This Privacy Policy explains how SenseTe Ltd (“SenseTe”, “we”, “us” or “our”) collects, uses, stores and shares personal data when you visit the website sensete.com (the “Website”), contact us, register for our referral programme, request a demonstration of our products, or otherwise interact with us in the course of our business.
We take the protection of personal data seriously. This policy sets out what data we collect, why we collect it, the legal grounds on which we rely, how long we keep it, who we share it with, and the rights you have in relation to it. We process personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (the “GDPR”), the Cyprus Law Providing for the Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of such Data of 2018 (Law 125(I)/2018), and other applicable data protection laws.
This policy applies to personal data collected through the Website and through our direct business dealings with prospective clients, partners, referrers and other contacts. It does not apply to the personal data that our clients process through our software products, such as borrower and applicant data analysed by CreditSense. In those cases, our client is the controller of the data and we act as a processor on the client’s instructions, under the terms of the agreement between us and that client. If you are a borrower or applicant whose data has been processed through one of our products, please contact the lender or financial institution with which you dealt.
Our product website, creditsense.ai, has its own privacy policy. Please read it separately if you use that site.
SenseTe Ltd is a company incorporated in the Republic of Cyprus under registration number HE 385247. Our registered office is at 1 Methonis Street, 5th Floor, 1070 Nicosia, Cyprus.
SenseTe develops and licenses AI-driven software to lenders and other financial institutions, including the CreditSense cashflow underwriting platform. We provide technology solutions to lenders; we are not ourselves a lender, credit provider or regulated financial services provider, and we do not make lending decisions.
For the purposes of data protection law, SenseTe Ltd is the controller of the personal data described in this policy. If you have any questions about this policy or about how we handle your personal data, you can contact us using the details in Section 17.
The personal data we collect depends on how you interact with us. We collect data in the following situations.
If you complete the contact form on the Website, send us an email, call us, or write to us, we collect the information you provide. This typically includes your name, company name, job title, email address, telephone number, and the content of your message. We also keep a record of our correspondence with you.
If you request a demonstration of our products, we collect your name, company name, job title, email address, telephone number, and information about your organisation’s requirements. Where the demonstration request is submitted through creditsense.ai, that site’s privacy policy also applies.
If you register as a referrer, we collect your full name, company name, email address, and your preferred method of receiving commission payments. Where a referral results in a commission payment, we also collect the payment details necessary to make that payment, such as bank account details, a PayPal account email address, or Stripe account information, together with any tax identification information required by law. We keep records of the referrals you make, the outcome of each referral, and the payments made to you.
If you refer a prospective client to us, we also collect the name and business contact details of the person you refer. By submitting a referral, you confirm that you have the right to share that person’s details with us and that they are aware you are doing so.
When you browse the Website, we and our service providers automatically collect certain technical information from your device. This includes your IP address, browser type and version, operating system, device type, screen resolution, language settings, the website that referred you to us, the pages you view, the time and date of your visit, the time spent on each page, and the links you click. Some of this information is collected through cookies and similar technologies, which are described in our Cookie Policy.
We do not knowingly collect special categories of personal data through the Website, such as information about health, racial or ethnic origin, political opinions, religious beliefs, trade union membership, sexual orientation, or genetic or biometric data. Please do not send us this type of information. We also do not collect personal data from children; see Section 13.
We use personal data only for the purposes for which it was collected, or for closely related purposes that you would reasonably expect. The main purposes are set out below.
We use the data you provide when you contact us to respond to your enquiry, to provide the information or assistance you have requested, and to keep a record of our communication.
We use the data you provide when you request a demonstration to arrange and conduct the demonstration, to understand your organisation’s requirements, to follow up with you afterwards, and to prepare proposals and agreements if you decide to work with us.
We use referral programme data to register you as a referrer, to track the referrals you make and their outcomes, to calculate and pay the commission due to you, to meet our accounting and tax obligations, and to communicate with you about the programme.
We use Website usage data to operate, secure and maintain the Website, to understand how visitors use it, to diagnose technical problems, to improve its content and performance, and to protect it against fraud, abuse and unauthorised access.
We use business contact data to manage our relationships with clients, prospective clients, suppliers and partners, to negotiate and perform contracts, to issue and process invoices, to provide support, and to keep you informed about our products and services where we are permitted to do so.
We may also use personal data to comply with legal and regulatory obligations, to establish, exercise or defend legal claims, to respond to lawful requests from public authorities, and in connection with any merger, acquisition, financing or sale of all or part of our business.
We do not use personal data collected through the Website for automated decision-making that produces legal or similarly significant effects on you.
Under the GDPR, we must have a lawful basis for every use of personal data. We rely on the following bases.
Performance of a contract. Where you register for the referral programme, request a demonstration with a view to purchasing our products, or enter into an agreement with us, we process your data because it is necessary to perform that contract or to take steps at your request before entering into it.
Legitimate interests. We process personal data where it is necessary for our legitimate business interests, provided those interests are not overridden by your rights and interests. Our legitimate interests include responding to enquiries, operating and securing the Website, understanding how the Website is used, managing relationships with business contacts, promoting our products to organisations likely to be interested in them, preventing fraud, and running our business efficiently. Where we rely on legitimate interests, we have assessed the impact on you and concluded that the processing is proportionate and that you would reasonably expect it.
Consent. We rely on your consent to place non-essential cookies on your device and, in some circumstances, to send you marketing communications. You may withdraw consent at any time, and we will stop the relevant processing. Withdrawing consent does not affect the lawfulness of any processing carried out before you withdrew it.
Legal obligation. We process personal data where necessary to comply with laws that apply to us, including accounting, tax, anti-money-laundering and record-keeping requirements, and to respond to lawful requests from courts, regulators and other public authorities.
If you have questions about the legal basis for a particular use of your data, please contact us using the details in Section 17.
Our referral programme allows registered referrers to introduce prospective clients to us and to earn commission when an introduction leads to a signed agreement. Participation is governed by the programme’s Terms and Conditions, which you accept when you register.
To run the programme, we keep a record of each referrer, the referrals they make, the status of each referral, and the commissions earned and paid. We share the name and contact details of a referred prospect only with the members of our team responsible for following up. We do not disclose the details of one referrer’s activity to another referrer.
Commission payments are made through the payment method you select at registration. To make payments, we share the necessary payment details with the relevant payment provider, such as our bank, PayPal or Stripe. These providers process your data under their own privacy policies and may be independent controllers of that data. We retain payment records for as long as required by accounting and tax law.
If you refer someone to us, you are responsible for ensuring that you have an appropriate basis for sharing their details, and that they are aware of the referral. We will inform the referred person of the source of their details when we first contact them.
The Website uses cookies and similar technologies to make the site work, to remember your preferences, to understand how the site is used and, with your consent, to support our marketing. When you first visit the Website, a consent banner allows you to accept or reject each category of non-essential cookies. You can change your choices at any time through the “Cookie Settings” link in the footer.
Full details of the cookies we use, their purposes, how long they last, and how to control them are set out in our Cookie Policy, which forms part of this Privacy Policy.
We do not sell personal data. We share it only with the categories of recipient described below, and only to the extent necessary for the purposes set out in this policy.
Service providers. We use third-party companies to perform services on our behalf, including website hosting, cloud infrastructure, email delivery, customer relationship management, analytics, payment processing, accounting, and IT support. These providers process personal data only on our documented instructions, under contracts that require them to protect the data and to use it solely to provide the service to us.
Professional advisers. We may share personal data with our lawyers, accountants, auditors, insurers and other professional advisers where necessary to obtain their advice or to protect our legal interests.
Group companies. We may share personal data with any affiliated company that is under common ownership or control with SenseTe Ltd, for the purposes described in this policy.
Authorities and legal recipients. We may disclose personal data to courts, regulators, law enforcement agencies and other public authorities where we are required to do so by law, where it is necessary to establish, exercise or defend legal claims, or where we reasonably believe disclosure is necessary to prevent harm or fraud.
Corporate transactions. If we sell, transfer or merge all or part of our business or assets, or if we are involved in a financing or restructuring, personal data may be disclosed to the prospective buyer, investor or their advisers under appropriate confidentiality terms, and may be transferred to the new owner on completion.
In each case we share only the data that is necessary for the purpose, and we take steps to ensure that the recipient protects it appropriately.
Some of the information collected through cookies, such as your IP address or a unique cookie identifier, may constitute personal data under the General Data Protection Regulation (GDPR). Where this is the case, we process that data on the following legal bases: for strictly necessary cookies, our legitimate interest in operating a secure and functional website; for all other cookies, your consent, which you may withdraw at any time.
We use cookie data only for the purposes described in this policy. We retain it for no longer than is necessary for those purposes, after which it is deleted or anonymised. Access to cookie data within SenseTe is limited to staff who need it to perform their roles.
Under the GDPR, you have the right to access the personal data we hold about you, to have it corrected or erased, to restrict or object to its processing, and to receive it in a portable format. You also have the right to lodge a complaint with a supervisory authority. In Cyprus, this is the Office of the Commissioner for Personal Data Protection, whose contact details are available at dataprotection.gov.cy. Further information on exercising your rights is set out in our Privacy Policy.
We keep personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, accounting and reporting requirements, and to establish, exercise or defend legal claims.
In general, we apply the following retention periods. Enquiries and demonstration requests that do not lead to a business relationship are kept for up to two years from our last contact with you, so that we can respond to follow-up questions and avoid contacting you again unnecessarily. Business contact data relating to clients, suppliers and partners is kept for the duration of the relationship and for six years after it ends, in line with limitation periods for contractual claims. Referral programme records, including commission payments, are kept for the duration of your participation and for seven years afterwards to meet accounting and tax requirements. Website usage data collected through analytics cookies is kept for the period set by the relevant tool, which is typically between two and twenty-six months. Server log files are kept for up to twelve months for security purposes.
When we no longer need personal data, we delete it securely or anonymise it so that it can no longer be associated with you. In some circumstances we may keep data for longer, for example where a legal claim is pending or where we are required to do so by a regulator.
We keep personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, accounting and reporting requirements, and to establish, exercise or defend legal claims.
In general, we apply the following retention periods. Enquiries and demonstration requests that do not lead to a business relationship are kept for up to two years from our last contact with you, so that we can respond to follow-up questions and avoid contacting you again unnecessarily. Business contact data relating to clients, suppliers and partners is kept for the duration of the relationship and for six years after it ends, in line with limitation periods for contractual claims. Referral programme records, including commission payments, are kept for the duration of your participation and for seven years afterwards to meet accounting and tax requirements. Website usage data collected through analytics cookies is kept for the period set by the relevant tool, which is typically between two and twenty-six months. Server log files are kept for up to twelve months for security purposes.
When we no longer need personal data, we delete it securely or anonymise it so that it can no longer be associated with you. In some circumstances we may keep data for longer, for example where a legal claim is pending or where we are required to do so by a regulator.
Under the GDPR you have a number of rights in relation to your personal data. These rights are subject to certain conditions and exceptions, but in summary they are as follows.
Right of access. You can ask us to confirm whether we are processing your personal data and, if so, to provide you with a copy of that data together with information about how we use it.
Right to rectification. You can ask us to correct personal data that is inaccurate or to complete data that is incomplete.
Right to erasure. You can ask us to delete your personal data in certain circumstances, for example where it is no longer needed for the purpose for which it was collected, where you have withdrawn consent, or where you have objected to processing and we have no overriding legitimate grounds to continue.
Right to restriction. You can ask us to restrict the processing of your personal data in certain circumstances, for example while we verify the accuracy of data you have contested, or where you have objected to processing and we are considering whether our legitimate grounds override yours.
Right to data portability. Where we process your data on the basis of consent or contract and the processing is carried out by automated means, you can ask us to provide the data to you, or to transmit it directly to another controller, in a structured, commonly used and machine-readable format.
Right to object. You can object at any time to processing that is based on our legitimate interests. We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is needed to establish, exercise or defend legal claims. You can also object at any time to the use of your data for direct marketing, and we will stop that processing without exception.
Right to withdraw consent. Where we rely on your consent, you can withdraw it at any time. This does not affect the lawfulness of processing carried out before withdrawal.
Right to lodge a complaint. If you believe that our processing of your personal data infringes data protection law, you have the right to lodge a complaint with a supervisory authority. In Cyprus, this is the Office of the Commissioner for Personal Data Protection, 1 Iasonos Street, 1082 Nicosia, Cyprus; website dataprotection.gov.cy; email commissioner@dataprotection.gov.cy. You may also complain to the supervisory authority in the EU member state where you live or work. We would, however, appreciate the chance to address your concerns first.
To exercise any of these rights, please contact us using the details in Section 17. We may need to verify your identity before responding. We will respond within one month of receiving your request, although we may extend this period by up to two further months where a request is complex or where we receive a number of requests. We will not charge a fee for responding unless a request is manifestly unfounded or excessive.
We may send you information about our products, services, events and industry developments where you have asked to receive it, where you are an existing or prospective business client and we are permitted to do so under applicable law, or where you have otherwise consented.
You can opt out of marketing communications at any time by clicking the unsubscribe link in any marketing email we send, or by contacting us using the details in Section 17. Opting out will not affect communications that are necessary to perform a contract with you or to respond to your enquiries.
The Website and our services are directed at businesses and professionals and are not intended for children under the age of 18. We do not knowingly collect personal data from children. If you believe that a child has provided us with personal data, please contact us and we will delete it.
The Website contains links to other websites, including creditsense.ai and the websites of our partners and integration providers. This Privacy Policy applies only to sensete.com. We are not responsible for the privacy practices or content of other websites, and we encourage you to read the privacy policy of every website you visit.
We may update this Privacy Policy from time to time to reflect changes in our practices, in the services we offer, or in the law. When we make changes, we will update the date at the top of this page. If a change materially affects how we use your personal data, we will take reasonable steps to bring it to your attention, for example by posting a notice on the Website or by contacting you directly. We encourage you to review this page periodically.
If you have any questions about this Privacy Policy, wish to exercise any of your rights, or have a concern about how we handle your personal data, please contact us:
SenseTe Ltd
1 Methonis Street, 5th Floor
1070 Nicosia, Cyprus
Email: sales@sensete.com
Telephone: +357 22 024165
