data.

By using our Services, or otherwise providing us with information, you consent to our collection, storage, use and disclosure of your personal information and other information as describedinthisPrivacy Policy. If we are not able to collect, store, use, and disclose information about you as set out in this Privacy Policy, we may not be able to provide you with access to our Services.

Our Services are not intended for children and we do not knowingly collect data related to children

Data Privacy Manager

We have appointed a data privacy manager who is responsible for overseeing questions in relationto this privacy policy. If you have questions about this privacy policy, including any requeststoexercise your legal rights regarding this policy, please contact us using the details set out intheContact Us section of the website and appropriate subsections such as How Can We Help, Get Support, Senstone Store, Returns and Replacements, Send a Feedback and Contact SenstoneBusiness, or through this email: team@senstone.io.

Changes To This Privacy Policy

Senstone has the discretion to update this Privacy Policy at any time. When we do, we will revisethe updated date immediately below. We encourage Users to frequently check this page for anychanges to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodicallyand become aware of modifications.

This privacy policy was last updated on July 20, 2020.

Information We May Collect

Personal data, or personal information, means any information about an individual fromwhichthat person can be identified. It does not include data where the identity has been removed(i.e., anonymous data).

We may collect, use, store and transfer different kinds of personal data about you that wehavegrouped together as follows:

Identity data includes first name, maiden names, last name, username or similar identifier, marital status, title, data of birth and gender.

Contact data includes billing address, delivery address, e-mail address and telephone numbers.

Financial data includes bank account and payment card details (encrypted)

Transaction data includes details about payments to and from you and other details of productsand services you have purchased from us.

Technical data includes Internet protocol (IP) address, your login data, browser type andversion, time zone setting and location, browser plug-in types and versions, operating systemand platform, and other technology on the devices you use to access our Services.

Profile data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey response.

Usage data includes information about how you use our products, Site, Apps, and Other Services.

Marketing and communications data a includes your preferences in receiving marking fromusandour third-party business partners, trusted affiliates, and service providers

We may also collect, use or share aggregated data such as statistical or demographic data for anypurpose. Aggregated Data could be derived from your personal data but is not consideredpersondata in law as this data will not directly or indirectly reveal your identity. If, however, we combineor connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data that will be used in accordance with this privacypolicy

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinion, trade union membership, information about your health, and genetic or biometric data). Nor dowecollect information about criminal convictions or offenses.

If You Fail to Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract with you, andyoufail to provide that data when requested, we may not be able to perform the contract we have or aretrying to enter into with you (e.g., to provide you with goods or services). In this case, we may haveto cancel a product or service you have with us but we well notify you if this is the case at the time

How We Collect Your Personal Data

Direct interactions. You may give use your Identity, Contact or Financial Data by usingour Services. This includes personal data you provide when you:

  • apply for or purchase our or our affiliated Seller’s products or services;
  • create an account through our Services;
  • subscribe to our service or publications;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us

Automated technologies or interactions. As you interact with our Services, we may automaticallycollect Technical Data about your equipment, browsing actions or patterns. We collect this personal data by using cookies, server logs, and other similar technologies. Users may choose to set their web browser to refuse cookies or to alert them when cookies are being sent. If they do so, wenotethat some parts of our Services may not function properly.

Third parties or publicly available sources. We may receive personal data about you fromvariousthird parties as set out below:

  • Technical Data from the following parties:
    • a) analytics providers such as Google Analytics, FacebookAds, Amplitude, Fabric;
    • b) advertising networks such as Facebook, Instagram, LinkedIn, Twitter and other; and
    • c) search information providers such Google, Yahoo, Bing, Baidu.
  • Contact, Financial and Transaction Data from providers of technical, payment and deliveryservices such as Stripe and Paypal based in the U.S.

How We Use Your Personal Data

In general, the personal information we collect is used for the primary purposes for whichit wascollected, including:

To deliver our Services to you. Senstone may use User’s personal information to deliver theServices and any other goods, services, or information that you request from Senstone or any other user of our Services.

To facilitate communications between Sellers and Buyers. Senstone may share your email address with other Users with whom you enter into a Transaction solely to aid the Users inmoreeffectively communicating with one another regarding the Transaction.

To prevent, detect, and mitigate illegal activities. Senstone may use User’s personal informationto prevent, detect, and mitigate fraudulent, counterfeit, or illegal activities.

To provide or improve customer service. We may use personal information to help us respondtoyour customer service requests and support needs more efficiently.

To personalize user experience. We may use personal information in the aggregate to understandhow our Users as a group use our Services and resources provided on our App.

To improve our Services. We may use personal information obtained from feedback you provideto improve our products and services.

To process payments. We may use personal information obtained when placing an order toprovide service to that order. We do not share this personal information with outside parties except to the extent necessary to provide the service.

To run a promotion, contest, survey, or other Service feature. We may use personal informationto send information that Users have agreed to receive about topics we think will be of interest tothem.

To send periodic e-mail. We may use personal information such as email addresses to sendUsersinformation and updates pertaining to their order. A User's email address may also be usedtorespond to their inquiries, questions, and/or other requests. If a User agrees to be on our mailinglists, they will receive emails that may include company news, updates, related product or serviceinformation, etc.

Third-party Apps

Users may find advertising or other content through our Services that link to the sites and servicesof our partners, suppliers, advertisers, sponsors, licensors, and other third parties. Clicking onlinksto third-party websites, plug-ins and applications or enabling those connections may allowthirdparties to collect or share data about you. We do not control the content or links that appear onthese sites and are not responsible for the practices employed by apps linked to or fromour Services. In addition, these sites or services, including their content and links, may be constantlychanging. These sites and services may have their own privacy policies and customer servicepolicies. Browsing and interacting on any other app, including apps which have a link to our App, issubject to that app's own terms and policies. Senstone is not a party to those agreements; theyaresolely between you and the third party.

Advertising

Advertisements appearing through our Services may be delivered to Users by advertising partners, who may set cookies. These cookies allow the advertising server to recognize your computer eachtime they send you an online advertisement to compile non-personal information about you or otherswho use your computer. This information allows advertising networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This Privacy Policydoes not cover the use of cookies by any advertiser.

Unsubscribe/Opt-out. If at any time the User would like to unsubscribe fromreceivingfuturepromotion, content, survey, feature, or other marketing information or emails, we include detailedunsubscribe instructions at the bottom of each email. You may not, however, unsubscribefromemails about your account status or order status.

Other uses. We may also use your personal information for a secondary purpose that is relatedtoa purpose for which we collected it, where you would reasonably expect us to use your personal information for that secondary purpose.

International Transfers

Senstone is located in the United States, and when you use our Services, we may collect, useandstore your information in the United States. Your personal information will be subject to laws of theUnited States, which may differ from your country of residence. For example, the lawof the UnitedStates may require that your personal information be disclosed to government agencies under different circumstances than in your country of residence.

For transfers of personal data from persons within the European Economic Area (EAA), we ensureasimilar degree of protection is afforded to it by ensuring at least one of the following:

  • We will provide an adequate level of protection for your personal data, as providedbythe European Commission. For further details, see https://wayback.archiveit.org/12090/20221207150029/https://ec.europa.eu/inea/en/mission-objectives/data- protection.
  • Where we use certain service providers, we may use specific contracts approvedbythe European Commission, which give personal data the same protection as it hasinEurope.
  • Where we use providers based in the U.S., we may transfer data to themif theyarepart of the Privacy Shield that requires them to provide similar protection to personal data shared between the U.S. and Europe.

Please contact us if you want further information on the specific mechanism used by us whentransferring your personal data.

How We Protect Your Personal Data

We adopt appropriate data collection, storage and processing practices, and security measuresthat are designed to protect against unauthorized access, alteration, disclosure, or destructionof your personal information, username, password, transaction information, and data storedonour Services. In addition, we limit access to your personal data to those employees, agents, contractorsand other third parties who have a business need to know. No Internet transmission, however, isever completely secure or error-free. Additionally, audio and text data sent through the Senstoneservice are encrypted.,

It is your responsibility to control access to your device, including keeping your login informationconfidential and not sharing it with anyone. It is also your responsibility to notify Senstone if youbelieve the security of the information in our Services or your Senstone account has beencompromised.

Prohibiting the disclosure of your personal information

We do not sell, trade, or rent Users’ personal information to others.

Senstone may disclose Users' personal information to the following parties and for the purposesfor which it was collected as described above:

Restrictions on Sellers from whom you have purchased items

When you buy an item on Senstone, the seller is strictly prohibited from using your informationfor anything other than completing the sale.

Business partners, trusted affiliates, and third-party service providers

We may disclose generic aggregated demographic information not linked to any personal information regarding visitors and users with our business partners, trusted affiliates, andadvertisers, without notification to the User of such disclosure. We may use third party serviceproviders to help us operate our business and our Services or administer activities on our behalf, such as sending newsletters or surveys. We may disclose your information, including your personal information, to these third parties only to the extent necessary for them to provide such servicestous and such third party service providers are contractually obligated to maintain the confidentialityand security of that information. These third parties may be located outside of your countryof 6residence, including in Canada, Australia, or European Union (“Offshore Recipients”). In this case, your personal information would be subject to the laws of the country in which the OffshoreRecipient is located, which may have laws that require that your personal information be disclosedto government agencies under different circumstances than would your country of residence. WhileSenstone remains committed to protecting your personal information, you consent tothisdisclosure and acknowledge that Senstone has no control over, and is not liable for, the actsandomissions of Offshore Recipients.

Corporate transactions

In the event of a sale, amalgamation, re-organization, transfer or financing of parts of some or all of Senstone’s business ("Transaction"), your personal information may be disclosed to an acquiringorganization either as part of due diligence or on completion of the transaction. If your personal information is ever disclosed in this context, Senstone will require the acquiring organizationtoagree to protect your personal information in accordance with this Privacy Policy and to onlyuseyour personal information for purposes relating to the Transaction. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy.

Law enforcement and government agencies

We may disclose User’s personal information as required by law, including to law enforcement andgovernment agencies in response to a verified request related to suspected illegal activitiesor related to a criminal investigation. We will only disclose information that we find necessaryandrelevant ("Disclosed Information"). Disclosed Information may include a User’s name, mailingaddress, phone number, and email address. Disclosure may be made without notice to User.

Third parties with intellectual property rights

We may disclose User’s personal information to third parties with intellectual property rights whohave complied with Senstone’s Digital Millennium Copyright Act (DMCA) Notification procedure. Wewill only disclose information found necessary and relevant in connection to an intellectual propertyinfringement, fraud investigation, or other unlawful activity to which the third party has been subject. Disclosed personal information may include, but is not limited to, User’s name, mailing address, phone number, and email address. Disclosure may be made without notice to User.

For avoidance of doubt, please take note that disclosing personal information to third parties withintellectual property rights includes the disclosure of personal information of a User who has beenidentified as selling unauthorized goods or replica items, which is in violation of our Terms of Use

Third parties in a legal proceeding

We may disclose User’s personal information to third parties involved in a legal proceedingif thethird party provides Senstone with a subpoena or other similar lawful process. Disclosure maybemade without notice to User.

Senstone will also disclose to third parties involved in a legal proceeding when Senstone believesingood faith that disclosing personal information is necessary to prevent imminent physical harmor financial loss, or to report suspected illegal activity.

Disclosure related to Senstone Terms of Use

If Senstone believes in good faith that User has breached the Terms of Use or any other SenstonePolicies, Senstone may disclose such User’s personal information as found necessary andrelevant to pursuing a claim or preventing further injury to Senstone, its Users, and others. Disclosuremaybe made without notice to User.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfill the purposesfor which we collected it, including for the purposes of satisfying any legal, regulator, tax, accountingor reporting requirements. We may retain your personal data for a longer period in the event of acomplaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, natureand sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosureof your personal data, the purposes for which we process your personal data and whether wecanachieve those purposes through other means, and the applicable legal, regulatory, tax, accountingor other requirements.

Your Legal Rights

Under certain circumstances, you may have rights under data protection laws in relation toyour personal data. These rights may include:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to the processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us - see the last section.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the legal rightsdiscussed above that you may have). We may, however, charge a reasonable fee if your request isclearly 8unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request inthese circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity andensureyour right to access your personal data (or to exercise any of your other rights). This is a securitymeasure to ensure that personal data is not disclosed to any person who has no right to receiveit. We may also contact you to ask you for further information in relation to your request to speedupour response.

We try to respond to all legitimate requests within one month. Occasionally, it could take us longer than a month if your request is particularly complex or you have made a number of requests. Inthiscase, we will notify you and keep you updated.

Administration And How To Contact Us:

Opt out

If you would like to opt-out of communications from Senstone, please follow the unsubscribeinstructions at the bottom of emails you receive from us or contact us directly using the contact details below.

Access, correction and complaints

If you wish to access, correct, or update the personal information we hold about you, learnabout the sources used to collect this personal information, why Senstone collected specific personal information, and the third parties with whom this personal information has been shared, pleasecontact us directly using the contact details below. Senstone cannot discriminate against youfor requesting this information by changing prices or the quality of your experience, but it may chargeareasonable amount for providing access to personal information or refuse access to personal information where permitted by law.

If you have any questions or concerns about Senstone’s collection, storage, use or disclosureof personal information, or if you believe that Senstone has not complied with this Privacy Policyor applicable privacy law, please contact Senstone using the contact details below. When contactingSenstone, please provide as much detail as possible in relation to the question, issue or complaint. Your complaint will be taken seriously and will be assessed by an appropriate person with the aimof resolving any issue in a timely and efficient manner. Senstone requests that you cooperatewithSenstone during this process and provide any relevant information that may be required.

Your acceptance of these terms

By using this our Services, you signify your acceptance of this Privacy Policy and our Terms of Use. If you do not agree to this policy, please do not use our Services. Your continued use of our Services following the posting of changes to this policy will be deemed your acceptance of thosechanges. You reserve the right to withdraw this acceptance at any time but doing so will likely impact your ability to use our Services

California Privacy Rights

California Civil Code Section 1798.83 permits customers of Senstone who are California residents 9to request certain information regarding its disclosure of their personal information to third partiesfor their direct marketing purposes. To make such a request, please send an e-mail to support@senstone.io. We may (and we may allow third-party service providers) use cookiesor similar technologies to collect information about your browsing activities across different apps after you have used our Services. Our Services do not respond to "Do Not Track" (DNT) signalsandoperates as described in this Privacy Policy whether or not a DNT signal is received.

Google Integrations

Senstone app’s use and transfer to any other app of information received from Google APIs adheres to Google API Services User Data Policy, including the Limited Use requirements. Android app distributed on Google Play complies with Google Play Developer Distribution Agreement. Senstone iOS app distributed on Appstore complies with the App Review Guidelines.

Contact us

If you have any questions about this Privacy Policy, the practices of our Services, our third-partyservice providers or your dealings with any of our Services, team@senstone.io, contact@mg.senstone.io or contact us at: Senstone Inc, Attn: Owen Geronimo, 479 Jessie St., San-Francisco CA, 94103 U.S.