When you use SENTINEL Services, you trust us with your information. We take your privacy very seriously and are committed to providing you with a positive experience on our website, with our products and in your other interactions with us.
The data protection declaration of SENTINEL is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to begin by explaining the terminology used.
Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Data controller under Article 4(7) GDPR for users in the territory of the EU and elsewhere:
Gradišćanska ulica 34
Questions, comments and complaints about SENTINEL's data practices can be submitted to SENTINEL’s data protection office by sending an email to firstname.lastname@example.org or writing to the above address.
Right of confirmation
Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact our Data Protection Officer or another employee of the controller.
Rights of access
Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to avail himself of this right of access, he or she may at any time contact our Data Protection Officer or another employee of the controller.
Right to rectification
Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact our Data Protection Officer or another employee of the controller.
Right to erasure (Right to be forgotten)
Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by SENTINEL he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of SENTINEL or another employee shall promptly ensure that the erasure request is complied with immediately. Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. The Data Protection Officer of SENTINEL or another employee will arrange the necessary measures in individual cases.
Right of restriction of processing Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by SENTINEL he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of SENTINEL or another employee will arrange the restriction of the processing.
Right to data portability
Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject may at any time contact the Data Protection Officer designated by SENTINEL or another employee or use the "Export" functionality from the SENTINEL web application.
Right to object
Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions. SENTINEL shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims. If SENTINEL processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to SENTINEL to the processing for direct marketing purposes, SENTINEL will no longer process the personal data for these purposes. In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by SENTINEL for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest. In order to exercise the right to object, the data subject may directly contact the Data Protection Officer of SENTINEL or another employee. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
Automated individual decision-making, including profiling
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent. If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, SENTINEL shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision. If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact our Data Protection Officer of SENTINEL another employee of the controller.
Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time. If the data subject wishes to exercise the right to withdraw the consent, he or she may at any time directly contact our Data Protection Officer of SENTINEL or another employee of the controller.
We collect your information through our sites and apps in several ways and at several different points,.
Traffic information is erased or made anonymous when it’s no longer needed for the purpose of transmission or, in the case of payable services, up to the end of the period during which the bill may lawfully be challenged or payment pursued.
In addition to traffic information mentioned above, we may collect two types of information: “personal information” and “non-personal information”.
We process personal information only for the purposes for which it was collected and in accordance with this Policy. We take reasonable steps to ensure that the personal information we process is accurate, complete and current, but we depend on you to update or correct your personal information when necessary.
Personal information is used to contact you or to determine your specific identity (your name, e-mail address, mailing address, phone number, etc.). Your personal information is used to help communicate with you (solicit feedback, respond to questions, provide technical support, deliver Products and Services to you, inform you).
SENTINEL may collect personal information from you in context of:
We collect information in the following ways:
a) Information you give us: when you interact with our services, we collect information that you provide to us, such as: name, email address, telephone number, User Content.
b) Information we get from your use of our services. We collect information about the services that you use and how you use them. This information includes:
We collect device-specific information (such as your hardware model, firmware version, unique device identifiers, and mobile network information).
When you use our Services we automatically collect and store certain information in server logs. This includes details of how you used Service
When you use our Services you normally register a telematics control unit (a TCU, such as Boat Monitor or Fleet Monitor) to your account. TCU data includes vessel location data. When you use SENTINEL Services, we collect and process information about the actual location of the vessel. We use various technologies to determine location, celltower ID, GPS, and other sensors that may, for example, provide SENTINEL with information on movement of the vessel. The vessel monitored might or might not be used by a registered user and is therefore not considered personal data. Regardless of that we are treating it with the same security standards.
In general, the Personal Information you provide to Us is used to help communicate with you. For example, We use your Personal Information to contact you in response to questions, solicit feedback from you, provide technical support, deliver Products and Services, and inform you about promotional offers. We only store User Content (e.g. photos you post through SENTINEL Apps) on our servers until you delete them.
SENTINEL Services might automatically send anonymized and obfuscated data log files to us that contain detailed information on your usage of the Service (e.g. data log files containing history, where (i) such history cannot be attributed to any individual person; and (ii) any personal details that you provide us voluntarily (e.g. personal names, addresses, numbers, places, etc.) are obfuscated/deleted within an app before they are sent to us). The data logs from you shall be assigned an ID that cannot be traced back to your device and your device identification shall be immediately deleted from our system. Such data log files are used solely for the purpose of:
We will use statistical data that may be connected with your device ID only for our internal purposes of:
SENTINEL also requires you to submit a user name and password of your choice for future access to your information. Your user name and password are to remain confidential and you should not share this information with anyone.
SENTINEL is the sole owner of the information collected. We are not in the business of selling or renting your personal information. We do not share your personal information with third parties for their direct marketing purposes, unless you have expressly agreed that we can do so.
We do use Third party services such as a shipping company to fulfil your orders, a credit card processing company to bill you for goods and services, an email service provider to communicate with you on our behalf, etc. When you order our Product, we will share your personal information as necessary for the third party to provide applicable services. However, they are prohibited from using your personal information for any purpose.
SENTINEL may disclose to parties outside SENTINEL collected information when SENTINEL has a good faith belief that disclosure is reasonably necessary to (i) comply with a law, regulation, or compulsory legal request, (ii) protect the safety of any person from death or serious bodily injury, (iii) prevent fraud or misuse of Service or its users, or (iv) to protect SENTINEL’s property rights.
Certain content, products and services available via SENTINEL Service may include materials from third parties (»Linked Sites«). Linked Sites may direct you to third-party websites that are not affiliated with SENTINEL. SENTINEL is not responsible for examining or evaluating the content or accuracy and we do not warrant and will not have any liability or responsibility for any third-party materials or websites, or for any other materials, products, or services of third-parties. Linked Sites are not under the control of SENTINEL, SENTINEL provides these links to you only as a convenience, and the inclusion of any link does not imply endorsement of the site or any association with SENTINEL. SENTINEL is not liable for any harm or damages related to the purchase or use of goods, services, resources, content, or any other transactions made in connection with any third-party websites. Please review carefully the third party’s policies and practices and make sure you understand them before you engage in any transaction. Complaints, claims, concerns, or questions regarding third-party products should be directed to the third party.
We appreciate your trust in sharing your personal information with us and are committed to protecting it.
We take appropriate security measures to protect against unauthorized access or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures as well as physical security measures. We restrict access to personal data to our employees, service providers and agents who need to know that information in order to operate, develop or improve our services.
We use secure socket layer (SSL) technology to encrypt and protect your personal information.
Please note that if you click away from our site to any other site you might be asked for your payment card or other personal data. These companies have their own privacy and data collection practices. We have no responsibility or liability for these policies.
On SENTINEL web app, the controller has integrated components of the enterprise Facebook. Facebook is a social network. The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. With a call-up to one of the individual pages of SENTINEL’s web app (Share route button), which is operated by the controller and into which a Facebook component (Facebook plug-ins) was integrated, the web browser on the information technology system of the data subject is automatically prompted to download display of the corresponding Facebook component from Facebook through the Facebook component. An overview of all the Facebook Plug-ins may be accessed under https://developers.facebook.com/docs/plugins/. During the course of this technical procedure, Facebook is made aware of what specific sub-site of our website was visited by the data subject. If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-site of our Internet page was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our website, e.g. the “Share route” button, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data. Facebook always receives, through the Facebook component, information about a visit to our website by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the call-up to our website. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then he or she may prevent this by logging off from their Facebook account before a call-up to our website is made. The data protection guideline published by Facebook, which is available at https://facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject. In addition, different configuration options are made available to allow the elimination of data transmission to Facebook, e.g. the Facebook blocker of the provider Webgraph, which may be obtained under http://webgraph.com/resources/facebookblocker/. These applications may be used by the data subject to eliminate a data transmission to Facebook.
Small Chat may store user IPs and emails for users of the Service.
In some cases, we arrange for external service providers to process your data (e.g. troubleshooting, creation of mailings). This makes it necessary for us to transmit your personal data to our external service providers for a specified purpose (confined to the purpose in question). We have selected our service providers carefully and commissioned them in writing. They are bound by our instructions and we have obtained information about their technical and organisational measures for the secure processing of personal data. We also require that our service providers comply with the applicable data protection regulations. We work with service providers from the EU and other EEA countries. We have concluded processing contracts with our external service providers in accordance with Article 28(3.) GDPR, EU standard contractual clauses in accordance with Article 28(7.) GDPR or the transmission is based on a decision of the EU Commission in accordance with Article 45 GDPR (e.g. Privacy Shield).
We store all our data with a cloud service provider within the EU or in IT infrastructures and systems (employee computers) at our sites within the EU.
We do not sell personal data to third parties. However, we do reserve the right to disclose information about you if we are legally obliged to or if we are required to surrender it by administrative or law enforcement bodies (e.g. police or public prosecutors).
You can update or remove your personal information or opt- out at any time.
Any request that you send to email@example.com or firstname.lastname@example.org may take up to 10 days to process and become effective.
While we strive to protect your personal information, we cannot guarantee its absolute security. Despite our efforts, there remains the possibility that information may be accessed, altered, disclosed, or destroyed due to a security breach. In the unlikely event of a breach of security, and we have a way and (if required) your permission to do so, we will notify you by email if your personal information was involved in any way.
However, we cannot be responsible for the functionality, privacy or security measures of any other organization.
Here is a list of cookies that we use. We have listed them here so you can decide whether you would like to opt-out or not.
Can I reject all cookies? You can modify your browser settings to control whether your computer accepts or declines cookies. If you choose to decline cookies, you may not be able to use certain interactive features of our Site and web app. Note that you can always go back and delete cookies from your browser; however, that means that any settings or preferences controlled by those cookies will also be deleted and you may need to recreate them.
We need certain information to complete the online transaction when you preorder or order our Products and services online:
All content you can find on our websites is the property of Us or our suppliers and is protected by copyright or other intellectual property laws. Our content is not for resale.
You agree not to modify, publish, transmit, reverse engineer, participate in the transfer or sale, create derivative works, or in any way exploit any of the content, in whole or in part, found through our websites. Our content is not for resale.
We like to communicate with you that’s why we use multiple Communication services, such as chat areas, news groups, forums, communities, etc.
These Communication services are there to support you and make your experience with our Products and Services better. That’s why they are meant only for posting, sending and receiving messages and material that is proper and related to the particular service that you’re using.
We reserve the right to terminate your access to any or all of the Communication services at any time without notice for any reason whatsoever.
Please always use caution when giving out any personally identifying information about yourself or your children in any communication service.
By way of example, and not as a limitation, you agree that when using a Communication Service, you will not:
We have no obligation to monitor the Communication Services. However, we reserve the right to review materials posted to a Communication Service and to remove any materials in its sole discretion. We reserve the right to terminate your access to any or all of the Communication Services at any time without notice for any reason whatsoever.
In principle, we process and store your data for the duration of our contractual relationship or as long as needed to provide you with Services. SENTINEL may store information longer, but only in a way that it cannot be tracked back to you. SENTINEL deletes the information as soon as they are not needed for providing our services.
When information is no longer needed, we shall delete it using reasonable measures to protect the information from unauthorized access or use.
The material on our sites is provided for general information only. We are not responsible if this information is not accurate, complete or current, though we will do our best that we provide information of that standard. However, any reliance on the material on our sites is at your own risk.
Our sites may also contain links to other sites. Those websites may have their own Privacy Policies or none at all. We do not take any responsibility for those websites.
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favour of the well-being of all our employees and the shareholders.
Our services are controlled, operated and administered by Us from our offices in EU. If you access our Products and services from outside of EU, you are responsible for compliance with all local laws.
Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact our Data Protection Officer. Our Data Protection Officer clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.
If your name, e-mail or postal address, telephone number or other personal information changes, you may update, correct or omit the relevant information by contacting SENTINEL customer service at email@example.com.
If you prefer not to receive newsletters or other marketing e-mails from SENTINEL, please let us know by clicking on the unsubscribe link within any newsletter or marketing e-mail you receive.
If you wish for your personal data to be completely removed from SENTINEL 's systems, please send deletion request to the email address firstname.lastname@example.org.
Please be sure to include in any e-mail your full name, e-mail address, and any message. Please note that such requests may take up to ten (10) days to become effective.
If you want to stop using your account, you may deactivate it. When You deactivate an account, you will not be able to use our Sites or Services and Your information will not be capable of being viewed through our sites. However, even after You deactivate Your account, copies of Your information including but not limited to name and email address may be retained by us as backup copies for legal and compliance reasons.
We may occasionally update this policy. If we make significant changes, we will notify you of the changes through the SENTINEL apps or through others means, such as email. To the extent permitted under applicable law, by using our services after such notice, you consent to our updates to this policy.
We encourage you to periodically review this policy for the latest information on our privacy practices. We will also make prior versions of our privacy policies available for review.
Last Modified: 11.11.2019