Summary of how we use your data
- Senti Tech Limited (“Senti” / “we” / “us”) uses your personal data to track and analyse data recorded by our smart garment, and by you via our web and mobile apps, including for use in research projects and studies and with healthcare professionals.
- Data is shared with medical, health or other professionals you authorise to have access to your data. If you are taking part in a research study, project or programme your data may be sent to an international dataset or repository outside of the country in which you reside. We will rely on your voluntary, informed consent, and you will be clearly informed if your data will be used in this way.
- Where we rely on your consent, such as for contributing your data to research studies, sending your data to research datasets or to send your data to 3rd parties, you can withdraw this consent at any time, simply by contacting firstname.lastname@example.org.
- Our Device, Apps and Services are designed to help you track your data, usually as part of a research project or study, or with a medical, health or other professional, who may be our partner. Access to the Apps and Services may therefore be made available to you via one of our partners.
- We believe that you should own both the data captured by our device and which you enter into our apps, and that your data should only be used by you and professional clinicians and / or researchers where this is part of the study, project or programme you have signed up for.
- Your data will not be sold off or sent to other parties not involved in the specific study, project or programme you are part of.
- We may aggregate your data, anonymously, with other users’ data, in order to train and improve our machine learning algorithms which help us to deliver valuable insight to you and our other customers. This is vital to our services, and our lawful basis under GDPR will be Legitimate Interest. Where, rarely, we would need to use identifiable data as part of this process, we will make this very clear to you, and will take every step to protect your personal data.
What does this policy cover?
We design, develop, operate and maintain a novel wearable medical device (‘The Smart Garment’) and software application (the “App”) to help people track their data, including for use in research projects and studies and with healthcare professionals. Where we or our partners run a research programme using our App and you sign up to that research programme, we will collect and process data in accordance with the scope of activity for that research programme or project (which we or our partners will provide in writing prior to your agreeing to participate). Where one of our partners runs a research programme or project using our App, they will have access to your data for the purposes of that research programme or project.
If you have any questions regarding a research programme or project in which you are participating or the data being processed about you for that research programme or project, please contact the sponsor organisation for that research programme or project. Our Apps, Sites and Services may contain links to and from the online properties of our customers, partner networks, advertisers and affiliates or other third parties. If you follow a link to any of these online properties, please note that these online properties have their own privacy policies and that we cannot and do not accept any responsibility or liability for these policies.
Please check these policies carefully before you submit any personal data to these websites.
This policy describes how Senti will make use of your data in relation to:
- Our Smart Garment,
- Our Apps (regardless of whether these are accessed via mobile device or otherwise)
- Any of the services accessible through the Apps (our “Services”); and
- Any of our websites including without limitations the Senti website located at: senti.care and all subdomains and paths (our “Sites”).
Together, these are referred to as the “Senti Platform”
It also describes your data protection rights, including a right to object to some of the processing which Senti carries out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.
Our Core Privacy Principles
OWNERSHIP – You own your personal data
CHOICE – You decide how much personal data you provide when using the Apps
TRANSPARENCY – we will always tell you what data we hold about you and what we do with this data
What information do we collect?
We collect and process personal data about you when you interact with us and the Senti Platform. We may collect and process the following data about you:
- Information that you provide by filling in forms or surveys on our Site or Apps. This includes information you provide when you register on our Sites or Apps and open an account, post material or request further services. We may also ask you for information when you report a problem with our Sites, Apps or Services.
- If you contact us, we may keep a record of that correspondence.
- When you visit our Sites or Apps or interact with our Services, we (and our other service providers) may use a variety of technologies that automatically or passively collect information about how our Services are accessed and used (“Usage Data”). Usage Data may include:
- The type of mobile device you use (e.g are you using an Apple or a Samsung Device);
- A unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface or the mobile phone number used by the Device);
- Mobile network information (e.g are you on the 3 network or the Vodafone network?);
- Your mobile operating system (e.g. are you using an iphone or an Android?);
- Your IP address and HTTP referrer information (eg the page served, the time, referring URLs);
- The type of mobile browser you use (e.g. are you using the Chrome or Safari browser?);
- Time zone setting (e.g. GMT, EST?);
- We will also collect similar usage data on your use of our smart garment.
Usage Data helps us understand our users better and tailor content to their needs and interest. Usage Data is statistical data about our users’ browsing actions and patterns, and does not identify any individual. Please rest assured that we will treat Usage Data as personal data if we combine it with you as a specific and identifiable person.
What information do we receive from third parties?
Sometimes, we may receive information about you from third parties. In particular, we may receive your name or email address from a healthcare professional, a hospital or care site, a study researcher or a project sponsor to invite you to use the Senti platform. Any information received from third parties would be processed in the same manner as any data you enter into the Senti platform.
How do we use the information collected by the Senti Platform or received from 3rd parties, and what is the legal basis for this use?
We process this personal data for the following purposes:
To fulfil a contract, or take steps linked to a contract, including a contract with yourself to deliver our Services. This includes:
- Creating a new account
- Verifying your identity to access your account;
- Arranging the delivery of our smart garment;
- sharing your data entered into the Senti Platform with professional authorised users;
- communicating with you about any research study, project or programme you have signed up to;
- providing customer services and arranging the delivery or other provision of products, information or services which you have signed up to;
- As required by Senti to conduct our business and pursue our legitimate interests, in particular:
- we will use your information to provide you with relevant information, products and/or services which you may request or which we may decide would fit your needs. For example, we may suggest ways in which you can act on the data insights delivered by our device, or alert you to suitable research opportunities which you might be interested in helping.
- we monitor use of our websites and online services, and use your information to help us monitor, improve and protect our products, content, services and websites, both online and offline and ensure that content from our Sites and Apps is presented in the most effective manner for you and for your computer;
- we use information you provide to personalise our website, products or services for you and notify you about changes to our Sites, Apps or Services;
- we may provide aggregate user statistics, demographic information and Usage Data which does not identify you specifically with third parties. We may combine your Usage Data with those of other users of our products and services and share or provide this trend information in aggregated and anonymised form with third parties. For example, we may use your Usage Data as part of an aggregated number to assist a university, academic institution or a hospital with their medical research;
- we may also use information collected from you and combine it with information provided by our other users of our products and services to help us improve the design and delivery of our software tools, increasing the effectiveness for all users. Data will usually be analysed in an anonymous format by company employees and contractors to improve our products;
- Specifically, we use data collected by our smart garment in order to train and validate machine learning models to improve the predictive insights on which our services rely. We will take every possible step to ensure that this data is anonymised. However, as with all complex biometric data, we cannot guarantee that it is impossible for an individual to be identified from the data we collect. We will take additional steps to layer anonymity by adding noise to the data prior to model training. We will also take all precautions to ensure that your data is secure, audit access to the data, and ensure good governance at all levels.
- we monitor customer accounts to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;
- we use information you provide to investigate any complaints received from you or from others, about our website or our products or services;
- we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation); and
- we use data of some individuals to invite them to take part in research studies;
- Where you give us consent:
- we place cookies and use similar technologies in accordance with our Cookies Policy (see separate document) = and the information provided to you when those technologies are used]
- on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.
- For purposes which are required by law:
- where we need parental consent to provide online services to children under 16. However, most of our websites are not designed for children under 16.
- In response to requests by government or law enforcement authorities conducting an investigation.
Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above.
Who will we share this data with, where and when?
Our Apps and Services are designed to help you track your data. They have additional value when used alongside your care team (medical, health or other professional), who may be our partner. There will also be opportunities to be part of research projects or studies. Access to the Senti Platform may therefore be made available to you via one of our partners (for example, your GP may provide you with access).
In registering to use the Apps and Services, you will have used a unique registration code. This unique registration code links your Senti account to one or more of our online properties or to online properties of our partners. For example, your Senti account may be linked to a specific database for a research study or for a particular hospital or a doctor’s surgery.
- Your data will be viewable by all professional authorised users of the online properties your account is linked to (researchers, site managers, doctors, nurses, practice managers, dieticians etc.).
- Your data will not be viewable by other patient users unless you elect otherwise.
- It may also be possible for your clinicians or health professionals to add data to your account (for example, a diary note, or a new task) as well as view any data you have entered.
- We do, however, put you in control of your data, and will explicitly ask for your consent before any of your data is shared with one of our partners, or with your own care team. However you should be aware that this may affect how you and your clinicians and / or researchers use the Service.
If you have access to the Apps and Services via a Senti partner and that partner terminates its contractual relationship with Senti, you may no longer have access to the Senti Platform via that partner. Data uploaded whilst using the Senti Platform via the Partner may also no longer be accessible.
If you would like further information about whether you will have continued access to the Platform following termination of our contractual relationship with the relevant partner, please contact email@example.com.
Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
Personal data will also be shared with third party service providers, who will process it on behalf of Senti for the purposes identified above. Such third parties include providers of website hosting, maintenance, call centre operations (if this is part of a specific project or programme in which you are participating) and identity checking services where this is an essential part of your project or programme.
In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.
Where your data is stored.
User data is generally stored exclusively within the UK.
What rights do I have?
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.
To exercise any of these rights, you can get in touch with us using the details set out below. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.
For registration into the Senti Platform and the verification of your identity the provision of information is mandatory: if relevant data is not provided, then we will not be able to create a new account, register you into your study, project or programme or securely log you into an existing account. All other provision of your information is optional. However, if you do not provide your information your experience in using the Senti Platform may be impaired and you may not receive the full benefit of using our Services, either individually, or with your healthcare professional or research team.
How do I get in touch with you?
We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at firstname.lastname@example.org
How long will you retain my data?
If you want to stop using your Senti account, you can either deactivate or delete it.
Deactivating your account puts your account on hold but we do not delete any of your information. You can deactivate your account by sending an email to email@example.com with the subject heading ‘Account deactivation’. When you delete an account, it is permanently deleted from Senti. This process is irreversible. It typically takes us about 48 hours to delete an account, but some information may remain in backup copies and logs for up to 6 months. You should only delete your account if you are sure you never want to reactivate it. You can delete your account by sending an email to firstname.lastname@example.org with the subject heading ‘Account deletion’.
Where we process registration data, we do this for as long as you are an active user of our Apps and Services and for 6 years after this.
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.
Where we process personal data in connection with performing a contract, a project or research study, we keep the data for 6 years from your last interaction with us.