PRIVACY POLICY

[Last Updated: April 15, 2024]

This Privacy Policy (“Privacy Policy”) governs the manner in which we, WOT Services LP - (“we” or “us”) process information collected from our users ("you", "your" or "user") in connection with their access to or use mobile application available on iOS (“App” all as detailed and defined in our Terms of Use (“Terms”), and how we may share this information.

All capitalized terms used but not otherwise defined herein shall have the meaning ascribed to them in the Terms. This Privacy Policy explains what information we may collect, how such information may be used or shared with others, how we safeguard it and how you may exercise your rights related to your Personal Data (as such term is defined below), among others, and where applicable, as required according to the EU General Data Protection Regulation (“GDPR”).

This Privacy Policy applies to all users worldwide. If you are a resident of California, please refer to Section 13. Additional Privacy Information for California Residents for information about the categories of Personal Information we may collect and your rights under California privacy laws. If you are a resident of Colorado, Connecticut, Virginia, or Utah, please refer to Section 13. Additional Privacy Information for Certain United States Residents, which includes additional information about privacy rights for residents of certain U.S. jurisdiction

We reserve the right to periodically amend or revise the Privacy Policy at our sole discretion. Such changes and updates will be effective immediately upon the display of the revised Privacy Policy. Thus, we encourage you to check this Privacy Policy regularly for updates, so that you are fully informed of how your data is collected and used by the Company and your related rights. The last revision date will be reflected in the "Last Modified" heading. Your continued use of the App or Service following the display of such amendments constitutes your acknowledgement of such amendments to the Privacy Policy. In the event of material changes that will adversely affect your use of the App or Service or the data collection by us, we will make best efforts to provide you with notification through the App or Service.

IF YOU OBJECT TO ANY OF THESE TERMS PLEASE DO NOT ACCESS, DOWNLOAD, INSTALL, OR USE THE APP OR SERVICES IN ANY MANNER.

Data We Collect and Purpose of Use -

How we use the Data: We use the Personal Information collected from you for the following purposes.
1. The first type of information we collect is aggregated, non-identifiable, non-personal information, which may be made available or gathered via the user's use of the Service (“Non-Personal Data”). We are not aware of the identity of the user from which the Non-Personal Data was collected. Non-Personal Data may include technical information automatically transmitted by the user's device such as, type of browser, the type of operating system, access time and date, approximate geographical location, etc. The second type of information is individually identifiable information, namely information that identifies an individual or entity or may with reasonable effort identify an individual (“Personal Data”).
2. Personal Information We Collect Directly From You - When you email, call, or otherwise communicate with us and with members of our team, we may collect and maintain a record of your contact details, communications, and our responses. We also maintain records of communications and information that you post on our social media channels and information you provide to us related to any customer support requests.
3. Personal Information We Collect Automatically Through the Services
  1. Data about your device, such as your screen resolution, operating system, device ID, device manufacturer and model, and language.
  2. Browsing activity and information regarding websites and content accessed such as websites you visited.
  3. Data about your use of the App, including content viewed, features used and the dates and times of your interactions with the App.
4. Permissions Requested - We request VPN permission to collect browsing data, in order to block suspicious and malicious websites before you even see them. Some of our features are supported by our affiliates’ technologies and your data and browsing activity will be disclosed with such affiliates to enable us to provide you with our browsing protection feature and for market intelligence purpose.
5. Operating Services and Providing Related Support - To provide and operate our Services, provide troubleshooting and technical support, and for similar service and support purposes. We process your Personal Information for this purpose for the performance of a contract we have with you e.g., because you have agreed to our Terms of Service) or to take steps at your request prior to entering into a contract with you or to meet our legitimate interest (e.g., to support the proper functioning of our Services) in doing so.
6. Analytics and Improvement - To better understand how users access and use the Services and Apps. In this regard, we have a legitimate interest in understanding how our Services work and ensuring the necessary improvements.
7. Marketing, Advertising and Campaign Management – To improve and measure the effectiveness of our ads and those of third parties. Where required by applicable law, we may obtain your consent in order to send you targeted marketing. We also have a legitimate interest in marketing and advertising our Services and may not rely on your consent to the extent permitted by applicable law.
8. Compliance and Legal Process - To comply with the law and our legal obligations and respond to the legal process and related legal proceedings. In this regard, we will process your Personal Information to comply with our legal obligations, and in our legitimate interest.
9. Business Transactions - To consider and implement mergers, acquisitions, reorganizations, and other business transactions, and to administer our general business, accounting, recordkeeping, and legal functions. Any such processing of your Personal Information will be in our legitimate interest.
WE DO NOT SELL ANY PERSONAL DATA WE COLLECTED FROM YOU. We may disclose Personal Information for the purposes described in this Privacy Policy to the following parties:
1. Vendors and Service Providers. Service providers, processors, and vendors who perform functions on our behalf to allow us to provide the Services.
2. Affiliates. our affiliates, who may use this Personal Information in connection with their market intelligence or analytics services and otherwise in accordance with the principles of this Privacy Policy.
3. Third Party Platforms and Networks. third parties to support of our marketing, advertising, and campaign management.
4. Business Partners. If we, our affiliates, or subsidiaries are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise.
5. Others as permitted or required by applicable law. To the extent permitted or required by applicable law. This may include regulators, government entities, and law enforcement. It may also include certain disclosures that we are required to make.
6. Security and protection of rights. to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Privacy Policy, or as evidence in litigation in which we are involved.
Aggregated Data and Non-Identifiable Data - We may use and disclose aggregated and other non-identifiable data related to our business and the Services for quality control, analytics, research, development, and other purposes. Some of this information may be considered “de-identified” under U.S. privacy laws (i.e., data that is no longer linked or reasonably linkable to an identified or identifiable consumer). Where we rely on data that has been “de- identified” as defined by U.S. privacy laws, we will: a (i) take reasonable measures to ensure that the de-identified information cannot be associated with an individual, household, or device; (ii) commit to maintain and use the information in de-identified form and not attempt to re-identify the information; and (iii) contractually obligate any further recipient to comply with this Section 3.
Cookies & Tracking Technologies -We use “cookies” and similar tracking technologies such as software developer kits (“SDK“) on our App and Services. A cookie is a small text file that a website places and stores on your device while you are viewing a website. Cookies are very helpful and can be used for various purposes. These purposes include: (i) allowing you to navigate between pages efficiently; (ii) enabling automatic activation of certain features; (iii) remembering your preferences; and (iv) making the interaction between you and our services quicker and easier. The SDKs create the opportunity to enhance our functionality.
Data retention - We retain the information we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws. We may at our sole discretion, delete or amend information from our systems, without providing any notice to you, once we deem it is no longer necessary for our purposes.
User Rights -
1. We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed. You can opt out and stop the automated collection of your browsing data by opting out of the VPN Permissions through device settings. Note, that once you opt out or turn off the VPN Permissions, some or all of the Services provided by the App will no longer be available. Where provided under applicable law (e.g., within the European Union and United Kingdom), you may have the right:
  1. To confirm with us whether your Personal Information is processed, and if it is, to request access to the Personal Information processed, the purpose of the processing, and the recipients or categories of recipients of your Personal Information.
  2. To rectify inaccurate or incomplete Personal Information concerning you. We encourage you to review your information on the Services regularly to ensure that it is accurate and up to date.
  3. In certain circumstances, to ask us to erase Personal Information concerning you;
  4. To request that we restrict the processing of your Personal Information in certain circumstances.
  5. To object to the processing of your Personal Information, where we are relying on a legitimate interest for such processing.
  6. To object to us processing your Personal Information for direct marketing purposes.
  7. To receive your Personal Information in a structured, commonly used and machine-readable format or ask that we transfer the Personal Information, to another organization. This right only applies if our lawful basis for such processing is your consent or a contract, we have entered into with you.
  8. To withdraw your consent at any time, where we are relying on consent to process your Personal information. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
2. Note that where your Personal Information has been de-identified, we will not be able to identify you or comply with some of the rights mentioned above. These rights do not apply to de-identified information. Additionally, these rights are not absolute and may therefore be subject to applicable exceptions, such as the interest of other individuals, in order to preserve that information for anticipated litigation or demands from a regulator.
3. If you wish to exercise any of these rights, please contact our Data Protection Officer at: admin@sentsecurity.com. Note that we may request proof of your identity, and we reserve the right to charge a fee where permitted by law, such as in circumstances where your request is deemed to be excessive. You may have the right to lodge a complaint with a data protection authority, subject to applicable law (as is the case in the European Union and the UK). You can find information on the relevant EU data protection authorities here and the UK Information Commissioner’s Office here.
Data Security - While there are inherent risks involved in all data transmissions over the Internet or wireless networks, and other security risks that apply to stored data, and we therefore cannot guarantee the security of your information, we use our best efforts, using industry-standard encryption and security technologies and methods, to collect and store information collected from you in a secure and safe manner.
Children Information - You represent and warrant that you are (i) at least sixteen (16) years of age if you are located in the EEA; or (ii) if you are located in any other geography and you are above the age defined as “child” under applicable laws in your jurisdiction (collectively “Child” or “Children”). If you are under 18, please be sure to read the terms of this Privacy Policy with your parents or legal guardians. The Services are not directed or intended for Children, as defined under applicable law, and we do not knowingly collect or solicit information from children. If we later obtain actual knowledge that a user is considered as a Child under applicable law, we will take steps to immediately delete its Personal Data. We request that such individuals do not provide Personal Data through the Services. If you become aware or have any reason to believe that a Child has shared any information with us, please contact us (as detailed below) and we will take reasonable steps to ensure that such information is immediately deleted from our files.
Transfer of Data - We may process or store Personal Data within the EEA, US, and internationally. In the event of data transfer out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law. Further, when Personal Data collected within the EU is transferred outside the EU (and not to a recipient in a country that the European Commission has decided provides adequate protection) it shall be transferred in accordance with the provisions of the standard contractual clauses approved by the European Union.
Contact Us - If you have any questions or concerns regarding privacy issues, or if you wish to be provided with any other information related to our privacy practices, please contact us at: support@sentinelsecurity.com.
Additional Notice to California Residents
1. This section applies only to California residents, pursuant to the California Privacy Act of 2018 (“CCPA”) effective November 2020, and as amended by the California Privacy Rights Act, effective January 1, 2023.
2. This section does not address or apply to our handling of publicly available information or to Personal Information that is otherwise exempt under the CCPA. This section also does not address or apply to Personal Information we collect and process about our employees, personnel, and job applicants, which are subject to different privacy notices.
3. Categories of Personal Information Collected and Disclosed. While our processing of Personal Information varies based upon our relationship and interactions with you, the list below identifies the categories of Personal Information we may collect about you (and may have collected in the prior 12 months), as defined by the CCPA, as well as the categories of third parties to whom we disclosed Personal Information for a business or commercial purpose:
  1. Category (A) Identifiers: Online Identifier; Internet Protocol address. We will disclose the Identifiers with the following categories of third parties affiliates; Advisors and agents; Advertising networks; Data Analytics providers; Social networks; Regulators, government entities, and law enforcement (if required to do so by law or court order); Others as required by law.
  2. Category (F) Internet or other similar network activity.: web domains visited. We will disclose the web domains visited with the following categories of third parties Affiliates; Advisors and agents; Regulators, government entities, and law enforcement (if required to do so by law or court order); Others as required by law
  3. Category (G) Geolocation Data.: approximate location derived from IP address. We will disclose the Geolocation Data with the following categories of third parties Affiliates; Advisors and agents; Regulators, government entities, and law enforcement (if required to do so by law or court order); Others as required by law
4. Sources of Personal Information. We generally collect Personal Information from the following categories of sources: directly and indirectly from you; affiliates; business partners; vendors and service providers; operations systems and platforms, and marketing and data analytics providers.
5. Purposes of Collection, Use, and Disclosure. As described above in Section 3. How We Use Personal Information and Section 4. How We Share Personal Information, in general, we may collect, use, disclose and otherwise process the above personal information for the following business or commercial purposes and as otherwise directed or consented to by you:
  1. Operating Services and providing related support
  2. Analytics and improvement
  3. Marketing, advertising, and campaign management
  4. Security and protection of rights
  5. Compliance and legal process
  6. Business transfers
  7. Market intelligence or analytics services of our affiliates
  8. Provision of Services by us and by our service providers, processors, and vendors
Sales and Sharing of Personal Information:
1. The CCPA defines “sale” as disclosing or making available Personal Information to a third-party in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available Personal Information to a third-party for purposes of cross-context behavioral advertising. We do not “sell" your data.
2. We do not knowingly sell personal information about individuals who we know are under age sixteen (16).
Data Retention - We retain the Personal Information we collect only as reasonably necessary for the purposes described above or as otherwise disclosed to you at the time of collection. When deciding how long to keep your Personal Information, we consider whether we are subject to any legal obligations (e.g., any laws that require us to keep records for a certain period before we can delete them) or whether we have taken any legal positions (e.g., issued any legal holds or otherwise need to preserve the information). Rather than delete your data, we may also deidentify it by removing identifying details. Where we have committed to maintaining and using Personal Information in a deidentified form, we agree not to reidentify deidentified data except as permitted by applicable law.
California Consumer Rights - California law grants consumers certain rights and imposes restrictions on particular business practices as set forth below. California consumers have the right to request that we disclose what personal information we collect, use, disclose, and sell about you.
1. Right to Opt-out of Sale of Personal Information ("Do Not Sell") - You may have the right to opt-out of the “sale” or “sharing” of your Personal Information.
2. Requests for Copy, Deletion and Right to Know - Subject to certain exceptions, California consumers have the right to make the following requests, at no charge, up to twice every 12 months. Please see "Submitting Requests" for instructions on how to exercise your rights.
  1. Deletion: the right to request deletion of personal information that we have collected about you, subject to certain exemptions.
  2. Copy: the right to request a copy of the specific pieces of personal information that we have collected about you in the prior 12 months.
  3. Right to Know (Collection): Where we have collected personal information about you, the right to request that we disclose certain information about how we have handled your personal information in the prior 12 months, including: the categories of personal information collected; categories of sources of personal information; business and/or commercial purposes for collecting and selling your personal information; and the categories of third parties/with whom we have disclosed or shared your personal information.
  4. Right to Know (Disclosure and Sale): Where we have sold or disclosed for a business purpose your personal information, the right to request that we disclose certain information about how we have handled your personal information in the prior 12 months, including: the categories of personal information collected; categories of third parties to whom your personal information has been sold and the specific categories of personal information sold to each category of third party; categories of third parties to whom personal information has been disclosed; and the categories of personal information that we have disclosed or shared with a third party for a business purpose.
3. Submitting Requests. You can exercise your rights by emailing us at admin@sentsecurity.com. When you submit your request, we will take steps to attempt to verify your identity. We will seek to match the information in your request to the personal information we maintain about you. As part of our verification process, we may ask you to submit additional information, use identity verification services to assist us. Please understand that, depending on the type of request you submit, to protect the privacy and security of your personal information, we will only complete your request where we are satisfied that we have verified your identity to an appropriate degree of certainty. We will make every reasonable effort to respond to you within 45 days after we receive a verified request. If we are unable to meet this timescale, we will respond as soon as possible over the next 45-day period.
Consumer Rights -Residents of certain U.S. states, including Colorado, Connecticut, Virginia, and Utah, may have additional rights under applicable privacy laws, subject to certain limitations, which may include:
1. Access. The right to confirm whether we are processing their Personal Information and to obtain a copy of their Personal Information in a portable and, to the extent technically feasible, readily usable format.
2. Delete. The right to delete their Personal Information provided to or obtained by us.
3. Correct. The right to correct inaccuracies in their Personal Information, taking into account the nature and purposes of the processing of the personal information.
4. Opt-Out. To opt out of certain types of processing, including: (i) to opt out of the “sale” of their Personal Information; (ii) to opt out of targeted advertising by us; and (iii) to opt out of any processing of Personal Information for purposes of making decisions that produce legal or similarly significant effects.

You may submit a request to exercise most of your privacy rights under U.S. state privacy laws online by emailing us to admin@sentsecurity.com. When you submit a request, we will take steps to verify your identity and your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for denial and how to remedy any deficiencies, where applicable.

Authorized agents may initiate a request on behalf of another individual by contacting us at admin@sentsecurity.com; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.