Last updated: Wednesday, July 15 2016

This privacy policy governs your use of Sentiance’s DataCollect mobile application (‘Application’) on your mobile device. The Application collects and processes information about your travel and routine behavior, such as driving, walking, biking and public transport (train, metro and bus) travel periods and distances. By using the Application, you consent to Sentiance’s collection, use and publication of information as set forth below. You may not download and use the Application if you are under sixteen (16) years of age.

A. Information collected through the application

Personal information is information which identifies you as an individual, whether directly or indirectly through the combination with other information held by Sentiance. In order for you to download and use the Application, Sentiance may require you to provide personal information such as your e-mail address.

Sentiance also collects non-personal information that does not directly or in combination with other information identifies you as an individual, such as your type of device, operating system (‘OS’), type of mobile browser, your use of the Application, your real-time location (based on information provided by your device OS), accelerometer data and gyroscope data. Further, depending on your device make and type and your permissions, Sentiance also collect the following data supplied by the device’s OS: activity information, step detection and count, Bluetooth information and battery information.

You agree that Sentiance may store a pseudonymous Sentiance ID number on your device that will be used for profiling as explained below. Sentiance may further request and collect your pseudonymous feedback on assumptions made by Sentiance based on non-personal information it collects.

For the avoidance of doubt, Sentiance defines pseudonymous data as personal data processed in such a manner that they can no longer be attributed to you without the use of additional information, which Sentiance keeps separately and subject to technical and organizational measures to this effect.

B. Purpose of collection and use of information

Sentiance collects and uses personal information for the following specific purposes:

  1. to send you adequate information regarding the application
  2. to respond to your comments and problems
  3. for Sentiance’s data analysis
  4. to investigate potentially unlawful use of the application

Sentiance only collects personal information that is adequate, relevant and not excessive in relation to the above purposes.

Non-personal information (including location data) is used by Sentiance to build pseudonymous profiles that may allow Sentiance to detect where you live and work, when and by what means you are travelling and to make an estimated guess of your age, gender and routine behavior. Sentiance will publish your pseudonymous location data on an interactive map on the public part of its website. Non-personal information is also used to refine the algorithms that detect transportation modes, to find battery-efficient triggers for start and stop of transport detection logging and to conduct analytics in order to improve the Application.

C. Third party recipients of information

Sentiance may disclose your personal information to

  1. Sentiance’s service providers who provide services to Sentiance, such as hosting (including Amazon Web Services), data analysis, IT services, and other similar services requested by Sentiance.
  2. Sentiance’s suppliers e.g. offshore development hubs and service providers
  3. Sentiance’s clients e.g. SDK licensees and Journey licensees
  4. Other recipients based on legitimate grounds or a legal obligation.

Other than as set forth above, Sentiance will not transfer any of your personal information to third parties without your explicit consent.

Transfers only relate to personal information which is adequate, relevant and limited to what is necessary in relation to the purpose for which they are transferred and abides by the concept of data minimization.

D. Security, reliability and retention of information

Sentiance has implemented appropriate technical and organizational measures to protect information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.

Sentiance takes reasonable steps to ensure that any personal information in its possession is accurate, complete, current and reliable for its intended use.

Sentiance will delete your personal information upon deletion of your account (unless a longer retention period is required by law). Non-personal information may be retained without limitation in time.

E. Your rights

In respect of the collection and use of your personal information, you may:

  1. inquire with Sentiance if your personal information is being processed, for which purposes and to which recipients the information has been disclosed
  2. access your personal information processed by Sentiance and have it rectified
  3. object against the further processing of your personal information on legitimate grounds
  4. request that your personal information will no longer be used for marketing purposes by Sentiance

In order to do so, you should send Sentiance a letter on the address provided below or an e-mail to privacy@sentiance.com with a copy of your identity card or other proof of your identity. Sentiance will undertake the necessary action without undue delay and provide the requested information within 45 days.

Privacy
Sentiance NV
Korte Lozanastraat 20-26
2018 Antwerp
Belgium

You may delete your account and uninstall the Application at any time to immediately stop any collection of data. You may also opt-out from collection of your real-time location data through the OS settings of your device. If you do not want to delete your account but want to temporarily stop any collection of information, you can do so by uninstalling the Application. Uninstalling the Application will also delete the anonymous Sentiance ID number.

F. Amendments

Sentiance reserves the right, in its sole discretion, to amend this Privacy Policy at any time by posting amendments on its website.

July 15, 2016