Sentinel Offender Services, LLC Privacy Policy
Last updated: January 31, 2023
Table of Contents
Who’s This Policy For And What Does It Cover?
What is “Personal Information”?
Personal Information We Collect And How We Collect It
How We Use Personal Information
How We Share Personal Information
Children’s Privacy
Cookies And Online Tracking
Your Rights And Choices
Links To Third Party Sites
Third Party Direct Marketing
Security
California Residents (CCPA Statement)
Data Subjects In The EEA, United Kingdom and Switzerland
Changes To This Policy
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.
Our Services include our website (sentineladvantage.com), the Sentinel DNA cloud platform, the Sentinel DNA mobile app offered to our customers and their users, the Sentinel Advocate App used by victim participants in a monitoring program operated by a public agency, 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:
- Offender participants in monitoring programs. We collect and process offender 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.
- The practices of public agencies who operate the monitoring programs that rely on our services. If a public agency enrolls you in a monitoring program as a victim participant, the agency’s handling of your Personal Information is governed by the agency’s own privacy policies, which Sentinel does not control.
- 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 internet 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 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.
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, 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.
The mobile app includes a feature that lets you scan or enter a program offender 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.
On The Sentinel Advocate Mobile App
The Sentinel Advocate App may only be downloaded by victim participants who are enrolled in a monitoring program on the DNA cloud platform by the public agency operating the program. Your enrollment information, which the agency enters on our platform, includes: identifiers such as your name, email address and phone number. Once your enrollment is complete, our platform will send you a text message containing information you may use to download the Sentinel Advocate App and register an account.
Once you have registered, you will be asked to enable GPS location tracking. The Sentinel Advocate App accesses your location data, with your consent, for public safety purposes consistent with the program in which you are enrolled.
Cookies or other technologies may be used on the Sentinel Advocate App to remember your preferences and 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 monitor your location on behalf of a public agency (if you are enrolled in a program as a victim participant)
- 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.
Analytics or Marketing Partners
We may share your Personal Information with analytics providers or marketing partners to measure performance of our Service or marketing efforts. This sharing may involve the use of browser cookies and similar technologies placed through our Service by our partners, as explained here. For example, when you visit our website, our partner’s Cookie may cause your browser to automatically send a request to our partner’s server and provide our partner with your IP address, other Identifiers, Device Information and Internet Activity.
Our Public Agency Customers
If you are authorized to use the Sentinel Advocate App, we will share your GPS location data with the public agency operating the monitoring program in which you have enrolled.
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 18). 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.
Some of the Cookies used on our Services are provided by Google: https://policies.google.com/technologies/partner-sites?hl=en-US
Our Services don’t use any Cookies to track you for cross-site targeted 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.
Browser Privacy Signals
Our website honors the Global Privacy Control (GPC) signal. If you have configured your browser to send the GPC signal, we will interpret that signal as your request to opt-out of non-Essential Cookies..
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
This statement doesn’t cover our California job applicants and employees. If you are applying for a job with Sentinel, you can read our Privacy Notice to California Job Applicants here. Our Privacy Notice to California Employees can be found here.
Collection Of Personal Information
The categories of Personal Information we have collected about consumers in the past 12 months include:
- Categories listed in Section 3 of our Privacy Policy
- “Sensitive Personal Information,” as defined in the CCPA, including precise geolocation data (accurate to within 1,850 feet or less)
Sale, Sharing Or Disclosure Of Personal Information
Under the CCPA, you can request to opt-out of the “Sale” of your Personal Information—which the CCPA defines very broadly to include some transactions or arrangements that do not involve the exchange of data for money—and the “Sharing” of your personal information, which the CCPA defines as sharing with third parties for purposes of cross-site targeted advertising. The use of third party analytics or advertising cookies may be considered a Sale or Sharing of website visitors’ Personal Information under the CCPA. As a result, within the past 12 months, we may have Sold or Shared the following categories of Personal Information (to the categories of recipients listed) by using such cookies on our site:
- Identifiers (to analytics or marketing partners)
- Service interactions or internet activity (to analytics or marketing partners)
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, Sale or Sharing
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, Selling or Sharing Personal Information, and (iv) the categories of third parties to whom the business discloses Personal Information.
If a business Sells or Shares 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 or Shared about you and the categories of third parties to whom the Personal Information was Sold or Shared, 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
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, perform a contract with you, comply with a legal obligation, or accomplish any other objective recognized as an exception to the right to deletion under applicable law.
Right to Request Correction
You have the right to request that we correct inaccurate Personal Information about you. This type of request may be referred to as a “Request to Correct.” By visiting your account settings, you can correct and change certain Personal Information associated with your account.
Right to Opt-Out of Sale or Sharing
You have the right to direct a business that Sells or Shares Personal Information about you to third parties not to Sell or Share your Personal Information. This type of request may be referred to as a “Request to Opt-Out.”
Right to Limit Use and Disclosure of Sensitive Personal Information
If a business collects Sensitive Personal Information* for the purpose of inferring characteristics about you, you have the right to request that the business limit its use and disclosure of your Sensitive Personal Information to that use and disclosure which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such goods and services. (Sentinel does not collect Sensitive Personal Information for the purpose of inferring characteristics about you.)
*Sensitive Personal Information includes social security number; driver’s license or state identification number; complete account log-in credentials; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, email and text messages (unless the business is the intended recipient of the communication); genetic data; biometric information; health information; and information concerning sex life or sexual orientation.
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,” “Delete” or “Correct”
You can submit a Request to Know, Delete or Correct 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 registered an account on our platform 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 provide proof of 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.
How to Submit a Request to Opt-Out
To request to opt-out of the Sale or Sharing of your Personal Information, click the “Do Not Sell or Share My Personal Information” link at the bottom of our website’s homepage.
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 not 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.
