PRIVACY POLICY

Effective Date: January 1, 2021

This Privacy Policy describes how Sentior, Ltd. ("Sentior", "sentior", "We", "Us", or "Our") protects your privacy when you use Sentior (the "Sentior Mobile Application", or "Sentior App") which includes the Web site located at www.sentior.com (the "Site") and all Sentior mobile phone applications ("Sentior", or "Sentior app").

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING SENTIOR, YOU AGREE TO BE BOUND BY THE TERMS AND CONDITIONS DESCRIBED HEREIN AND ALL TERMS AND CONDITIONS INCORPORATED BY REFERENCE. THIS PRIVACY POLICY IS PART OF AND INCORPORATED INTO SENTIOR'S TERMS OF USE ("Terms of Use"). IF YOU DO NOT AGREE TO ALL OF THE TERMS AND CONDITIONS SET FORTH BELOW, YOU MAY NOT USE THE SENTIOR APP.

This Privacy Policy applies to information (including personal information) collected through the Sentior app.

THE WHAT & HOW OF INFORMATION WE COLLECT

We collect information that you voluntarily provide to us. For example, we collect your name, email address, username, social network information and other information you provide us when you register, set up an account, contact us by e-mail or use our services. We may collect information about you from other Users if they share any Content with you, send a message, image and online contact information.

When you visit the Site, we automatically collect some information. For example, it is standard for your Web browser to automatically send information to every Web site you visit, including ours. Such information includes your computer's Internet Protocol ("IP") address, access times, browser type and language, and referring Web site addresses. We also collect and combine information about devices you use to access the Sentior app, and information about your usage and activity on the Site.

With your permission (on download or in the app), we may access and store your device's contact list to find your friends on the Sentior app, to invite them, or to share your Content with them. We may also collect information about others if you use the Sentior app to upload, share and/or distribute Content that contains information about them, including their name, image, and online contact information.

Cookies We automatically collect certain information through the use of "cookies". Cookies are small data files that are stored on your hard drive by a Web site. Among other things, the use of cookies helps us to improve the Site and your experience on the Site. We use cookies to see which areas and features of the Site are most popular, to count the number of computers accessing the Site, to personalize your experience and to remember your preferences. If your browser is set not to accept cookies or if you reject a cookie, you may not be able to access certain features or services of the Site. You can adjust your cookie preferences here.

Content and Metadata We also collect and retain your metadata along with your Content. For example, your location can be used to find new opportunities within your area.

STORAGE OF INFORMATION & TRANSFER OF DATA

If you are using the Sentior app from a country other than the country in which our servers are located (currently in The Netherlands) the various communications will necessarily result in the transfer of information across international boundaries.

HOW WE USE YOUR INFORMATION

We use information collected through the Sentior app:

to communicate with you or third parties;
to process your requests and transactions;
tto provide and improve the Sentior app;
to customize the services and/or products we provide to you;
to assist with our product and service development;
to perform marketing activities;
to provide relevant advertising;
for other purposes related to our business;
to protect the security of our interests, including our premises, assets, and systems;
to comply with the law; or
as otherwise disclosed at the time personal information is collected.

WITH WHOM WE SHARE YOUR INFORMATION

Information collected through the Sentior app may be shared with companies and organizations that perform services on our behalf (for example, companies that provide data management or other support services to us such as data storage and Web hosting services). We may share your information with third parties to serve you relevant requests and market our products.

Also, we may disclose the information we collect through the Sentior app when we, in good faith, believe disclosure is appropriate:

to comply with applicable law (e.g., in response to a valid court order or subpoena);
to prevent or investigate a possible crime, such as fraud or identity theft;
to enforce the Terms of Use or other agreements that govern your use of the Sentior app and/or our services;
pursuant to a subpoena, court order, governmental inquiry, or other legal process or as otherwise required by law, or to protect our rights or the rights of third parties;
with your consent or as otherwise disclosed at the time of data collection or sharing; or
to protect the rights, property, vital interests, or safety of us, our users or others.

We share information that has been de-identified or aggregated without restriction.

We may disclose your information without giving you prior notice if we believe it is necessary to prevent imminent and serious bodily harm to a person. Nothing in this privacy policy is intended to limit any legal objections or defenses you might have to efforts by third parties to compel disclosure of your information, including legal orders from the government.

Your information and other data collected by us may be transferred to another company that has acquired our stock or assets, for example, as a result of a sale, merger, reorganization, dissolution or liquidation.

HOW LONG WE RETAIN YOUR INFORMATION

The retention period of collected information depends on the type of information and the reasons why we collect it. In case the retention of your information is extended for a longer period for reasons we define below, we encrypt (anonymize) it to ensure it does not directly identify you. Such data is further retained until complete deletion becomes possible.

Your account information is retained while your account is active, unless you request us to delete it or remove your account. In case you deactivate/delete your account or request us to delete your information, some information may still be retained for a reasonable time to enhance your re-activation in case you decide to return to our services. We may also retain some information we believe in good faith is necessary for legal and regulatory compliance, research and development, business matters, and improvement of our Services.

In cases when you delete your information or request us to delete it, some of your information you shared through the Services may still be accessible for those with whom you shared it. For example, if you shared an request through the Sentior app, this request may still be visible for those with whom you shared, even if we delete it from your account.

CONTROLLING AND MODIFYING YOUR INFORMATION - OPT-OUT / OPT-IN

We respect your right to control and make choices about your information. You may request Sentior to:

provide you with information we collect about you;
transfer your information to another controller of your choice, when technically feasible;
delete (please see below for more details on deletion);
update, edit or modify your information; or
change your privacy preferences at any time.

Your request can be made by emailing us at support@sentior.com or, in some instances you may also do it yourself via the Sentior app.

We believe that you proceed to use our Sentior app upon accepting all the terms in our Terms of Use, which incorporate also the terms of this Privacy Policy. And as such we have your consent in processing and using your data as defined above. However, you are also free to choose to withdraw your consent and request us to cease processing your information by sending us a notice. In such case your withdrawal will not affect the legitimacy of the prior data processing.

You may also opt out of receiving promotional communications from us, including, but not limited to, promotional emails, by emailing us at support@sentior.com. Transactional service communications (such as messages about your registration) are not subject to the foregoing opt-out procedures, as are necessary for the regular conduct of our business records. Requests to disable your account or reset your password should be sent to support@sentior.com for faster processing.

DIGITAL ADVERTISING & ANALYTICS

We may partner with ad networks and other ad serving providers (“Advertising Providers”) that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information Advertising Providers collect about your use of the Site and other sites or apps over time, including information about relationships among different browsers and devices. This type of advertising is known as interest-based advertising.

Sentior adheres to the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles in connection with this interest-based advertising activity. You may visit the DAA Webchoices tool at www.aboutads.info to learn more about this type of advertising and how to opt out of this advertising on websites by companies participating in the DAA self-regulatory program and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps. If you delete your cookies or use a different browser or mobile device, you may need to renew your opt-out choices exercised through the DAA Webchoices tool. Note that electing to opt out will not stop advertising from appearing in your browser or applications. It may make the ads you see less relevant to your interests. Additionally, your browser may offer tools to limit the use of cookies or to delete cookies; however, if you use these tools, our Site may not function as intended. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see https://optout.networkadvertising.org/?c=1#!%2F.

We may also work with third parties that collect data about your use of the Site and other sites or apps over time for non-advertising purposes. Sentior uses Google Analytics and other third-party services to improve the performance of the Site and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you use our Site, visit www.google.com/policies/privacy/partners , and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout.

We support the ad industry’s 2009 Self-regulatory Principles for Online Behavioral Advertising ( https://www.iab.com/wp-content/uploads/2015/05/ven-principles-07-01-09.pdf ) and expect that ad networks we directly engage to serve you Interest-based Advertising will do so as well, though we cannot guarantee their compliance. We are not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

SECURITY OF YOUR INFORMATION

We work hard to ensure integrity and security of your information (including preventing the loss, misuse, unauthorized access, disclosure, alteration and destruction of your information). To this end we have incorporated security measures into our system to protect you and Sentior from any data breach. Such measures include encryption of your data while in transfer, regular revision of security procedures and compliance in the system, restricted number of employees under strict confidentiality obligations that are authorized to access your information for the purposes of legitimate processing and handling, as described above. However, we cannot guarantee that unauthorized third parties will not be able to defeat our security measures. If you use an account on the Sentior app, you are responsible for keeping it confidential. Do not share it with any other person. If you believe your account compromised, please advise us immediately by sending a notice at support@sentior.com.

CHILDREN UNDER 18

THE SENTIOR APP IS NOT MEANT FOR PEOPLE UNDER 18. We are committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children's online activities and interests. We do not knowingly collect information from children under the age of 18 and we do not target the Sentior App to children under 18. If we receive a valid notice through support@sentior.com that a minor under age of 18 has provided us with personal information, we will take measures to delete it as soon as possible.

CONTACT US

For questions or concerns about Sentior’s privacy policy or practices, please email support@sentior.com or contact us by mail at Sentior, Ltd., Attn: Verrijn Stuartlaan 18, 2288 EL Rijswijk.

CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy from time to time. If we make any changes to this Privacy Policy that we think materially alter your rights, then we will post the latest policy to this site and change the "Last Updated" date above. We encourage you to review this Privacy Policy whenever you visit the Sentior app to understand how your information is used