1. Introduction

This Privacy Notice applies to the website located at www.sensei.tech (“Website”), which is owned and operated by SENSEIDATA, S.A., a company incorporated under Portuguese laws, with registered office at Avenida do Empresário, 1, 6000-767 Castelo Branco, Portugal, registered with the competent authorities under number / VAT 514507250 (“Sensei”); and aims to inform Website Users on how Sensei processes User’s Personal Data collected and/or provided to Sensei through the Website.

‍
Users must read this Privacy Notice carefully and freely decide whether to provide Sensei with their Personal Data before using the Website. User guarantees that he/she is of legal age and that the data provided is true, accurate, complete and up-to-date, being responsible for any non-compliance. If the Personal Data provided belongs to a third party, User warrants that has informed the third party of the conditions set out in this document and that has obtained authorisation to provide data to Sensei, for the indicated purposes.

‍

2. Privacy Overview

Sensei is committed to respecting the privacy of the Website Users, protecting and securing the information Users share with us, especially when it relates to their Personal Data, including from individual representatives or contacts of an organization. Even in a business context, we recognize the importance of data that can identify, contact or locate specific individuals (“Personal Data”).

‍

3. Data controller

The data controller of the Personal Data collected through the Website is Sensei (as identified above).

‍

4. Contacts

Users may contact Sensei for any question regarding the processing of their Personal Data referred to in this Privacy Notice, as well as for the exercise of their rights mentioned herein, by means of a written request addressed to privacy@sensei.tech .

‍

5. Personal Data collected and purposes

In accordance with this Privacy Notice and information as further displayed on the Website, we collect information from you when you voluntarily fill out an online form or enter information on our Website. Different types of Personal Data from Users are collected, according to the purposes:

• Subscription to newsletters: name and e-mail, from Users who want to register on the Website to receive news and other communications from Sensei;
• Process surveys or marketing communication: name and e-mail, from Users who register on the Website to participate in surveys or receive marketing communication from Sensei;
• Follow up on requests for more information about products and services, or to respond to User’s request for a product demonstration: name and e-mail;
• Recruitment: name, e-mail and curriculum data for Users who want to apply for work positions at Sensei: name, email, CV.
  ‍

In addition to the purposes described above, Sensei may also process Personal Data of Users for statistical purposes, limited, however, to the minimum necessary for such purposes and using anonymization.

‍

Legal basis for the processing: processing of Personal Data for the transmission of communications is based on the User’s specific consent, being the legal basis for the processing of Personal Data. Users may withdraw their consent at any time and delete their registration by the means indicated above, without affecting the lawfulness of the previous processing. Processing of Personal Data for the purpose of selection and recruitment is necessary to proceed at the request of the data subjects prior to entering into a contract, as well as to manage recruitment proceedings.

‍

6. Data Sharing and Transfer

Sensei does not sell, share or transfer User’s Personal Data to third parties, except as strictly necessary to (i) process requests, as necessary to facilitate the demonstration of Sensei’s products and services as provided through the Website; (ii) contractors for the provision of services that comprise one or more of the purposes mentioned above, as well as the maintenance of the Website; (iii) or as required by law or court orders. Any third parties with whom Sensei shares information are contractually bound to maintain the confidentiality and security of that information and will process Personal Data only under documented instructions from Sensei.

‍

7. Data Security

Sensei will endeavor its best efforts to protect the confidentiality of Users' Personal Data and uses appropriate technical and organizational measures to protect User’s Personal Data from unauthorized access, use or disclosure. User’s Personal Data is stored behind secure networks. It is only accessible to a limited number of people who have special access rights to these systems and are required to keep the information confidential. Sensei uses a variety of security measures when a User enters, submits or accesses their Personal Data and other information to ensure the security of User’s data.

‍
However, please bear in mind that due to the design and characteristics of the Internet, as well as constant changes in technology and other factors outside our control, we cannot guarantee that communications between Users and the Website will not be exempt from unauthorized access or tampering by third parties. Also, it is User’s responsibility to guarantee and ensure that the device used to access the Website is adequately protected against harmful software, computer viruses and worms. We do not accept any responsibility for the disclosure of Personal Data and other information caused by errors in transmission or unauthorized or unlawful acts of third parties. For further information, please refer to our Terms & Conditions [insert link] available at our Website.

‍

8. Personal Data Retention

Sensei will retain and store Users’ personal data for (a) the strict period of time necessary to carry out the purposes for which they were collected: (i) subscription to newsletters, process surveys, marketing communication, follow up on requests for a product demonstration: two (2) years after the last contact; (ii) recruitment: one (1) year after sending the application or after the end of candidate selection and recruitment procedure; OR (b) until User exercises the right to have the Personal Data erased/deleted; OR (c) as required by applicable laws and regulations.

‍
9. Users’ Rights

Users, as Personal Data subjects, have the following rights:

• Right of access: Users have the right to request information regarding the processing of their Personal Data and request a copy of their Personal Data subject to processing;
• Right of rectification: in case of incomplete or inaccurate data, Users have the right to request their rectification;
• Right to erasure: Users have the right to request the erasure of their Personal Data subject to processing. However, this right may be limited in certain situations, for example, when the processing of data is required to comply with legal obligations to which Sensei is subject to or when such processing is necessary for the establishment, exercise or defense of legal claims.
• Right to restriction: Users have the right to request restriction the processing of their Personal Data or to suspend processing activities, in cases where: (i) Users contest the accuracy of their Personal Data, for a period of time that allows Sensei to verify its accuracy; (ii) the processing is no longer necessary but the data is required by the Users for the establishment, exercise or defense of legal claims; (iii) Users have objected to processing, until verified whether the legitimate interests of Sensei or third parties override those of the Users.
• Right to portability: Users have the right to receive their Personal Data, provided through a contract or based on consent, in a structured format, in common use and machine-readable format. They also have the right to have their data transmitted to another controller, whenever technically possible;
• Right to object: Users have the right to object to the processing of their Personal Data in cases where the data is processed based on the legitimate interests of Sensei, except in cases in which it presents compelling and legitimate reasons that prevail over the rights of the data subjects;
• Automated individual decision-making, including profiling: Users have the right not to be subject to any decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.

‍
Users also have the right to lodge a complaint to the Portuguese Data Protection Authority («Comissão Nacional de Proteção de Dados – CNPD») if they consider that their rights over their Personal Data have been infringed.

‍
As part of a request to Sensei regarding any of the rights identified above, Users may be asked to prove their identity in order to ensure that Personal Data is shared only with the respective data subject.

‍

The exercise of rights is free, except in cases of manifestly unfounded or excessive requests, in which case a reasonable fee may be charged taking into account the costs.

‍
To exercise any of these rights or if you have any questions about this Privacy Notice, please contact us at privacy@sensei.tech.

‍
10. Cookies

Our website does not use cookies.

‍
11. Applicable law and Forum

This Privacy Notice is governed by Portuguese law. Any disputes regarding the use or interpretation of these T&Cs shall be settled by the competent courts of Lisbon.

‍
12. Updates and changes

We may change or update, in whole or in part, from time to time, this Privacy Notice. Any changes or updates to this Privacy Notice will take effect as soon as they are published in the correspondent section of the Website. Users are advised to regularly check the Privacy Notice sections to confirm the latest versions thereof.

‍

‍

_{Last update 15/12/2023}