We are Sen Corporation Limited, a private company incorporated in England with our registered address at 1st Floor 33 Great Sutton Street, London, United Kingdom, EC1V 0DX and our company number: 06270642 (“we”, “us”, “our”).
This privacy policy aims to give you information about how we collect and process your personal data through your use of the Sen Content accessed via our app on iOS, our web app on sen.com or on any other platform through which Sen makes the Sen Content available (“our Platform”) and any related services which you receive from us (“our Services”).
It is important that you read this privacy policy together with any other privacy policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Since we make decisions about what data we collect when you access our Platform or use our Services, and about how we use that data, we are acting as a controller in respect of that data. This means that we are responsible to you for such collection, storage and use.
If you have any questions about this privacy policy or our privacy practices, please contact us atdata.privacy@sen.comor you can write to us at Sen Corporation Limited, 1st Floor 33 Great Sutton Street, London, United Kingdom, EC1V 0DX.
If you are based in the EU or the EEA you may also contact our EU representative, Data Protection Representative Limited (trading as “DataRep”) You can contact them by:
Please note that if you mail any inquiries to DataRep, it isESSENTIAL that you mark your letters for the attention of: ‘DataRep’and not ‘Sen Corporation Limited’ or your inquiry might not reach the appropriate party. Please do refer clearly to Sen Corporation Limited in your correspondence.
You can find out more information about DataRep’s handling of personal data on their privacy notice, which is available at the following link:www.datarep.com/privacy-policy .
You have the right to make a complaint at any time to a national supervisory authority in the Member State of your residence or in the place of the alleged infringements. You can find a list of contact details for all EU supervisory authorities athttp://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
As we are incorporated in the United Kingdom, our regulatory authority is the Information Commissioner’s Office (“ICO”). Contact details for the ICO can be found on its website athttps://ico.org.uk.
We keep our privacy policy under regular review. This version was last updated on 1 September 2022. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Platform, we encourage you to read the privacy policy of every website you visit.
Personal data, or personal information, means any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name, username or similar identifier, gender, preferred pronoun and your date of birth (or confirmation as to age).
Contact Data includes email address, physical address and telephone numbers. If you are signing up in connection with a business this may also include job role and the name of the business you work for.
Financial Data includes information relating to your banking details and payment card details. This will only be relevant if you sign up to receive any of our premium services.
Transaction Data includes details about payments to and from you, such as invoices credit notes and financial statements of account and other details of services you have purchased from us. This will only be relevant if you sign up to receive any of our premium services.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Platform.
Profile Data includes your browsing history, videos viewed, shared, liked or saved, preferences, interests, information about any content you post on our Platform, ads clicked on, survey responses.
Usage Data includes information about how you use our Platform and Services (such as duration, frequency and timing of access, devices used for access and interactions).
Marketing and Communications Data includes your preferences in receiving marketing from us and third parties and your communication preferences.
We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data willnotdirectly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website or app feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
Owing to the nature of our services (which include access to real-time videos from space), we may need to carry out certain due diligence activities on customers so we understand who they are, how they intend to use our data and why they want to access our services. This might require us to collect and store information relating to a customer’s political affiliations, beneficial ownership and we may also look at your credit rating (any such data, “Due Diligence Data”).
Aside from this, we do not collect any “Special Categories of Personal Data” about you (such as information about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data), nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, to meet our internal due diligence requirements or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may not be able to provide our Services to you or may have to cancel some of our Services to you.
We use different methods to collect data from and about you including through:
Direct interactions . You may give us your Identity, Contact, Financial and Marketing and Communications Data by registering with us, filling in forms on our Platform or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Automated technologies or interactions . As you interact with our Platform we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policyhttps://sen.com/cookiesfor further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from:
analytics providers such as Google, which is based outside the UK;
various advertising networks, which may be based outside the UK; and
Contact and Financial Data from providers of technical, payment and delivery services which may be based outside the UK;
Identity and Due Diligence Data from provides of EDD, KYC and credit rating services, which may be based outside the UK; and
Contact Data and information relating to any requests, comments or complaints which you might send to our EU Representative;
Identity, Contact and Due Diligence Data from publicly available sources such as Companies House and other websites.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.Legitimate Interestmeans the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Where we need to comply with a legal obligation.Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
To register your user account with us. |
| Performance of a contract with you |
To carry out due diligence checks and assessments (which may be required if you wish to receive certain premium services). |
|
|
To provide you with our Services, which might include:
|
|
|
To manage our relationship with you which will include:
|
|
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To enable you to partake in a prize draw, competition or complete a survey |
|
|
To administer and protect our business and our Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
|
|
To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
| Necessary for our legitimate interests (to study how customers use our Services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to improve our Platform, services, marketing, customer relationships and experiences |
| Necessary for our legitimate interests (to define types of customers for our Services and services, to keep our Platform updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about our Services that may be of interest to you |
| Necessary for our legitimate interests (to define types of customers for our Services and services, to keep our Platform updated and relevant, to develop our business and to inform our marketing strategy) |
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased or accessed services from us and you have not opted out of receiving that marketing or if you have given us your consent.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us to stop emailing or texting you marketing messages at any time by following the opt-out links on any marketing message we send to you by contacting us at any time.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Platform may become inaccessible or not function properly. For more information about the cookies we use, please see https://sen.com/cookies.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table above.
Service providers acting as processors which provide IT, hosting, document management, marketing and system administration services (such as AWS, Microsoft O365, Salesforce, Mailchimp and Docusign).
Our employees and consultants who provide us with IT support, infrastructure and other customer-facing or management services
Professional advisers including lawyers, bankers, auditors and insurers based in who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
Providers of due diligence services, credit ratings agencies and other publicly available search engines.
Third party payment providers which we use to facilitate payments to use our premium services.
Third party affiliates and advertising engines.
Our EU Representative (the details of which are provided at section 1.3)
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
Occasionally we may be required to share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We are located in the UK. Therefore, when you submit personal data to us, whether through your interactions with our Platform or otherwise, if you are based outside the UK, you acknowledge that your personal data will be transferred into the UK.
Our Platform, video content and Usage Data is hosted on AWS servers in the UK and Ireland. Where possible we only use processors which has servers based in the UK and Ireland. However, from time to time some of our service providers and/or third party affiliates may be based outside the UK and the EEA. Non-EEA countries do not have the same data protection laws as the UK and the EEA. In particular, non-EEA countries may not provide the same degree of protection for your personal data, may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data. When transferring your personal data outside the UK or the EEA, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data. For example:
We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission and/or the UK government (as applicable).
Where we use certain service providers, we may use specific standard contractual clauses approved by the European Commission and/or the UK government which give personal data the same protection as it has in Europe and/or the UK.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for the duration for which they receive our Services plus six years after they cease being customers for tax purposes and for our own internal records.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
We do not knowingly use our Platform to collect data relating to minors. If you are under the age of 16, you must ask a parent or legal guardian to sign up on your behalf. Please contact us if you have reason to believe that a minor may have submitted personal data to us via our Platform.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Request access to your personal data (commonly known as a 'data subject access request'). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processingof your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data‘s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us (or our EU Representative) using the details at section 1.3 above.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.