SENTIENT SOLUTIONS LIMITED (trading as Scorebuddy)
Please read the following Privacy Statement to learn more about how we collect, store, use and disclose information about you when you interact with Sentient. This Privacy Statement applies to all your Personal Data collected by, or on behalf of, Sentient.
If you believe that we hold or are using your personal data in a manner which is contrary to your wishes, please contact firstname.lastname@example.org.
“you” and “your”
|the person/entity that has purchased the SaaS Service(s) and is using the SaaS Services;|
|“Data Protection Legislation”||(a) the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”);
(b) the Irish Data Protection Acts 1988 and 2018;
(c) the European Communities (Electronic Communications Networks & Services) (Privacy & Electronic Communications) Regulations 2011;
(d) the EU Data Protection Directive 95/46/EC;
(e) the EU ePrivacy Directive 2002/58/EC (as amended) (the “ePrivacy Directive”);
(f) any relevant transposition of, or successor or replacement to the laws detailed at (a) to (e) inclusive (including the successor to the ePrivacy Directive); and
all other industry guidelines (whether statutory or non-statutory) or applicable codes of practice and guidance notes issued from time to time by the Irish Data Protection Commissioner or other relevant national or supra-national authority relating to the processing of Personal Data or privacy;
|“data subjects”||shall have the meaning ascribed under the GDPR;|
|“personal data”||shall have the meaning ascribed under the GDPR;|
|“Privacy Statement”||this Privacy Statement;|
|“SaaS Services”||Sentient’s multichannel call centre quality assurance solution for call centres and outsourcers; Scorebuddy, and/or Sentient’s customer analytics solution for call centres and outsourcers; Cx Moments;|
|“Sentient”||Sentient Solutions Limited and its related companies and subsidiaries;|
|“Terms and Conditions”||Sentient Solutions’ Terms and Conditions of Use of the SaaS Services; and|
- What does this Privacy Statement cover?
This Privacy Statement sets out how, and for what purposes, we use the information collected about you directly, indirectly or via our website. This Privacy Statement covers our treatment of your personal information that we gather when you are interacting with Sentient either via the Website or via the SaaS Services (a “Data Subject”). In the course of our business, we gather various types of information about our Data Subjects, including information that identifies you as an individual (“Personal Data”) as explained in more detail below. This website is not intended for children and we do not knowingly collect data relating to children.
- Who is responsible for the processing of your Personal Data?
The data controller is Sentient whose registered office is The Masonry, 151 Thomas Street, Dublin 8, Ireland.
- Handling of Third Party Data
Sentient is also required to process third party data (acting as a “data processor”) on behalf of our Customers. We are not the data controller in respect of our Customer’s clients’ personal data. The Customer is the data controller in respect of this data and we are the Customer’s data controller. We exclusively process this third party data in the form of meta-data, and do not import any personal information for unique use. It is a condition of any contract with Sentient that the data controller (i.e. the party that supplies the third party data to us and the party that determines the purpose and means of the personal data processing) is entirely compliant with Data Protection Legislation. Sentient cannot oversee contractual agreements between you and third parties, as such your use of third party data is solely your responsibility.
- What is the legal basis for possessing my Personal Data?
The principal legal basis for this processing is our legitimate interest in the provision of our core business activities of; providing a call centre quality assurance solution for scoring customer service calls, emails and web chat; ‘Scorebuddy’, and our customer analytics solution for call centres and outsourcers; ‘Cx Moments’. In addition, please note that in accordance with applicable data protection law, your personal data can be processed if:
- you have given us your consent for the purposes of the Processing. For the avoidance of doubt, you will always have the right to withdraw your consent at any time;
- it is necessary for the performance of a contract to which you are a party; or
- it is required by law.
- Sentient’s Terms and Conditions
- Personal Data Collected by Sentient
There are various circumstances in which Sentient is required to process and store personal data. We set them out here:
- We collect the e-mail addresses of data subjects who communicate with us via e-mail or supply their email addresses to us by some other means;
- We collect information volunteered by you (such as survey information and/or site registrations), and other personal information where applicable such as you or your customers’ name, telephone number, home address and information and services which you have requested;
- We store aggregate information on what pages consumers access or visit; and
- We store third party data provided to us by you in accordance with our Terms and Conditions.
- Use of Personal Data
We use personal data which we collect in the ordinary course of our business in accordance with your permission. We may use your data where necessary for our legitimate business interests, including to:
- improve the content of our Website and the services we offer;
- ensure the Website is presented in the most effective manner for you and for your computer;
- compile statistical data on the use of our Website;
- allow you to participate in interactive features of our service, when you choose to do so; and
- notify you about changes to our service.
The information we collect is not shared with or sold to other organizations for commercial purpose except to provide products or services you’ve requested, when we have your permission.
- Marketing Emails
We send marketing emails on a monthly basis to our database of emails. We do this on an opt-in basis and provide a clear unsubscribe option in circumstances where you no longer wish to receive such emails.
- We may disclose your personal data to third parties who provide a service to us, such as our Internet Service Provider who records data on our behalf and is bound by confidentiality provisions.
- We may from time to time be required to your personal disclose data under special circumstances and where it is expressly required by applicable legislation or by law enforcement agencies, such as to comply with a subpoena or if your actions violate our Terms and Conditions.
- It may be necessary to share your personal data in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Terms of Service of the specific application, or as otherwise required by law.
- Any such disclosure shall be assessed individually and carried out in strict accordance with Data Protection Legislation. Where Sentient is required to disclose your data to third party by law, we will do so according to the strictest guidelines and only where we deem the action to be necessary.
- Third Party Data
In offering cloud based solutions through SaaS Services, Sentient may be required to store certain third party data uploaded by you for the following general purposes: products and services provision, billing, identification and authentication, services improvement, contact, and research. Sentient does not share your personal information or the information of your consumers with any third parties.
- The security of your personal data is very important to Sentient. We use all appropriate physical, electronic, and administrative safeguards designed to protect your personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction.
- The transmission of information via the internet is not completely secure and may involve the transfer of data to a third party outside of the European Economic Area (EEA). To the limited extent that it is necessary to transfer your Data outside of the EEA, we will ensure appropriate safeguards are in place to protect the privacy and integrity of such data.
- If we discover a breach which could have an impact on your privacy, we will notify you as soon as practicable and keep you up to date with how we are managing the problem. We will also report any such breach to the Supervisory Authority in accordance with Data Protection Legislation.
- Your browser may allow you to set how it handles cookies, such as declining all cookies or prompting you on whether to accept each cookie. But please note that some parts of the Site may not work as intended or may not work at all without cookies.
- Data Retention
- We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 requirements.
- Sentient upholds the your “right to be forgotten”. If you wish for any data concerning you to be deleted by us, we will do so upon a written request to email@example.com.
- Data Storage
Sentient may use third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run our services. Although Sentient owns the code, databases, and all rights to the Sentient applications, you retain all rights to your data.
- Your rights
- You may request access to, rectification, erasure or restriction of your personal data, or object to the processing of your personal data or data portability at any time. We will respond to your request in writing, or orally if requested, as soon as practicable and in any event within one month of receipt of your request. We may request proof of identification to verify your request. All requests should be addressed to firstname.lastname@example.org.
- You have the right to lodge a complaint with the Data Protection Commission if you are unhappy with how we are processing your Data.
- At Sentient, we take the issue of data security very seriously. If you believe that we are in breach of our obligations in this regard, please get in contact with our highly skilled staff members and they will endeavour to resolve your issue without delay.
- Changes to this Privacy Statement
We reserve the right to change this Privacy Statement from time to time at our sole discretion. If we make any changes, we will post those changes here and update the “Last Updated” date at the bottom of this Privacy Statement. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check this Statement periodically for updates.
- Contact Us
If you have any questions or concerns regarding how your Data is processed via this Site, please contact us at email@example.com or by post to Sentient Solutions Limited, The Masonry, 151 Thomas Street, Dublin 8, Ireland. All requests will be dealt with promptly and efficiently.
Last Updated: 14 June 2021
This Policy details our commitment to protecting the privacy of individuals who visit our Website (“Visitors”), who register to use the products and services which we market for subscription (available at www.cxmoments.com) (the “Service(s)”. For the purposes of this Policy, the term, “Website”, shall refer collectively to www.cxmoments.com.
2. Scope of this policy
For the purposes of this Policy, “Cx MOMENTS Customer” shall refer to an individual or an entity that has entered into a Service Agreement (defined below) for use of our Services.
In this Policy, personal information means information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, and online identifier or to one or more factors specific to his/her physical, physiological, genetic, mental, economic, cultural or social identity. The use of information collected through our Service shall be limited to the purpose of providing the Service for which the Cx MOMENTS Customers has engaged.
With the exception of Account Information (as defined below) and other information we collect in connection with your registration or authentication into our Services (as defined below), this Policy does not apply to our security and privacy practices in connection with your access to and use of the Services. These security and privacy practices, including how we protect, collect, and use electronic data, text, messages, communications or other materials submitted to and stored within the Services by You (“Service Data”), are detailed in and governed by our Service Agreement.
Cx MOMENTS Customers to our Services are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements or other obligations, relating to the collection of personal information in connection with the use of our Services by individuals (also referred to as “data subjects”) with whom our Cx MOMENTS Customers interact. If you are an individual who interacts with a Cx MOMENTS Customer using our Services, then you will be directed to contact our Cx MOMENTS Customer for assistance with any requests or questions relating to your personal information.
We collect information under the direction of our Cx MOMENTS Customers, and have no direct relationship with individuals whose personal information we process in connection with our Cx MOMENTS Customer’s use of our Services. If you are an individual who interacts with a Cx MOMENTS Customer using our Services (such as a customer of one of our Cx MOMENTS Customers) and would either like to amend your contact information or no longer wish to be contacted by one of our Cx MOMENTS Customers that use our Services, please contact the Cx MOMENTS Customer that you interact with directly.
We may transfer personal information to companies that help us provide our Services. Transfers to subsequent third parties for these purposes are governed by the Service Agreements with our Cx MOMENTS Customers.
3. Information that you provide to us
Account and registration information: We ask for and may collect personal information about you such as your name, address, phone number, email address, instant messaging ID, and credit card information, as well as certain related information like your company name and website name, when you register for an account to access or utilize one or more of our Services (an “Account”). We also ask for and collect personal information such as an email address and a name or alias from any individual that you authorize to log into and utilize our Services in connection with Your Account. If you sign-up for a free trial Account, you are not required to enter your credit card information unless and until you decide to continue with a paid subscription to our Services. A third-party intermediary is used to manage credit card processing. This intermediary is not permitted to store, retain, or use your billing information for any purpose except for credit card processing on our behalf.
We refer to any information described above as “Account Information” for the purposes of this Policy. By voluntarily providing us with Account Information, you represent that you are the owner of such personal data or otherwise have the requisite consent to provide it to us.
We ask for and may collect personal information from you when you submit web forms on our Website.
4. Information that we collect from you on our Website
Web beacons, tags and scripts may be used on our Website or in email or other electronic communications we send to you. These assist us in delivering cookies, counting visits to our Website, understanding usage and campaign effectiveness and determining whether an email has been opened and acted upon. We may receive reports based on the use of these technologies by our third-party service providers on an individual and aggregated basis.
We use Local Storage Objects (“LSOs”) such as HTML5 to store content information and preferences. Various browsers may offer their own management tools for removing HTML5 LSOs. Third parties with whom we partner to provide certain features on our Website or to display advertising based upon your Web browsing activity use LSOs such as HTML5 and Flash to collect and store information. For further information on how to manage Flash LSOs please click here.
Logs: As is true with most Website and services delivered over the Internet, we gather certain information and store it in log files when you interact with our Website and Services. This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, identification numbers associated with your devices, your mobile carrier, and system configuration information. Occasionally, we connect personal information to information gathered in our log files as necessary to improve our Website and Services. In such a case, we would treat the combined information in accordance with this Policy.
Analytics: We collect analytics information when you use the Website to help us improve them. We may also share anonymous data about your actions on our Website with third-party service providers of analytics services.
We also use mobile analytics software to allow us to better understand the functionality of our mobile application on your device. This software may record information such as how often you use the mobile application, the events that occur within the mobile application, aggregated usage, performance data, and where the mobile application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.
5. Information collected from other sources
Social Media Widgets: The Website include social media features, such as the Facebook Like button, and widgets, such as the Share This button or interactive mini-programs that run on our Website. These features may collect your Internet protocol address, which page you are visiting on the Website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Website. Your interactions with these features are governed by the privacy statement of the companies that provide them.
Information from third party services: We may also obtain other information, including personal information, from third parties and combine that with information we collect through our Website. For example, we may have access to certain information from a third party social media or authentication service if you log into our Services through such a service or otherwise provide us with access to information from the service. Any access that we may have to such information from a third party social media or authentication service is in accordance with the authorization procedures determined by that service. By authorizing us to connect with a third party service, you authorize us to access and store your name, email address(es), current city, profile picture URL, and other personal information that the third party service makes available to us, and to use and disclose it in accordance with this Policy. You should check your privacy settings on these third party services to understand and change the information sent to us through these services. For example, you can log in to the Services using sign-in services such as Facebook Connect or an Open ID provider, as further described below.
6. How we use information that we collect
General uses: We may use the information we collect about you (including personal information, to the extent applicable) for a variety of purposes, including to (a) provide, operate, maintain, improve, and promote the Services; (b) enable you to access and use the Services; (c) process and complete transactions, and send you related information, including purchase confirmations and invoices; (d) send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages; (e) send promotional communications, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events; and provide other news or information about us and our partners. You can opt-out of receiving marketing communications from us by contacting us at firstname.lastname@example.org or following the unsubscribe instructions included in our marketing communications; (f) process and deliver contest or sweepstakes entries and rewards; (g) monitor and analyze trends, usage, and activities in connection with the Website and Services and for marketing or advertising purposes; (h) investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities; (i) personalize the Website and Services, including by providing features or advertisements that match your interests and preferences; and (j) for other purposes for which we obtain your consent.
Legal basis for processing (EEA only):
If you are an individual from the European Economic Area (EEA), our legal basis for collecting and using the personal information will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where: (a) we have your consent to do so, (b) where we need the personal information to perform a contract with you (e.g. to deliver the Cx MOMENTS Services you have requested), or (c) where the processing is in our or a third party’s legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms). In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.
Where we rely on your consent to process the personal information, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our (or a third party’s) legitimate interests which are not already described in this Notice, we will make clear to you at the relevant time what those legitimate interests are.
If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided further below in Section 16.
7. Sharing of information collected
Third-party service providers: We share information, including personal information, with our third-party service providers that we use to provide hosting for and maintenance of our Website, application development, backup, storage, payment processing, analytics and other services for us. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.
Compliance with Laws and Law Enforcement Requests; Protection of Our Rights: In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Service Agreement, or as otherwise required by law.
Testimonials: From time to time, we may post testimonials on the Website that may contain personal information. We obtain your consent to post your name along with your testimonial. If you wish to update or delete your testimonial, you can contact us at email@example.com.
With your consent: We may also share personal information with third parties when we have your consent to do so.
8. International transfer of information collected
We primarily store personal information about Visitors and Cx MOMENTS Customers within the European Economic Area (the “EEA”) and the United States. To facilitate our global operations, We may also transfer your personal information to our third party subprocessors as detailed here, who may be located in a different country to you. Such countries may have laws which are different, and potentially not as protective, as the laws of your own country.
If you are visiting our Website from the EEA or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal information to the United States and other jurisdictions in which we operate. By providing your personal information, you consent to any transfer and processing in accordance with this Policy.
If you are visiting our Website from the EEA or other regions with laws governing data collection and use, please note that by providing this personal information, you acknowledge that your personal information may be transferred to the United States and other jurisdictions in which we operate.
9. Communications preferences
We offer those who provide personal contact information a means to choose how we use the information provided. You may manage your receipt of marketing and non- transactional communications by clicking on the “unsubscribe” link located on the bottom of our marketing emails or you may send a request to firstname.lastname@example.org.
10. Personal Information retention period
For personal information that we process on behalf of our Cx MOMENTS Customers, we will retain such personal information in accordance with the terms of our agreement with them, subject to applicable law.
11. Your privacy rights
Upon request we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at email@example.com. Cx MOMENTS Customers to our Services may update or change their Account Information by firstname.lastname@example.org. To make a request to have personal information maintained by us returned to you or removed, please email email@example.com. Requests to access, change, or remove your information will be handled within thirty (30) days.
An individual who seeks access to, or who seeks to correct or, amend inaccuracies in, or delete personal information stored or processed by us on behalf of a Cx MOMENTS Customer should direct his/her query to the Cx MOMENTS Customer (the data controller). Upon receipt of a request from one of our Cx MOMENTS Customers for us to remove the data, we will respond to their request within thirty (30) days. We will retain personal information that we store and process on behalf of our Cx MOMENTS Customers for as long as needed to provide the Services to our Cx MOMENTS Customers. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at firstname.lastname@example.org.
If you are a Cx MOMENTS Customer or otherwise provide us with personal information in connection with your use of our Website or Services, we will delete this information upon your request, provided that, notwithstanding such request, this information may be retained for as long as you maintain an account for our Services, or as needed to provide you with our Services, comply with our legal obligations, resolve disputes and enforce our agreements.
Additional rights for EEA and some other territories:
If you are from certain territories (such as the EEA), you may have the right to exercise additional rights available to you under applicable laws, including:
Right of erasure: In certain circumstances, you may have a broader right to erasure of personal information that we hold about you – for example, if it is no longer necessary in relation to the purposes for which it was originally collected. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
Right to object to processing: You may have the right to request that Cx MOMENTS stop processing your personal information and/or to stop sending you marketing communications.
Right to restrict processing: You may have the right to request that we restrict processing of your personal information in certain circumstances (for example, where you believe that the personal information we hold about you is inaccurate or unlawfully held).
If you would like to exercise such rights, please contact us at the contact details in Section 16 below. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.
You also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. A list of contact details for the EU data protection authorities is available here.
12. Children’s personal information
We do not knowingly collect any personal information from children under the age of 13. If you are under the age of 13, please do not submit any personal information through our Website or Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through the Website or Services without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us through the Website or Services, please contact us at email@example.com, and we will use commercially reasonable efforts to delete that information.
13. Business transactions
We may assign or transfer this Policy, as well as your account and related information and data, including any personal information, to any person or entity that acquires all or substantially all of our business, stock or assets, or with whom we merge.
15. Changes to this policy
If there are any material changes to this Policy, you will be notified by our posting of a prominent notice on the Website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Website or the Services constitutes your agreement to be bound by such changes to this Policy. Your only remedy, if you do not accept the terms of this Policy, is to discontinue use of the Website and the Services.
16. How to contact us
If you have questions regarding this Policy or about Cx MOMENTS’s privacy practices, please contact us by email at firstname.lastname@example.org, or at:
Cx MOMENTS Ltd.
Attn: Privacy Officer
Block 3, Blackrock Business Park,
Blackrock, Co. Dublin