This Privacy Policy explains how we collect, use, process, and disclose your information across the Sensee’s Services.

Last updated on November 29, 2018.

If you see an undefined term in this Privacy Policy, it has the same definition as outlined in our Terms of Service.

When this policy mentions “Sensee”, “we”, “us” or “our”  it refers to Sensee AS, which is responsible for your information under this Privacy Policy (the “Data Controller”).

1. Information We Collect: There are three general categories of information we collect.
   • Information you provide. We collect information you share with Sensee when you use the Sensee Services.
     
     • Account Information. When you sign up for an Sensee Services, we require certain information such as your name, email address, and and other information related to you and your use of the Sensee Services.
     • Other Authentication-Related Information. To help create and maintain a trusted environment, we may collect identification (like a photo of your government-issued ID) or other authentication information.
     • Payment Information. We collect your financial information (like your bank account or credit card information) when you use the subscribe to Sensee’s Services
     • Communications with Sensee and/or other Authenticated Users. When you communicate with Sensee or use the Sensee Services to communicate with other Authenticated Users, we collect information about your communication and any information you choose to provide.
     • Other Information. You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your Sensee Account, respond to surveys, post to Sensee forums or help desks, participate in promotions, or use other features of the Sensee Services.
   • Information we collect automatically. When you use the Sensee Services, we collect information about how you use them.
     • Usage Information. We collect information about your interactions with the Sensee’s Services, such as the pages or other content you view and other actions as allowed by the Services.
     • Location Information. When you use certain features of the Sense Services, we may collect different types of information about your general location (e.g. IP address, postal code) or more specific location information (e.g. precise location from your mobile GPS). Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu.
     • Log Data. We automatically collect log data related to your use of Sensee’s Services, such as sensor and gateway readings, IP addresses, access times, hardware and software information, device information, device event information (e.g., crashes, browser type), and the page you’ve viewed or engaged with before or after using Sensee’s Services.
     • Cookies and Similar Technologies. We use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers. We may also allow our business partners to use these tracking technologies on the Sensee Web Services, or engage others to track your behavior on our behalf. While you may disable the usage of cookies through your browser settings, we do not change our practices in response to a “Do Not Track” signal in the HTTP header from your browser or mobile application. For more information on our use of these technologies, see our Cookie Policy.
   • Information collected from third parties. We may collect information that others provide about you when they use the Sensee’s Services, or obtain information from other sources and combine that with information we collect through Sensee’s Services. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Sensee Services through partnerships, or about your experiences and interactions from our partnered third parties.
2. How We Use Information We Collect.
   We use, store, and process information about you to provide, improve, and develop the Sensee Services, and to create and maintain a trusted environment.
   1. Provide, improve, and develop Sensee Services.
      
      1. Enable you to access and use the Sensee Services.
      2. Operate, protect, improve and optimize the Sensee Services, such as by performing analytics and conducting research.
      3. Personalize or otherwise customize your experience.
      4. Enable you to purchase paid subscriptions to the Sensee Services.
      5. Provide customer service.
      6. Send you service or support messages, such as updates, security alerts, and account notifications.
   2. Create and maintain a trusted environment.
      
      1. Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
      2. Conduct investigations and risk assessments.
      3. Verify or authenticate information or identifications provided by you
      4. Conduct checks against databases and other information sources.
      5. Comply with our legal obligations.
      6. Resolve any disputes with any of our users and enforce our agreements with third parties.
      7. Enforce our Terms of Service, and other policies.
   3. Provide, personalize, measure, and improve our advertising and marketing.
      
      1. Send promotional messages, marketing, advertising, and other information that may be of interest to you based on your communication preferences.
      2. Personalize, measure, and improve advertising.
      3. Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Sensee or its third party business partners.
3. Sharing & Disclosure
   
   1. With your consent. We may share your information at your direction or as described at the time of sharing.
   2. Service providers. We use a variety of third party service providers to help us provide services related to the Sensee Services. Service providers may be located inside or outside of the European Economic Area (“EEA”). For example, service providers may help us: (i) verify or authenticate your identification, (ii) check information against public databases, (iii) assist us with background checks, fraud prevention, and risk assessment, (iv) provide customer service, advertising, or payments services or, (v) provide underlying infrastructure as required for the operation of the Sensee Services. These providers have limited access to your information to perform these tasks on our behalf, and are contractually obligated to use it consistent with this Privacy Policy.
   3. Payments to Sensee. Sensee may share your personal information to:
      (i) take payment from you for your use of the Services and
      (ii) facilitate your use of the Sensee Services.
   4. Safety and compliance with law. Sensee may disclose your information to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required to do so by law or if such disclosure is reasonably necessary:
      (i) to comply with legal process and to respond to claims asserted against Sensee,
      (ii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability,
      (iii) to enforce and administer our Terms of Service or other agreements with our account holders,
      (iv) for fraud investigation and prevention, risk assessment, customer support, product development and debugging purposes, or
      (v) to protect the rights, property or personal safety of Sensee, its employees, its other account holders, or members of the public.
       
      We will attempt to notify you about these requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Sensee’s Services, its other account holders and/or and the Sensee technical platform (collectively, “Risk Scenarios”). In instances where we comply with legal requests without notice for these reasons, we will attempt to notify you about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no Risk Scenarios apply.
   5. Corporate affiliates. To help us provide the Sensee Services, Sensee may share your information within its corporate family of companies (both financial and non-financial entities) that are related by common ownership or control. These related entities are covered under this Privacy Policy.
   6. Assignment of rights. If Sensee undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then Sensee may sell, transfer or share some or all of its assets, including your information. In this event, Sensee will notify you before your personal information is transferred and becomes subject to a different privacy policy.
   7. Aggregated data. Sensee may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and non-personally identifiable information for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
4. Analyzing Your Use.
   Sensee may review, scan, or analyze your use of the Sensee Services for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, and customer support purposes. In some cases, Sensee may also scan, review, or analyze your use of the Services to debug, improve, and expand product offerings. Sensee uses automated methods where reasonably possible. However, occasionally Sensee may need to manually review some use of the Services, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools.
5. Your Choices
   
   1. Access and update. You may review, update, or delete the information in your Sensee Account by logging into your Account and reviewing your Account settings and profile.
   2. EEA and Japan Residents: Review and Update Your Information.
      If you reside in the EU or Japan, you may request in writing copies of your personal information held by us. We will provide you with a copy of the personal information held by us as soon as practicable, and in any event not more than 40 days after receiving a valid request in writing. There may be a charge to access your personal data (which will not exceed €6.35 in Ireland and £10 in the United Kingdom, and will not be applicable in Japan). We may request proof of identification to verify your access request.If your personal information that we hold is inaccurate, let us know and we will update the relevant information. You may also request the erasure of your personal information in accordance with the relevant data protection legislation. We will notify you within 40 days of your valid request about the relevant action taken.Requests should be addressed to:

      Sensee AS
      Data Protection Compliance
      Alfheim 26
      N-1384 Asker, Norway

      Sensee Inc
      Data Protection Compliance
      PO Box 1161
      Madison, NJ  USA

      We may request proof of identification to verify your request

   3. EEA Residents: Access and challenge information provided by third parties. You are entitled to see and challenge information third parties provide to us as part of our fraud detection, prevention and risk assessment efforts if all of the following factors apply: (i) we use third parties to carry out automated checks or risk assessments, (ii) we make a decision which has legal consequences for you or which significantly affects you, and (iii) such decision is based solely on such automated checks or risk assessments.Requests should be addressed to:

      Sensee AS
      Data Protection Compliance
      Alfheim 26
      N-1384 Asker, Norway

      Sensee Inc
      Data Protection Compliance
      PO Box 1161
      Madison, NJ  USA
      

      We may request proof of identification to verify your request

6. Global Operations. As described in this Privacy Policy, we may sometimes share your information within our family of companies or with third parties. When you use the Sensee Services, you authorize us to transfer, store, and process your information to Norway, the United States and possibly other countries. Laws in these countries may differ from the laws applicable to the place where you live. For example, information collected within the EEA may be transferred, stored, and processed outside of the EEA for the purposes described in this Privacy Policy. By using the Sensee Services, you consent to transferring your data to these countries.
7. Data Security. Sensee is continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. However, the Internet is not a 100% secure environment so we can’t guarantee the security of the transmission or storage of your information.
8. Changes to this Privacy Policy. Sensee reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Sensee Services and update the “Last Updated” date at the top of this Privacy Policy. We will also provide you with notice of the modification by email at least thirty (30) days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your Sensee Account. If you do not cancel your Sensee Account before the date the revised Privacy Policy becomes effective, your continued access or use of the Sensee Services will constitute acceptance of the revised Privacy Policy.
9. Contact. If you have any questions or complaints about this Privacy Policy or Sensee’s information handling practices, you may contact us at:

   Sensee AS
   Data Protection Compliance
   Alfheim 26
   N-1384 Asker, Norway

   Sensee Inc
   Data Protection Compliance
   PO Box 1161
   Madison, NJ  USA
   

   We may request proof of identification to verify your request
   

You may also email us at dataprotection@sensee.io