Sentiance only ever processes first-party data. The very highest privacy standards are an essential part of how we work.
Safer drivers T&C proposal
By opting-in during the installation process of the Application and by your continuing use of the Application, you grant your unambiguous consent to the collection, processing and publication of your personal and non-personal data as described below.
The Application may only be used by individuals as from eighteen (18) years of age.
The Application is provided by a joint collaboration between Sentiance NV (“Sentiance”) and RACWA Holdings Pty Ltd (“RAC”).
Protecting your personal data is of the utmost importance for Sentiance and RAC and we take the necessary precautions to safeguard your data and process it only in compliance with the General Data Protection Regulation (GDPR) and the Australian Privacy principles (APP).
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 and/or RAC.
In order for you to download and use the Application, Sentiance and RAC will require you to provide personal information such as your email address and your confirmation on the age restriction. After verification of your email address, Sentiance will store a Sentiance ID number which it will use for automated profiling as explained in section B below. In addition, Sentiance will collect and process your real-time location based on information provided by your device operating system (‘OS’) and share this data with RAC.
Sentiance collects non-personal information that does not directly or in combination with other information identifies you as an individual.
The non-personal information collected by Sentiance and RAC may be your type of device, type of OS, type of mobile browser, information on your use of the Application, accelerometer data and gyroscope data. Further, depending on your device make and type and your permissions, Sentiance and RAC may also collect the following non-personal data supplied by the device’s OS: activity information, step detection and step count, Bluetooth information and battery information
In order to improve its profiling algorithms, Sentiance and RAC may request and collect your feedback on assumptions made by Sentiance and RAC based on the collected information.
B. Purpose of collection and use of information
Sentiance collects and uses personal information for the following specific purposes:
- to build profiles that may allow Sentiance to detect places you visit and frequent, when and by what means you are travelling and to make an estimated guess of your age, gender and routine behavior;
- to provide tailored coaching advice based on your profile
- to send you adequate information regarding the Application
- to respond to your comments and problems
- for Sentiance’s data analysis
- to investigate potentially unlawful use of the Application
Sentiance may also use your profile to build an interactive map. Sentiance only collects personal information that is adequate, relevant and limited to what is necessary for the above purposes.
Non-personal information is used to refine the algorithms that detect transportation modes, to find battery-efficient triggers for the start and stop of transport detection logging and to conduct analytics in order to improve the profiling algorithms and Application.
C. Third party recipients of information
Sentiance and RAC may disclose your personal and non-personal information to third party recipients such as:
- Sentiance’s service providers, such as its offshore development hubs and service providers, hosting providers (including Amazon Web Services), and providers of data analysis, IT services, and other similar services requested by Sentiance
- Other recipients based on legitimate interests as permitted under applicable law
- A third party as required by applicable law, to comply with legal procedures, to respond to requests from public authorities, to enforce this policy and to protect Sentiance’s rights
- A third party in the event of any merger, sale or transfer or other disposition of all or any portion of Sentiance’s business, assets or stock in which said third party is involved
Transfers only relate to personal information which is adequate, relevant and limited to what is necessary in relation to the purpose for which it is transferred.
Other than as set forth above, Sentiance and RAC will not transfer any of your personal information to third parties without your explicit consent.
D. Security, reliability and retention of information
Sentiance has implemented appropriate technical and organizational measures (such as explicit opt-in and pseudonymisation), which are designed to implement data-protection principles (such as data minimization) in an effective manner and integrated the necessary safeguards into the processing in order to protect information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to personal information, and against all other unlawful forms of processing.
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.
Sentiance takes reasonable steps to ensure that any personal information in its possession is accurate, current and reliable for the purposes set out above.
E. Your rights
In respect of the collection and use of your personal information, you may
- ask Sentiance whether it processes personal data about you, for which purposes, the categories of personal data concerned, to which recipients the information has been disclosed, where possible, the envisaged period for which the personal data will be stored (or, if not possible, the criteria used to determine that period)
- inquire with Sentiance about the appropriate safeguards relating to the transfer to a third country
- ask Sentiance a copy of the personal data undergoing processing (including for data portability purposes) and have it rectified
- object against the further processing and request erasure of your personal information on legitimate grounds
- request that the processing of your personal information is restricted by Sentiance
- request not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you
In order to do so, you should send Sentiance a letter on the address provided below or an email to firstname.lastname@example.org with a copy of your identity card or other proof of your identity. Sentiance will undertake the necessary action without undue delay and provide information on action taken (or the absence of any such action) within 30 days.
Korte Lozanastraat 20-26
You may also lodge a complaint with a supervisory authority in case of breach of the applicable privacy laws by Sentiance.
You may at any time immediately stop any collection and processing of personal data by Sentiance by uninstalling or deleting the Application. Uninstalling the Application will also delete the Sentiance ID number from your mobile device.
If you want to keep the Application but stop the collection of your real-time location data, you may opt-out through the OS settings of your device. Please be aware that such opt-out may result in your profile becoming inaccurate and unreliable.
F. Data controller coordinates
Korte Lozanastraat 20-26
April 12, 2021