# Privacy Policy

**Updated**: 5th May 2025

## 1. Introduction
We are committed to protecting your privacy and ensuring the security of your personal data. This policy is designed to provide you with detailed information about how we collect, use, process, and protect your personal information when you use our web app and mobile application (collectively referred to as our "Service").

## 2. Definitions
To help you better understand this policy, we've defined some key terms:

- **Personal data**: Any information relating to an identified or identifiable natural person ('data subject'). This includes, but is not limited to, names, identification numbers, location data, online identifiers, or factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.

- **Data Controller**: The entity that determines the purposes and means of processing personal data. In this context, Sensay acts as the Data Controller for the personal data you provide to us.

- **Data Processor**: A person or entity that processes personal data on behalf of the Data Controller.

- **Data Subject**: Any living individual whose personal data is being processed.

- **Processing**: Any operation performed on personal data, such as collection, recording, organization, structuring, storage, adaptation, or alteration.

## 3. Principles for Processing Personal Data
At Sensay, we adhere to the following principles when processing your personal data:

### 3.1 Lawfulness, Fairness, and Transparency 
We process personal data lawfully, fairly, and in a transparent manner.

### 3.2 Purpose Limitation 
We collect personal data for specified, explicit, and legitimate purposes.

### 3.3 Data Minimization 
We ensure that the personal data we collect is adequate, relevant, and limited to what is necessary.

### 3.4 Accuracy
We take reasonable steps to ensure that personal data is accurate and up to date.

### 3.5 Storage Limitation 
We keep personal data in a form that permits identification of data subjects for no longer than necessary.

### 3.6 Integrity and Confidentiality 
We process personal data in a manner that ensures appropriate security.

### 3.7 Accountability
We are responsible for and can demonstrate compliance with the above principles.

## 4. Data We Collect and Process
Sensay collects and processes various types of personal data:

### 4.1 Personal Identifiers
- Email address
- Full name
- Phone number
- User account credentials
- Postal address (if provided)
- Date of birth (if provided)
- Profile picture (if uploaded)

### 4.2 Technical Data
- IP address
- Device type and model
- Operating system and version
- Browser type and version
- Mobile device identifiers

### 4.3 Usage Data
- Pages or features accessed
- Time spent on different parts of the Service
- Interaction patterns

### 4.4 Communication Data
- Email correspondence
- Chat logs
- Feedback provided

## 5. How We Use Your Data
Sensay uses your personal data for various purposes:

### 5.1 Providing and Improving Our Service
- Creating and managing your account.
- Personalizing your experience.

### 5.2 Communicating with You
- Sending service-related notifications and updates.
- Providing customer support.

### 5.3 Ensuring Security and Compliance
- Detecting and preventing fraud, spam, abuse, and security incidents.

### 5.4 Legal and Regulatory Compliance
- Responding to legal requests and subpoenas.

## 6. Legal Bases for Collection, Use and Disclosure of Personal Data
We collect, use and disclose your Personal Data only where permitted under the applicable data protection laws.

### 6.1 Consent
You have given clear consent for a specific purpose.

### 6.2 Legitimate Interests Exception
We may rely on the statutory "legitimate interests" exception where the benefits to you or us outweigh adverse effects.

## 7. Disclosure of Your Data
Sensay may disclose your personal data to various parties under specific circumstances.

### 7.1 Subsidiaries and Affiliates
- We may share your data with our subsidiaries for purposes consistent with this privacy policy.

### 7.2 Service Providers and Contractors
- We engage third-party service providers to perform certain business functions on our behalf.

## 8. Data Security
We implement reasonable administrative, physical and technical safeguards to prevent unauthorized access.

### 8.1 Data Encryption
- All customer data stored is encrypted using Advanced Encryption Standard (AES).

### 8.2 Access Controls
- Strict access controls and authentication measures are in place.

## 9. Data Management and Privacy Layers
We have implemented a multi-layered approach to data management and privacy:

### 9.1 Public Replicas
- Digital replicas designed for broad interaction and sharing.

### 9.2 Private Replicas
- Restricted to the user and specific whitelisted accounts.

## 10. User Levels of Control
At Sensay, we believe in empowering our users with comprehensive control over their personal data:

### 10.1 Account Settings
- Modify your profile information at any time.

### 10.2 Privacy Settings
- Control the visibility of your profile and content.

## 11. Company Levels of Control
As a data controller, Sensay implements various organizational and technical measures to ensure the proper handling and protection of user data.

### 11.1 Data Processing
- Consent-Based Processing.

### 11.2 Data Protection
- Encryption Protocols.

## 12. End-to-End Encryption and Security
At Sensay, we employ advanced encryption technologies to ensure data protection.

### 12.1 Data Encryption
- We use end-to-end encryption to protect data from the moment collected until it reaches its intended destination.

## 13. Data Retention
We retain personal data only as long as necessary to fulfill the purpose for which it was collected.

### 13.1 General Retention Periods
- Account Information: Retained for the duration of your account's active status.

## 14. Cookie Policy
Cookies are small text files that are placed on your device when you visit our website or use our services.

### 14.1 Types of Cookies We Use
- **Essential Cookies**: Necessary for the Service to function.
- **Performance Cookies**: Help us understand how you use our Service by collecting and reporting information.

## 15. Ethical Considerations of Digital Cloning
We recognize that the creation and use of digital replicas raises important ethical considerations:

### 15.1 Informed Consent
We obtain explicit, informed consent from individuals before creating their digital replicas.

### 15.2 Transparency 
We are open about the capabilities and limitations of our digital replica technology.

## 16. Your Rights Under GDPR
As a data subject under the GDPR, you have several rights concerning your personal data:

### 16.1 Right to be Informed
You have the right to be informed about the collection and use of your personal data.

### 16.2 Right of Access
You have the right to request a copy of your personal data that we hold.

## 17. International Data Transfers
Sensay operates globally, meaning your personal data may be transferred to countries other than your residence.

### 17.1 Comparable Protection
The recipient country must provide a standard of protection comparable to the PDPA.

## 18. Changes to This Policy
We may update this Privacy Policy from time to time.

### 18.1 Notification of Changes
For material changes, we will provide notification via email or prominent notices on our website.

## 19. Contact Details
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

### 19.1 Data Protection Officer
- Name: Marco Bettiolo
- Email: gdpr@sensay.io