1. INTRODUCTION

Senton group entity, the details of which are indicated in the Senton’s Terms of Service, ("Senton") provides you web-hosting, domain name registration, and related products and service.

Senton seeks to ensure the highest level of data privacy when offering its variety of quality products and services to Senton customers and subscribers ("Subscribers") (collectively, “You”, or "Users").

At Senton, the privacy and security of our Users is of paramount importance. Senton is committed to protecting the data you share with us. When this Policy mentions "Senton", "we," "us", or "our", it refers to Senton that is responsible for protection of your personal information in line with this Privacy Policy ("Data Controller").

This Privacy Policy ("Policy") explains how Senton processes information that can be used to directly or indirectly identify an individual ("Personal Data") collected on our Site, our services (“Service”), forums and our mobile applications ("Platform").

All personal data are processed in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

For any questions regarding this Policy or any requests regarding the processing of personal data, please contact us at gdpr@Senton.com.

2. GENERAL PRINCIPLES: CONFIDENTIALITY

Senton shall process all Personal Data adhering to the general data processing principles:

• lawfully, fairly and in a transparent manner in relation to the data subject (lawfulness, fairness, and transparency)
• collect and process Personal Data only for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (purpose limitation)
• ensure that Personal Data is adequate, relevant and limited to what is necessary for relation to the purposes for which they are processed (data minimization)
• ensure that Personal Data is accurate and, where necessary, kept up to date (accuracy)
• ensure that Personal Data is kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (storage limitation)
• process Personal Data in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures (integrity and confidentiality).

All and any information stored on Senton's Platform is treated as strictly confidential. All information is stored securely and is accessed by qualified and authorized personnel only.

3. INFORMATION WE COLLECT

3.1. Information You provide to us.

Information that is necessary for the use of the Senton Platform We ask for and collect the following personal information about you when you use the Senton Platform. This information is necessary for the adequate performance of the contractual arrangement which is in place between you and us and to allow us to comply with our legal obligations. Failing to provide any of this data or decision to delete or object to the processing of any of such data may result in de-activation of your Senton Account.

• Account Signup Information. When you sign up to Senton, we require you to provide minimum information - email address and password. In some particular cases we ask you to provide more information - such as your first and last name, identity verification, contact details. Such information is required when you are applying for a registration of domain name and indicated as the WHOIS information.
• Login information. We collect Login scope and Email scope from Google, please see https://developers.google.com/identity/protocols/oauth2/scopes?hl=en and email from Facebook.
• Identity Verification. To comply with the rules set forth by the Internet Corporation for Assigned Names and Numbers ("ICANN") before the registration of the new domain name, Senton may collect identity verification information (such as images of your passport, national ID card, valid driving license or other documents as required or permitted by applicable laws).
• Payment Information. To order and use features of the Senton Platform (such as web-hosting, domain name registration), we may require you to provide certain financial information in order to facilitate the processing of payments. We use 3rd party (payment processor) services, so we do not collect and store credit card information (we receive information about the payment status and store only last 4 credit card digits).
• Communications, Chats, Messaging. When you communicate with Senton (including by using general inquiries windows, chat windows or chatbots), we collect information about your communication and any information you choose to provide or disclose. In order to respond to your request, we may also access information provided in your Senton Account, purchase history, etc. 
• Job applicants' information. We also collect information that you provided to us by applying to any of the open career positions published at https://www.Senton.com/career, by e-mail or otherwise. For more details see Section 5 below.
• Visitors and users of our User’s websites or services. We may also collect information pertaining to visitors and users of our User’s websites or services (“Users-of-Users”), solely for and on our Users’ behalf.

You may also choose to provide us information when you fill in a form, conduct a search, update or add information to your Senton Account, respond to surveys, post to community forums, participate in promotions, or use other features of the Senton Platform. We advise against posting any information you don’t wish to make public on the Senton Platform. If you upload any content to your account or post it on your Website and provide it in any other way as part of the use of any Service, you do so at your own risk. Senton processes information you provide to us on the legal basis of:

• Your consent, expressed when voluntarily submitting and filling your Personal Data details in sign-up forms, by e-mail, request or inquiries window, etc.; and
• Conclusion and performance of contractual arrangements and obligations between Senton and the User;
• Pursuance of legitimate interests of Senton, as Data Controller and manager of Senton platform;
• Compliance with a legal obligation to which Senton is subject, including, but not limited to, ICANN rules: https://www.icann.org/resources/pages/approved-with-specs-2013-09-17-en#whois.

Disclaimer

Please always take care and observe at least the following minimum requirements for the protection of your personal information:

• please omit using your name, address, telephone number, e-mail, personal identification number, date of birth, bank Account number, card number, other special (sensitive) data, etc. in the subject of the request or file name;
• please omit using your personal code, payment card number, and other financial information and details, health, family member details, or other specific (sensitive) data, in the texts of requests, e-mails or similar communication to us, and
• please make sure that the remaining personal data is only indicated to the extent necessary for the purposes for which the letter, request or inquiry is sent.

Right to delete your data

You may at any time access and edit, update or delete your contact details by logging into your Senton's platform Account.

Please note that you will only be able to delete your email during de-activation of your Senton Account. To deactivate your Account, please send your request to gdpr@Senton.com, and you will be provided with further guidance.

Information related to the calls or meetings you participate

In cases where you call Senton or schedule an appointment for a meeting, such conversations will be recorded by Senton International Ltd. for quality management purposes. As a result, we will be able to maintain and improve the quality of Senton services based on Senton quality standards and policies. For this purpose we will process the following data: email address, date and time of conversation, its duration, audio and/or video recording, any other personal data provided by you voluntarily during the conversation. Also, provided email address and / or phone No. may be used for the purposes of allowing you to reach us or contacting you regarding your matter.

In such cases processing is necessary for the purpose of the legitimate interests pursued by Senton (under Article 6(1)( f) of GDPR) or is based on your consent, when you consent to video recording by turning video on, or provide certain data voluntary (under Article 6(1)(a) of GDPR).

The recordings will be kept up to for 30 days and deleted thereafter as soon as technically feasible.

3.2. Information We Collect when You use the Platform

When you use the Senton Platform or contact us directly by any communication channel, we may collect information, including personal information, about the services you use and how you use them.

This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities and security of the Senton Platform.

Automatic collection of data

• Log data and Device information. We automatically collect log data and device information when you access and use the Senton Platform, even if you have not created an Senton Account or logged in. That information includes, among other things: Internet protocol (IP) addresses, browser information, including its type, Internet service provider (ISP), referring/exit pages, device properties, including its operating system, date/time stamp and/or clickstream data.
• Tracking technologies and Cookies. We use cookies, beacons, tags, scripts and other similar technologies, such as CI codes (click tracking), ISC (source tracking), and ITC (item tracking codes). We also automatically collect information about device's operating system, phone model, device ID and customer number. For more detail information on the use of these technologies, see our Cookies Policy.
• Usage information. We use a tool called "Google Analytics" to collect information about your interactions with the Senton Platform (what pages you visit, such as the pages or content you view, your searches for Listings, bookings you have made, and other actions on the Senton Platform. In consequence, Google, Inc. plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this Site). For more information please visit Google.
• Geo-location data. We collect information about your approximate location as determined by data such as your IP address to offer you an improved user experience and comply with applicable legal requirements, such as taxes, pricing, etc. Such data may be collected only when you access Senton platform using your device.

Senton processes this information on the legal basis of:

• Your consent;
• Conclusion and performance of contractual arrangements and obligations between Senton and the User;
• Pursuance of legitimate interests of Senton, as Data Controller and manager of Senton platform.