Sentinel Offender Services, LLC Privacy Policy for Sentinel DNA Mobile App, Website and Services

 

Last updated:  April 14, 2021

 

Table of Contents

  1. Who’s This Policy For And What Does It Cover?
  2. What is “Personal Information”?.
  3. Personal Information We Collect And How We Collect It
  4. How We Use Personal Information.
  5. How We Share Personal Information.
  6. Children’s Privacy.
  7. Cookies And Online Tracking.
  8. Your Rights And Choices
  9. Links To Third Party Sites
  10. Third Party Direct Marketing.
  11. Security.
  12. California Residents (CCPA Statement)
  13. Data Subjects In The EEA, United Kingdom and Switzerland.
  14. Changes To This Policy.
  15. Contact Us

 

1.  Who’s This Policy For And What Does It Cover?

Sentinel Offender Services, LLC (“Sentinel” or “we”) takes your privacy seriously.  This Privacy Policy (“Policy”) applies to users of our “Services” and individuals we interact with for marketing or other commercial purposes.  It describes how we may collect, use, and share your Personal Information.  It also explains related rights and choices you may have.  Rights described in this Policy may not apply if you are using a Service or interacting with us on behalf of a government agency or other organization that is our customer, vendor or partner.

Our Services include our website (www.sentineladvantage.com), the Sentinel DNA cloud platform and Sentinel DNA mobile app offered to our customers and their users, and any other service we operate that links or refers to this Policy.  By using a Service, you consent to the practices described in this Policy.

You may see other privacy notices when we collect your Personal Information for certain purposes.  Those notices supplement this Policy.

 

This Policy does not apply to:

  • Participants in our offender monitoring programs. We collect and process program participants’ Personal Information strictly as a service provider to our customers (who are typically government agencies charged with supervising program participants).  That collection and processing is directed by our customers and governed by the terms of our agreements with them.  If you are a program participant, please contact your supervising agency to request information about their privacy practices and to exercise rights regarding your Personal Information.
  • Our employees, contractors and job applicants. We provide separate privacy notices to these individuals where required by applicable law.

 

2.  What is “Personal Information”?

When we say “Personal Information,” we mean information that can reasonably be linked to a particular individual or their household.  Generally speaking, your Personal Information includes your unique identifiers (full name, phone number, email address, user name, etc.), and information about your characteristics, conditions or behavior that is associated with one of your identifiers or could otherwise reasonably be linked to you.

“Non-Personal Information,” on the other hand, has been anonymized, aggregated or de-identified such that it cannot reasonably be linked to a particular individual or their household.

 

3.  Personal Information We Collect And How We Collect It

Categories

The Personal Information we collect may include:

  • Identifiers. Your contact information (such as first and last name, address, email address, phone number) and other identifiers that are specific to you or the compute or mobile device with which you access our Service (such as username, signature, IP address, cookie ID and similar information).
  • Demographic information. Data about you such as your age and preferred language. Demographic information may include legally protected classifications.
  • Financial information. Data to process payments, such as payment card information, which is processed on our behalf by a trusted vendor and not stored by us.
  • Commercial information. Data about what products or services you purchase, obtain or consider.
  • Professional or employment information. Data such as job title and agency, business or employer name.
  • Device and usage information. Data such as the type of device or browser you use to access the Service
  • User content. Files, data or other content you choose to post or upload to a Service.
  • Service interactions and activity. Data you share with us via email, information about how you use the Service, social media content you share, interactions with our Service such as the pages that you visit and your preferences, and interactions with communications sent on our behalf.
  • Location data. If you use our mobile app, it may access your device’s geolocation as described in more detail here.
  • Other categories disclosed to you at the point of collection

On The Sentinel DNA Mobile App

When you register an account on the DNA cloud platform via the mobile app, we collect identifiers such as your name and email address. The platform also stores user content that you generate.

The mobile app includes a feature that lets you scan or enter a program participant’s monitoring device ID during a field visit. When you use the app for that purpose, the app may access your mobile device’s precise geolocation at the time of scanning or data entry, which gets logged on our platform as part of the field visit record.  Where required by law or platform rules, you’ll see a pop-up notice that asks for your consent in order to proceed with this collection of your location data.  If you decline, your location will not be logged as part of the field visit record.

Cookies or other technologies may be used on the mobile app to remember your preferences, such as map settings, and to collect usage information to improve platform features.

Click here to see how Personal Information collected through the mobile app may be used, and here to see the types of parties with whom it may be shared.

On Our Public Website

When you visit the site, you can choose to provide us with your name and email address in order to receive more information about us or our Services.

Like most online services, our site passively collects some information from users’ devices in order to make features function correctly, customize the user experience, understand how the Service is being used, or measure the effectiveness of marketing efforts.  Some of this data may be collected through the use of browser cookies or similar online tracking technologies, which are explained below.  In some cases, we limit this type of collection to Non-Personal Information.  However, this data may include Personal Information such as online identifiers, related device information and information about how you use the site.

On The Sentinel DNA Web Portal

When you register an account on the DNA cloud platform via the web portal, we collect identifiers such as your name and email address, and our payment processor will collect payment card information to process payments for use of the platform.  The platform also stores user content that you generate.

Cookies and other technologies are used on the web portal to remember your preferences, such as map settings, and we collect usage information to improve platform features.

Other Interactions With You

We may collect Personal Information, such as your name and contact information, when you call or emails us, when you visit one of our offices, or when you interact with our representative at a meeting or conference.

 

4.  How We Use Personal Information

We use Personal Information for the following purposes:

  • To process orders and payments
  • To maintain your account
  • To present, maintain and improve our Services and analyze how they are used;
  • To secure our Services against fraud, malicious activity, or conduct that may violate our terms of use;
  • To personalize and improve your experience with the Service;
  • To provide you with information, products, or services that you request from us;
  • To notify you about changes to our Service and any products or services we offer or provide through them;
  • To allow you to participate in interactive features on the Service;
  • To provide you with periodic product newsletters and offers;
  • To contact you and provide you with help if you have a customer service issues;
  • To contact you to fill out surveys and participate in other types of market research;
  • To measure performance of our marketing efforts;
  • To notify you of new products or services we think you might be interested in;
  • To comply with our legal obligations
  • To secure our offices and other physical locations
  • In any other way we may describe when we collect the information; and
  • For any other purpose with your consent.

We may use Non-Personal Information for any purpose.

 

5.  How We Share Personal Information

Vendors

We may share Personal Information with contractors, service providers, and other vendors who assist or support us in providing the Services.  Examples of these third party services may include hosting our website or DNA cloud platform, storing data, performing analytics, processing payments, or sending marketing communications.  Our agreements with vendors prohibit them from retaining, using or disclosing the Personal Information we share with them for any purpose other than providing services to us.

Mandatory Disclosures And Legal Proceedings

We may have a legal obligation to disclose Personal Information to government authorities or other third parties pursuant to a valid regulatory request, subpoena or court order.  We may also need to disclose and otherwise process your Personal Information in accordance with applicable law to prevent physical harm or financial loss, protect the vital interests of a person, enforce our various policies or terms of use, protect our property, services and legal rights, prevent fraud, support auditing, compliance and corporate governance functions, or comply with applicable law.

Change In Control Or Merger

We may transfer your information in the event of the sale of substantially all of the assets of our business to a third-party or in the event of a corporate merger, consolidation, acquisition or reorganization. However, in such event, any acquirer will be subject to the provisions of our commitments to you or we will not disclose your information.

With Your Direction Or Consent

We will share your Personal Information with other third parties as you may direct or otherwise consent.

 

6.  Children’s Privacy

Our Services are not directed to children (individuals under the age of 16).  We do not knowingly collect, maintain, or process children’s Personal Information unless the child’s parent or guardian consents and provides the information.  If we determine that we have received a child’s Personal Information from a source other than the child’s consenting parent/guardian, we will immediately delete the information.

 

7.  Cookies And Online Tracking

What Are Cookies?

A browser cookie is a small piece of data that a website stores in your device’s browser.  It holds information that the site uses to function properly, remember your preferences, or personalize your experience.  A typical cookie contains a cookie ID, which is a unique string of characters used to identify your browser during the browsing session, or in some cases, during subsequent browsing sessions.  Cookies, cookie ID’s and similar pieces of data may be considered Personal Information (identifiers or internet activity) under applicable law.

Other online technologies, similar to cookies, may allow users to be identified and tracked across multiple browsing sessions, and in some cases tracked across different websites and online services for marketing or advertising purposes.  These technologies include, but are not necessarily limited to, pixels, web beacons and scripts (collectively with browser cookies, “Cookies”).

 

How Cookies May Be Used On Our Services

Our Service uses “first party” Cookies, which are set by our web domain (sentineladvantage.com or sentineldna.com).  Our Service also uses some “third party” Cookies, which are set by other web domains associated with our vendors.  This means that, when you visit our site, your browser may automatically connect to our vendor’s web server, as well as ours, and provide them with access to your online identifiers and information about how you use our site.

Both First Party and Third Party Cookies may be used on our Services for the following purposes:

  • Essential: Essential Cookies are necessary for site security and to enable you to move around our site and use its features.
  • Preferences. Preference Cookies allow us to remember your preferences on the Service during a browsing session or across browsing sessions.
  • Analytics: Analytics Cookies allow us to analyze use of our Site or Service to evaluate and improve performance or marketing efforts.

Our Services don’t use any Cookies to track you for cross-site advertising purposes.

 

How You Can Block Cookies

You can block, disable or delete cookies at any time by changing the settings in your browser. However, blocking, disabling, or deleting cookies may limit your ability to view all the pages of our site or other sites.  You can find more information about cookies and other options you may have for restricting them at www.cookiesandyou.com/, and www.aboutads.info/choices.

 

“Do Not Track” Signals

Your browser may offer a Do Not Track (DNT) setting.  If you turn that setting on, your browser sends a signal to websites indicating that you don’t want to be tracked over time or across third party sites.  We don’t currently respond to these signals because there is not yet a common understanding of how to process them or a consensus on what “tracking” means.

8.  Your Rights And Choices

You may opt-out of our marketing emails by using the unsubscribe link provided in the email.

See Section 7 for options to restrict Cookies.

If you reside in California, you may have additional rights and choices.

9.  Links To Third Party Sites

Our Services may contain links to third-party websites, products or services.  If you use these links, you will leave our site. Such links do not constitute or imply an endorsement, sponsorship or recommendation by us of the third party, the third-party website or the information contained therein, and we shall not be responsible or liable for your use thereof. Such use shall be subject to the terms of use and privacy policies applicable to those sites.

 

10.  Third Party Direct Marketing

We don’t share Personal Information with third parties for their direct marketing purposes.

 

11.  Security

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure.  While we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security.

 

12.  California Residents (CCPA Statement)

This statement makes additional disclosures to California residents (i.e., “consumers”), and describes rights they have, under the California Consumer Privacy Act of 2018, as amended.(the “CCPA”).  You can learn more about the CCPA here:  https://oag.ca.gov/privacy/ccpa

The rights described in this statement may not apply if you are using a Service or otherwise interacting with us on behalf of an organization that is our customer, vendor or partner.

 

Collection Of Personal Information

The categories of Personal Information we have collected about consumers in the past 12 months are listed in Section 3 of our Privacy Policy.

 

Sale Or Disclosure Of Personal Information

We don’t sell consumers’ Personal Information.

 

Within the past 12 months, we disclosed the following categories of Personal Information for a business purpose (to the categories of recipients listed):

  • Identifiers (to vendors)
  • Financial information (to vendors)
  • Commercial information (to vendors)
  • Service interactions and activity (to vendors)

Your Rights As a Californian

California residents have the right to make the following requests to covered businesses.  The requests may be made by a consumer, by a consumer on behalf of the consumer’s minor child, or by a person authorized by the consumer to act on the consumer’s behalf.

Right To Request Information About Collection, Disclosure or Sale of Personal Information              

You have the right to request that a business disclose to you: (i) the categories and specific pieces of Personal Information the business has collected about you within the past 12 months, (ii) the categories of sources from which the Personal Information is collected, (iii) the business or commercial purposes for collecting or selling Personal Information, and (iv) the categories of third parties with whom the business shares Personal Information.

If a business sells Personal Information, or discloses it for a business purpose, you also have the right to request that the business disclose the following with respect to the 12-month period preceding your request: (i) the categories of Personal Information that the business sold about you and the categories of third parties to whom the Personal Information was sold, and (ii) the categories of Personal Information that the business disclosed about you for a business purpose.

This type of request may be referred to as a “Request to Know.”  Before we can honor a Request to Know, we need to verify that the person making it is the consumer whose Personal Information we have.  Our method for verifying any particular request weighs information we receive as part of the request, the sensitivity of the consumer information at issue, and the risk of harm to the consumer from unauthorized disclosure.

Right to Request Deletion of Personal Information

You have the right to request that a business delete any Personal Information that the business has collected from you.  This type of request may be referred to as a “Request to Delete.”

Before we can honor a Request to Delete, we need to verify that the person making the request is the consumer whose Personal Information we have.  Our method for verifying any particular request weighs information we receive as part of the request, the sensitivity of the consumer information at issue, and the risk of harm to the consumer from unauthorized deletion.

We are not required to delete Personal Information if we still need it in order to complete the transaction for which the information was collected, provide a good or service requested by you (or that we reasonably anticipate based on our relationship with you), perform a contract with you, comply with a legal obligation, enable internal uses that are consistent with the context in which you provided the information, or accomplish any other objective recognized as an exception to the right to deletion under applicable law.

Right to Opt-Out of the Sale of Personal Information

You have the right to direct a business that sells Personal Information about you to third parties not to sell your Personal Information.  This type of request may be referred to as a “Request to Opt-Out.”  Because we don’t sell consumers’ Personal Information, we don’t offer an opt-out mechanism.

Right to Non-Discrimination

You have the right not to receive discriminatory treatment by a business for the exercise of your privacy rights under the CCPA.

How to Submit a Request To “Know” or “Delete”

You can submit a Request to Know or Delete to privacy@sentineladvantage.com.  The request must state “CCPA Request” and include:

  • your first and last name;
  • an email address at which you can be reached for purposes of the request;
  • the California county in which you reside;
  • for a Request to Know, the disclosure(s) you are requesting;
  • for a Request to Delete, a clear statement that you want us to delete your Personal Information; and
  • the reason(s) you believe we have collected, disclosed or sold your Personal Information, specifically, within the past 12 months (for example, you purchased a product or received a communication from us)

If you are submitting a request on behalf of another consumer as their authorized representative, you must include the foregoing information about the consumer and attach a copy of a power of attorney appointing you as a duly authorized representative under California Probate Code sections 4000 to 4465 or written permission from the consumer to make the request.

 

After confirming receipt of your request, we’ll contact you if we need more information in order to verify it.  If we can’t verify a request, we may deny it.

 

13.  Data Subjects In The EEA, United Kingdom and Switzerland

Sentinel is a Delaware limited liability company headquartered in Irvine, California that does not have an office, employees or other establishment in the European Economic Area (EEA) or any other country outside the United States (collectively, with EEA countries, the “Other Countries”).  Our Services are not targeted to natural persons in Other Countries.  If you visit our website or contact us, your Personal Information will be processed in the United States—which has neither sought nor received a finding of “adequacy” from the European Commission as referenced in Article 25 of the European Union’s General Data Protection Regulation (GDPR)—and will be handled in accordance with this Policy and applicable U.S. law, unless we have agreed otherwise in writing with you or a third party you are affiliated with.

 

14.  Changes To This Policy

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically.  Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.  If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

 

15.  Contact Us

If you have any questions or concerns about this Policy, please contact us via privacy@sentineladvantage.com.