Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how Sentriom ("we," "us," or "our") collects, uses, and shares information about you when you access or use our cryptocurrency savings platform, website, mobile applications, and related services (collectively, the "Services").

By using our Services, you consent to the collection, use, and sharing of your information as described in this Policy. If you do not agree with this Policy, please do not use our Services.

2. Information We Collect

2.1 Information You Provide to Us

We collect information that you voluntarily provide when you:

Account Registration Information:

• Personal Identifiers: Full name, email address, phone number, date of birth
• Authentication Data: One-Time Passwords (OTP), security questions and answers
• Profile Information: Username, profile picture, preferences

Identity Verification Information:

• Government-Issued ID: Passport, driver's license, national ID card
• Proof of Address: Utility bills, bank statements, rental agreements
• Biometric Data: Facial recognition data for identity verification
• Tax Information: Tax identification numbers, W-9 forms (if applicable)

Financial Information:

• Cryptocurrency Wallets: Wallet addresses, transaction history
• Bank Account Details: Account numbers, routing numbers, IBAN
• Payment Information: Credit/debit card details (processed by third-party payment processors)
• Transaction Data: Deposit amounts, withdrawal requests, savings plan selections

Communications:

• Support Inquiries: Messages, emails, chat logs with customer support
• Feedback: Surveys, reviews, testimonials
• Marketing Preferences: Newsletter subscriptions, communication preferences

2.2 Information Collected Automatically

When you access or use our Services, we automatically collect certain information:

Device Information:

• Device Identifiers: IP address, device ID, MAC address
• Device Characteristics: Operating system, browser type and version, device model
• Mobile Information: Mobile carrier, time zone, screen resolution

Usage Information:

• Activity Data: Pages visited, features used, time spent on pages
• Click Data: Links clicked, buttons pressed, navigation paths
• Session Data: Login times, session duration, logout times
• Search Queries: Search terms entered within the platform

Location Information:

• IP-Based Location: Country, region, city derived from IP address
• GPS Location: Precise location data (only with your explicit consent)

Cookies and Tracking Technologies:

• Cookies: Small data files stored on your device
• Web Beacons: Electronic images that track page views
• Local Storage: Data stored in your browser's local storage
• Analytics Tools: Google Analytics, Mixpanel, or similar services

2.3 Information from Third Parties

We may receive information about you from third-party sources:

• Identity Verification Services: Third-party verification providers
• Payment Processors: Payment service providers
• Blockchain Networks: Public blockchain transaction data
• Social Media: Information from social media platforms (if you connect your accounts)
• Marketing Partners: Demographic and interest data from marketing partners
• Public Databases: Publicly available information from government databases

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 Provide and Improve Services

• Create and manage your account
• Process deposits, withdrawals, and transactions
• Calculate and distribute APY returns
• Provide customer support and respond to inquiries
• Improve and optimize our Services
• Develop new features and functionality
• Personalize your experience

3.2 Security and Fraud Prevention

• Verify your identity and prevent fraud
• Detect and prevent unauthorized access
• Monitor for suspicious or illegal activity
• Protect against security threats
• Investigate and resolve disputes
• Enforce our Terms of Service

3.3 Compliance and Legal Obligations

• Comply with identity verification and anti-money laundering regulations
• Meet tax reporting requirements
• Respond to legal requests and court orders
• Comply with sanctions and export control laws
• Maintain records as required by law
• Report suspicious activities to authorities

3.4 Communications

• Send transactional emails (confirmations, notifications)
• Provide customer support communications
• Send marketing and promotional materials (with your consent)
• Notify you of changes to our Services or policies
• Conduct surveys and request feedback

3.5 Analytics and Research

• Analyze usage patterns and trends
• Conduct market research
• Generate statistical and aggregated data
• Improve our algorithms and models
• Benchmark performance metrics

4. How We Share Your Information

We may share your information in the following circumstances:

4.1 Service Providers

We share information with third-party service providers who perform services on our behalf:

• Payment Processors: Third-party payment service providers
• Identity Verification: Identity verification services
• Cloud Hosting: Railway, AWS, or other cloud infrastructure providers
• Email Services: SendGrid, Mailchimp, or similar email providers
• Analytics Providers: Google Analytics, Mixpanel, or similar services
• Customer Support: Zendesk, Intercom, or similar support platforms
• Security Services: Fraud detection and prevention services

4.2 Legal and Regulatory Authorities

We may disclose your information to:

• Law enforcement agencies
• Regulatory authorities
• Tax authorities
• Courts and legal tribunals
• Government agencies

When required by law, court order, subpoena, or to comply with legal obligations.

4.3 Business Transfers

If we are involved in a merger, acquisition, sale of assets, bankruptcy, or other business transaction, your information may be transferred as part of that transaction.

4.4 With Your Consent

We may share your information with third parties when you explicitly consent to such sharing.

4.5 Aggregated and De-Identified Data

We may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you with:

• Business partners
• Researchers
• Industry analysts
• The public

5. Data Retention

We retain your information for as long as necessary to:

• Provide our Services to you
• Comply with legal and regulatory obligations
• Resolve disputes and enforce agreements
• Prevent fraud and abuse
• Maintain business records

5.1 Retention Periods

Data Type	Retention Period
Account Information	Duration of account + 7 years after closure
Transaction Records	7 years from transaction date
Identity Verification Documents	7 years after account closure
Communications	3 years from last communication
Marketing Data	Until you opt-out or 2 years of inactivity
Usage Logs	2 years from collection

5.2 Data Deletion

After the retention period expires, we will securely delete or anonymize your information, unless we are required to retain it longer by law.

6. Data Security

We implement robust security measures to protect your information:

6.1 Technical Safeguards

• Encryption: Data encrypted in transit (TLS/SSL) and at rest (AES-256)
• Access Controls: Role-based access control (RBAC) and multi-factor authentication
• Firewalls: Network firewalls and intrusion detection systems
• Secure Servers: Servers hosted in secure, certified data centers
• Regular Audits: Security audits and penetration testing
• Monitoring: 24/7 security monitoring and incident response

6.2 Organizational Safeguards

• Employee Training: Regular security and privacy training
• Background Checks: Background checks for employees with data access
• Confidentiality Agreements: All employees sign confidentiality agreements
• Incident Response: Documented incident response procedures
• Data Minimization: Collect only necessary information

6.3 Your Responsibility

You are responsible for:

• Keeping your account credentials confidential
• Using strong, unique passwords
• Enabling two-factor authentication
• Reporting suspicious activity immediately
• Keeping your contact information up-to-date

7. Your Privacy Rights

Depending on your location, you may have the following rights:

7.1 Access and Portability

• Request access to your personal information
• Receive a copy of your data in a portable format
• Request information about how we process your data

7.2 Correction and Update

• Correct inaccurate or incomplete information
• Update your account information
• Request correction of errors in your data

7.3 Deletion

• Request deletion of your personal information
• Close your account
• Withdraw consent for data processing

Note: We may retain certain information as required by law or for legitimate business purposes.

7.4 Objection and Restriction

• Object to certain data processing activities
• Restrict how we use your information
• Opt-out of marketing communications

7.5 Automated Decision-Making

• Request human review of automated decisions
• Object to automated decision-making
• Understand the logic behind automated decisions

7.6 Exercising Your Rights

To exercise your privacy rights, contact us at:

• Email: privacy@sentriom.com
• Subject Line: "Privacy Rights Request"
• Include: Your name, email, and specific request

We will respond to your request within 30 days.

8. Cookies and Tracking Technologies

8.1 Types of Cookies We Use

Cookie Type	Purpose	Duration
Essential Cookies	Enable core functionality (login, security)	Session or 1 year
Performance Cookies	Analyze usage and improve performance	2 years
Functional Cookies	Remember preferences and settings	1 year
Marketing Cookies	Deliver targeted advertising	1 year

8.2 Managing Cookies

You can control cookies through:

• Browser settings (block or delete cookies)
• Our cookie consent banner
• Opt-out tools provided by third parties

Note: Disabling essential cookies may affect functionality.

9. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws.

9.1 Safeguards for International Transfers

When we transfer data internationally, we use appropriate safeguards:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions by regulatory authorities
• Binding Corporate Rules (BCRs)
• Your explicit consent

10. Children's Privacy

Our Services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children.

If we discover that we have collected information from a child under 18, we will delete it immediately. If you believe we have collected information from a child, please contact us at privacy@sentriom.com.

11. Third-Party Links and Services

Our Services may contain links to third-party websites, applications, or services. We are not responsible for the privacy practices of these third parties.

We encourage you to review the privacy policies of any third-party services you access through our platform.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Posting the updated Policy on our website
• Sending an email notification
• Displaying a prominent notice on the platform

The "Last Updated" date at the bottom of this Policy indicates when it was last revised. Your continued use of our Services after changes become effective constitutes acceptance of the updated Policy.

13. Contact Us

If you have questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us:

14. Regulatory Compliance

We comply with applicable data protection laws, including:

• GDPR: General Data Protection Regulation (EU)
• CCPA: California Consumer Privacy Act (USA)
• PIPEDA: Personal Information Protection and Electronic Documents Act (Canada)
• Other: Local data protection laws in jurisdictions where we operate

14.1 EU/EEA Residents

If you are located in the European Union or European Economic Area, you have additional rights under GDPR, including:

• Right to lodge a complaint with a supervisory authority
• Right to data portability
• Right to object to processing
• Right to withdraw consent

14.2 California Residents

If you are a California resident, you have rights under CCPA, including:

• Right to know what personal information is collected
• Right to know if personal information is sold or disclosed
• Right to opt-out of the sale of personal information
• Right to deletion
• Right to non-discrimination