Privacy Policy

Privacy Policy

 Introduction and Scope

We appreciate you taking the time to review our Privacy Policy. This Privacy Policy outlines how Sentai Ltd (“we,” “us,” or “our”) collects, uses, and discloses personal data when you interact with us, use our website, and access our products and services, including our mobile app, our direct to consumer product (‘Sentai’) and Sentai Pro, which we supply to care providers. We are committed to protecting and respecting your privacy.

By accessing, interacting with, or using our website and our products and services, you agree to the terms set out in this Privacy Policy. This includes the collection, use, and processing of your personal information for the purposes described herein.

  • We are committed to processing your data transparently, securely, and in line with the UK GDPR and other applicable data protection laws.

If you have any questions, please get in touch with our Data Protection Officer at privacy@sentai.co.uk

 

Data Controller Information

Sentai Ltd, located at 71-75 Shelton Street, London, Greater London, WC2H 9JQ, United Kingdom, is the data controller responsible for processing personal data under the retained EU law General Data Protection Regulation (UK GDPR) and the  Data Protection Act 2018.

For services where we act as a data processor (e.g., Sentai Pro provided by care providers), our responsibilities are outlined in our Data Processing Agreement (DPA).

 

How we collect your data

We use different methods to collect data from and about you including through:

  • Your interactions with us. This includes personal data you provide when you:
    • subscribe to our products or services, including for a trial period;
    • download our app;
    • request email marketing to be sent to you; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies. Please see the section titled ‘ Cookies’ within this policy.
  • Third parties. We will receive personal data about you from third parties, for example via your chat messages with family members.

Audio Data

Sentai devices feature integrated microphones that allow for seamless, voice-driven interaction. The system actively listens locally for specific wake words and once detected, provides a subtle visual cue via the device’s light ring to indicate it is ready to receive and respond to spoken commands.

Data We Collect and How We Use It

To improve clarity, we categorise the data collected and processed into three distinct purposes:

1.Business Operations (Sales, Marketing, Finance, Website Usage, and Product Support)

Data Collected:

  • Identity Data: Full name, preferred name.
  • Contact Data: Email address, telephone number, postal address.
  • Usage Data: Interactions with our website, browsing history and cookies.
  • Transaction Data: Billing information, payment history.
  • Communication Data: Support requests, email correspondence.

Purpose of Processing:

  • Manage and process customer enquiries, support requests, and transactions.
  • Manage and process billing, payments, and financial transactions, including invoicing and payment history tracking
  • Send marketing communications where consent is obtained.
  • Analyse website usage for product improvement and personalisation.
  • Perform internal reporting, business analysis, and compliance activities.

Legal Basis:

  • Contractual necessity for service delivery.
  • Legitimate interests for marketing, analytics, and service improvement.
  • Consent for email marketing and cookies.

2.Sentai Consumer Product (Sold directly to consumers)

If you have subscribed to Sentai via our website, this section will apply to you.

Data Collected:

  • Identity Data: Full name, preferred name, date of birth.
  • Contact Data: Email address, billing address, telephone number.
  • Reminder Responses: Mealtime, medication, wake-up, and bedtime schedules.
  • Shopping Lists: Items added to a shopping list.
  • Activity Data: Motion and presence activity.
  • Chat Data: Messages between the end user and their contacts.
  • Speech Data: Conversation transcripts and responses (no audio recordings).
  • Device Data: Call logs, device IP addresses.
  • Notes: Notes shared among end users and family members.
  • Financial Data: includes bank account and payment card details.

Purpose of Processing:

  • Deliver and improve Sentai consumer services and features.
  • Enable reminders, shopping lists, activity monitoring, and communication tools.
  • Personalise services based on user preferences.
  • Generate anonymised insights for product enhancement.
  • Manage your subscription and provide you with the Sentai product.

Legal Basis:

  • Contractual necessity for delivering the product.
  • Legitimate interests to recover payments due to us.
  • Consent for processing special categories of data (e.g., reminders and transcripts).

Additional Note: If you purchase Sentai on behalf of someone else, you will be considered a joint controller with us. This means you have specific responsibilities under the UK GDPR, including:

  • Informing the end user about how their data will be processed as part of the service.
  • Ensuring that the end user provides explicit consent for the processing of their personal data. These responsibilities are outlined in the Terms of Service, and it is your obligation to comply with these requirements before activating the product on behalf of the end user.

3.Sentai Pro (Sold via Care Providers)

If you have subscribed to Sentai Pro via a care provider, the care provider will be the data controller of your personal data. Please refer to the care provider’s privacy policy for information on how they will use your personal data. We have set out below information about how we will process your personal data on the care provider’s behalf, in order to deliver the Sentai Pro service to you.

Data Collected:

  • Identity Data: Full name, preferred name, date of birth.
  • Contact Data: Email address, telephone number.
  • Employee Data: Care provider employee names, job titles, and contact information.
  • Reminder Responses: Mealtime, medication, wake-up, and bedtime schedules.
  • Activity Data: Motion and presence activity.
  • Chat Data: Messages between care providers, end users, and family members.
  • Speech Data: Conversation transcripts and responses (no audio recordings).
  • Device Data: Call logs, device IP addresses.
  • Notes: Notes shared across care providers, family members, and end users.

Purpose of Processing:

  • Provide Sentai Pro services in compliance with agreements made with care providers.
  • Enable care providers to manage end-user services effectively.
  • Maintain employee contact information for communication and support purposes.
  • Support care providers in complying with their data protection obligations.
  • Process data under the explicit instructions of care providers.

Care Provider Obligations and Responsibilities:

  • End-User Data: Care providers, as data controllers, must inform end users about the collection and use of their data in accordance with applicable data protection laws. This includes obtaining explicit consent where required.
  • Employee Data: Care providers are responsible for ensuring their employees are informed about how their data will be processed and stored as part of service delivery.

Legal Basis:

  • Care providers act as data controllers, and Sentai Ltd acts as a data processor under a Data Processing Agreement (DPA). This agreement defines the roles, responsibilities, and limitations of both parties in data handling.

Transparency and Accountability:

  • All processing is governed by the agreements established with care providers. Sentai Ltd commits to ensuring that its processing activities align with care providers’ instructions and applicable laws.
  • Care providers must ensure their privacy policies and practices are communicated effectively to end users and employees, and that appropriate security measures are in place to safeguard all collected data.

Legal Basis for Processing

We are committed to protecting your privacy and will only collect, process, use, or share your personal information as described in this Privacy Policy, relying on one or more of the following legal grounds:

  • Your consent: Where you have provided explicit consent, we will process your information for specific purposes, such as sending marketing communications or handling special categories of data. You can withdraw your consent at any time.
  • To fulfil a contract: We process your personal information where it is necessary to deliver the services you have requested, particularly for Sentai Consumer products, or to meet our obligations under our Terms of Service.
  • Legitimate interests: We may process your information to support our legitimate business interests, such as improving our services, performing analytics, and maintaining the functionality and security of our systems. In doing so, we ensure that our interests are carefully balanced against your rights and freedoms.
  • Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

We always aim to process your data lawfully, fairly, and transparently, under applicable data protection laws.

Marketing

Direct marketing

During the subscription process on our website when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from us via email.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes (for example renewal reminders for your subscription or updates to our Terms of Service).

Your Rights

Your rights under the UK GDPR include:

  • Right of Access (commonly known as a ‘subject access request’): Request a copy of the personal data we hold about you.
  • Right to Rectification: Request correction of inaccurate or incomplete data.
  • Right to Erasure: Request deletion of your personal data in certain circumstances. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Right to Restrict Processing: Request restriction of processing in one of the following scenarios:
    • If you want us to establish the data’s accuracy;
    • Where our use of the data is unlawful but you do not want us to erase it;
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Right to Object: Object to data processing, particularly for direct marketing purposes or where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
  • Right to Data Portability: Request transfer of your data in a machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Right to Withdraw Consent: Where processing relies on consent, you may withdraw it at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You will not have to pay a fee to exercise any of your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to exercise any of your rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Variations Based on Service:

  • Direct-to-Consumer Services: If you purchased services or products directly from Sentai Ltd, Sentai Ltd acts as the data controller and is responsible for managing your DSAR.
  • Sentai Pro Services (via Care Providers): If you access Sentai Pro through a care provider, the care provider acts as the data controller. All DSAR requests must be directed to the care provider, who is responsible for responding to your rights under the UK GDPR.

To exercise any of your rights, please contact: Email: privacy@sentai.co.uk

Third-Party Data Transfers

For Sentai and Sentai Pro, we use trusted third-party processors to provide hosting, storage, and AI functionalities, including:

  • Microsoft Azure: Hosting and data storage services.
  • Amazon Web Services (AWS): Cloud infrastructure and services.
  • OpenAI: AI-powered features and processing capabilities.

Personal data may be processed by third-party service providers (e.g., hosting, analytics, payment processors).

Whenever we transfer your personal data out of the UK to third parties, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

  • We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data, for example, the EEA.
  • We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement.

Data Retention

For Sentai and Sentai Pro products, we retain personal data for the duration of the contract with the customer or care provider. Once the contract ends, data is securely deleted or anonymised unless retention is required by legal obligations.

We retain other personal data for as long as necessary to fulfil the purposes described in this policy. When no longer needed, data is securely deleted or anonymised.

We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Security

We are committed to ensuring the security and protection of the personal data we process. To achieve this, we implement a comprehensive range of industry-standard security measures, including:

  • Encryption: Personal data is encrypted during transmission and at rest to prevent unauthorised access.
  • Access Controls: Role-based access is enforced to ensure that only authorised personnel can access sensitive data.
  • Network Security: Firewalls, intrusion detection systems, and other advanced technologies are employed to protect our infrastructure from malicious attacks.
  • Regular Audits: Security systems and policies are regularly audited and updated to address evolving threats and vulnerabilities.
  • Incident Response Plan: A robust incident response plan is in place to quickly address and mitigate any security breaches or data incidents.

Despite these measures, no method of transmission over the Internet or electronic storage is entirely secure. We continue to enhance our security measures and encourage users to take precautions, such as safeguarding their login credentials.

Cookies

Our website uses cookies to enhance user experience and gather analytics data. By using our website, you agree to our use of cookies as described in this policy. You can manage your cookie preferences in your browser settings.

When you use the website or Service, certain information may be stored locally on your device using ‘cookies’. A cookie is a small text file that is stored on your browser or your device’s local storage. Cookies store limited information about the user of the device, such as the device model, manufacturer, screen resolution, device capabilities, service provider and country and city location data. This helps us to identify how users use our website and Service so that we can continue to develop and improve them and so that we can provide you with content which is more relevant to your interests. We may also use this information for reporting and analytics purposes.

Cookies We Use:

  • Google Analytics: For usage analytics.
  • Google AdWords: For targeted advertising.
  • HubSpot: For customer relationship management.

Please note that our advertisers may also use cookies, over which we have no control. For more information about what cookies are and how they can be controlled, please visit the third-party educational resource www.allaboutcookies.org.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated “Last Updated” date. Continued use of our services constitutes acceptance of the updated policy.

How to Contact Us

For privacy-related enquiries, contact our Data Protection Officer at:

Email: privacy@sentai.co.uk

Postal Address:
Sentai Ltd 71-75 Shelton Street
London, WC2H 9JQ
United Kingdom

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using our contact details above.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:          
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint

++Last updated 20th March 2025++