1. Introduction and Scope
Sentens ("we", "our", or "us") respects your privacy and is committed to protecting your personal data. This comprehensive Privacy Policy details how we collect, use, process, and disclose your information when you access or use our algorithmic trading platform, website, applications, and associated services (collectively, the "Services").
This policy applies to all users of our Services, including but not limited to registered clients, website visitors, and institutional partners globally. By accessing or using our Services, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy.
Data Controller Information
Depending on your jurisdiction, the primary data controller for your personal information is FIERES LIMITED SP ZOO (for EU/EEA users) or Sentens US LLC (for US users). For any privacy-related inquiries, please contact our Data Protection Officer (DPO) at [email protected].
2. Information We Collect
We collect various categories of information to provide, secure, and improve our Services. This information is collected directly from you, automatically through your use of the Services, and sometimes from third-party sources.
2.1 Information You Provide Directly
- Account and Identity Information: Name, date of birth, nationality, residential address, government-issued identification numbers (e.g., SSN, Passport Number, National ID), and copies of identity documents.
- Contact Information: Email address, phone number, and primary language preferences.
- Financial Information: Bank account details, source of funds declarations, trading experience, risk tolerance, and net worth attestations (as required for institutional or accredited investor status).
- Communication Data: Content of your emails, support tickets, and chat communications with our customer service team.
2.2 Information Collected Automatically
When you interact with our platform, we automatically record information about your device and usage:
- Device Identifiers: IP address, MAC address, browser type and version, operating system, and hardware model.
- Usage Data: Log information, access times, pages viewed, API calls made, trading algorithms deployed, and execution logs.
- Location Data: Geo-location derived from your IP address to ensure compliance with jurisdictional restrictions.
- Cookies and Tracking Technologies: Session cookies, persistent cookies, and web beacons to analyze trends and administer the platform.
3. How We Use Your Information
We use your personal information for several critical business and regulatory purposes. Our primary goal is to provide a secure, efficient, and personalized trading experience.
- Service Provision: To create and manage your account, process deposits and withdrawals, execute algorithmic trading strategies, and provide customer support.
- Regulatory Compliance (AML/KYC): To verify your identity, perform risk assessments, monitor transactions for suspicious activities, and comply with Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) laws globally.
- Security and Fraud Prevention: To protect our platform against cyber threats, unauthorized access, fraud, and other illegal activities. This includes advanced biometric verification and behavioral analytics.
- Service Improvement: To analyze usage patterns, optimize our trading engine performance, and develop new features.
- Communication: To send you administrative notifications, technical alerts, security updates, and, where permitted by law, marketing materials relevant to your interests.
4. Information Sharing and Disclosure
Sentens strictly protects your data. We do not sell your personal information to third parties. However, we may share your data under specific circumstances:
- Service Providers: We share information with trusted third parties who provide essential services on our behalf, such as identity verification (e.g., Onfido, SumSub), payment processing, cloud hosting (e.g., AWS), and cybersecurity monitoring.
- Legal and Regulatory Authorities: We will disclose your information to law enforcement, government agencies, or courts when compelled by subpoena, court order, or other legal procedure, or when we believe in good faith that disclosure is necessary to prevent physical harm or financial loss.
- Corporate Restructuring: In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred as part of the business assets.
5. Data Retention and Security
Retention: We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including satisfying any legal, accounting, or reporting requirements. Due to stringent AML regulations, we are typically required to retain identity verification data and transaction records for a minimum of five (5) to seven (7) years after your account is closed.
Security: We implement state-of-the-art technical and organizational measures to protect your data. This includes end-to-end encryption for data in transit (TLS 1.3), AES-256 encryption for data at rest, strict access controls based on the principle of least privilege, regular penetration testing, and continuous security monitoring.
User Responsibility
While we strive to protect your data, no transmission over the Internet is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and enabling Two-Factor Authentication (2FA).
6. Your Privacy Rights
Depending on your jurisdiction (such as under the GDPR in Europe or the CCPA in California), you may have specific rights regarding your personal data:
- Right to Access: You can request a copy of the personal data we hold about you.
- Right to Rectification: You can request that we correct inaccurate or incomplete data.
- Right to Erasure (Right to be Forgotten): You can request the deletion of your data, subject to our overriding legal retention obligations.
- Right to Restrict Processing: You can ask us to suspend the processing of your data in certain scenarios.
- Right to Data Portability: You can request the transfer of your data to another party in a structured, machine-readable format.
To exercise these rights, please submit a request through your account dashboard or email [email protected].