Privacy Policy

This Privacy Policy explains how Sentrios ("Sentrios", "we", "us", or "our") collects, uses, stores, and protects personal data when you visit our website at sentrios.dk or contact us directly. We are committed to protecting your privacy and processing your personal data in full compliance with Regulation (EU) 2016/679 (the General Data Protection Regulation, "GDPR") and Danish data protection law (Lov om supplerende bestemmelser til forordning om beskyttelse af fysiske personer i forbindelse med behandling af personoplysninger, "Databeskyttelsesloven").

Please read this policy carefully. If you have questions, you can contact us at any time using the details in Section 1 below.

1. Data Controller

The data controller responsible for processing your personal data is:

Sentrios
Copenhagen, Denmark
Email: hello@sentrios.dk

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact us at the email address above. We aim to respond to all enquiries within 30 days.

2. Scope of This Policy

This policy applies to:

• Visitors to the Sentrios website (sentrios.dk and any subdomains).
• Individuals who contact us via the contact form on our website, which is powered by Formspree.
• Individuals who contact us directly by email.

This website is a pre-launch marketing and information website. Sentrios does not currently operate user accounts, customer portals, or any service that requires end-user registration. When the Sentrios platform is made available to customers, a separate Data Processing Agreement and product-specific privacy notice will govern that relationship.

3. Personal Data We Collect

We collect only the personal data that is necessary for the purposes described in this policy. The categories of data we collect are as follows.

Contact form submissions. When you submit a message via our contact form (powered by Formspree), we collect the information you provide, which typically includes your name, email address, and the content of your message. You may also provide your company name, job title, or other details voluntarily.

Direct email correspondence. When you email us at hello@sentrios.dk, we collect your email address, name (if provided), and the content of your message.

Website analytics. We use cookies and similar technologies to collect basic, anonymised information about how visitors interact with our website. This includes pages visited, time spent on pages, browser type, and approximate geographic region (at country level). We do not collect individually identifying data through analytics. See Section 7 (Cookies) for full details.

Technical data. When you access our website, your browser automatically transmits certain technical data to our web server, including your IP address, browser version, operating system, referring URL, and the date and time of your request. This data is processed transiently for security and operational purposes and is not used to build individual profiles.

4. Legal Bases for Processing

Under the GDPR, we must have a valid legal basis for every processing activity. The legal bases we rely on are:

• Legitimate interests (Article 6(1)(f) GDPR). We process contact form submissions and email correspondence to respond to your enquiry. Our legitimate interest is to communicate with prospective customers, partners, and members of the public who reach out to us. We have assessed that this processing does not override your rights and freedoms, as we process only the data you have proactively provided, retain it for a limited period, and do not use it for unrelated purposes.
• Consent (Article 6(1)(a) GDPR). Where we use non-essential cookies for analytics, we rely on your freely given, specific, and informed consent obtained via our cookie banner before any such cookies are set. You may withdraw your consent at any time by adjusting your browser settings or cookie preferences.
• Legal obligation (Article 6(1)(c) GDPR). In limited circumstances we may be required to process or retain personal data to comply with a legal obligation under Danish or EU law, including accounting record-keeping requirements and responding to lawful requests from competent authorities.

5. Purposes of Processing

We process your personal data for the following purposes only:

• Responding to enquiries. To read and reply to messages you send us via the contact form or email, including answering questions about our product, pricing, or partnership opportunities.
• Pre-launch communications. If you have expressly requested to be notified when the Sentrios platform launches, we will use your contact details to send you that notification. We will not add you to any mailing list without your explicit consent.
• Website analytics and improvement. To understand how visitors use our website so that we can improve its content, navigation, and performance.
• Security and fraud prevention. To protect the integrity and security of our website and systems by monitoring for unauthorised access, abuse, or malicious activity.
• Legal and regulatory compliance. To meet our obligations under applicable Danish and EU law.

We will not use your personal data for any purpose that is incompatible with the purposes listed above without first notifying you and, where required, obtaining your consent.

6. Third-Party Sub-Processors

We engage a small number of trusted third-party service providers who process personal data on our behalf as data processors. We have entered into written data processing agreements with each processor, as required by Article 28 GDPR, and we verify that they provide sufficient guarantees of appropriate technical and organisational measures.

Formspree, Inc. (contact form). Our website contact form is powered by Formspree, a third-party form submission service. When you submit the contact form, your submission data (name, email address, message, and any other fields you complete) is transmitted to and temporarily stored by Formspree in order to deliver it to us. Formspree acts as a data processor on our behalf. Their privacy policy is available at formspree.io/legal/privacy-policy. Formspree is a US-based company. Where personal data is transferred outside the European Economic Area ("EEA"), Formspree relies on Standard Contractual Clauses (SCCs) approved by the European Commission as the appropriate safeguard under Chapter V GDPR.

Analytics provider (website analytics). We use a privacy-focused analytics tool to collect aggregated, anonymised data about website traffic. We take care to configure our analytics in a way that avoids collecting personally identifying information and, where possible, process analytics data entirely within the EU. Full details of the specific provider and their data processing practices are disclosed in our Cookie Policy at /cookies.

Hosting and infrastructure. Our website is hosted on infrastructure operated by our hosting provider. We ensure that our hosting infrastructure is located within the European Union in order to maintain EU data sovereignty for all data that passes through our systems.

We do not sell, rent, or otherwise disclose your personal data to any third party for their own marketing or commercial purposes.

7. Cookies and Similar Technologies

We use cookies and similar browser storage technologies on our website. Cookies are small text files placed on your device by your browser when you visit a website.

We use the following categories of cookies:

• Strictly necessary cookies. These cookies are essential for the website to function correctly. They do not collect personal data and do not require your consent under the ePrivacy Directive and Danish e-handelsloven. Examples include session integrity cookies and cookies that remember your cookie consent preference.
• Analytics cookies. These cookies help us understand how visitors interact with our website by collecting information about pages visited and navigation paths. This data is aggregated and anonymised. Analytics cookies are only set after you have given your consent via our cookie banner.

You can withdraw your consent for analytics cookies at any time by clearing your cookies in your browser settings, or by changing your preferences in our cookie consent tool. Note that strictly necessary cookies cannot be disabled without affecting core website functionality. For full details, including a list of specific cookies, their lifetimes, and the data they collect, please see our Cookie Policy at /cookies.

8. International Data Transfers

Sentrios is headquartered in Denmark and operates within the European Union. We are committed to EU data sovereignty: our primary infrastructure, data storage, and data processing activities take place exclusively within the European Economic Area.

The one exception identified at the time of this policy is the use of Formspree for contact form processing. As described in Section 6, where data is transferred to Formspree in the United States, that transfer is governed by Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914) which provide an equivalent level of protection to that within the EEA. You can request a copy of the applicable SCCs by contacting us at hello@sentrios.dk.

We will update this section promptly if we engage any new sub-processor that involves a transfer of personal data outside the EEA.

9. Data Retention

We retain personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by law. Our specific retention periods are as follows:

• Contact form and email enquiries. We retain correspondence for up to 24 months from the date of the last interaction. This allows us to provide a continuous and informed response if you follow up on an earlier enquiry. After 24 months, data is securely deleted or anonymised unless we are legally required to retain it for longer.
• Pre-launch notification requests. If you have consented to receiving a launch notification, we retain your contact details until the notification has been sent or until you withdraw your consent, whichever is earlier. We will send the launch notification within a reasonable period following our product launch and then promptly delete the data unless you have opted in to further communications.
• Analytics data. Aggregated, anonymised analytics data may be retained indefinitely as it no longer constitutes personal data. Any personal data processed in the course of analytics (such as IP addresses, prior to anonymisation) is anonymised or deleted within the retention periods specified by our analytics provider.
• Legal obligations. Where we are required by Danish or EU law to retain records (for example, accounting records under Bogføringsloven), we retain the relevant data for the legally prescribed period and no longer.

10. Your Rights Under GDPR

As a data subject under the GDPR, you have the following rights in relation to the personal data we hold about you:

• Right of access (Article 15). You have the right to obtain confirmation of whether we process personal data about you, and if so, to receive a copy of that data along with information about how we process it.
• Right to rectification (Article 16). You have the right to request that we correct any inaccurate personal data we hold about you, or that we complete any incomplete data.
• Right to erasure (Article 17). You have the right to request that we delete your personal data in certain circumstances, for example where the data is no longer necessary for the purpose for which it was collected, or where you withdraw consent and there is no other legal basis for processing.
• Right to restriction of processing (Article 18). You have the right to request that we restrict our processing of your personal data in certain circumstances, for example while the accuracy of the data is contested or an objection to processing is being assessed.
• Right to data portability (Article 20). Where processing is based on your consent or on a contract, and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.
• Right to object (Article 21). You have the right to object at any time to processing of your personal data that is based on our legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or unless the processing is for the establishment, exercise, or defence of legal claims.
• Right to withdraw consent (Article 7(3)). Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
• Right not to be subject to automated decision-making (Article 22). We do not carry out any automated decision-making or profiling that produces legal or similarly significant effects on individuals.

To exercise any of these rights, please contact us at hello@sentrios.dk. We will respond to your request without undue delay and in any event within one month of receipt. In complex or numerous cases, we may extend this period by a further two months, and we will notify you of any extension within the first month. We will process all requests free of charge unless they are manifestly unfounded or excessive, in which case we may charge a reasonable fee or decline to act.

We may need to verify your identity before acting on a request in order to prevent unauthorised disclosure or deletion of data.

11. Right to Lodge a Complaint

If you believe that our processing of your personal data infringes the GDPR, you have the right to lodge a complaint with the competent supervisory authority. In Denmark, the competent supervisory authority is:

Datatilsynet (The Danish Data Protection Agency)
Carl Jacobsens Vej 35
2500 Valby, Denmark
Website: www.datatilsynet.dk
Email: dt@datatilsynet.dk
Phone: +45 33 19 32 00

You also have the right to lodge a complaint with the supervisory authority of your EU member state of habitual residence or place of work if that differs from Denmark. We encourage you to contact us directly in the first instance, as we would welcome the opportunity to address your concern before it reaches a supervisory authority.

12. Security of Personal Data

We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access, in accordance with Article 32 GDPR. Specific measures include:

• Encryption of data in transit using TLS 1.2 or higher across all website connections.
• Limiting access to personal data to Sentrios personnel who need it to respond to your enquiry, and who are bound by confidentiality obligations.
• Selecting sub-processors that demonstrate appropriate security certifications and contractual commitments to data protection.
• Regular review of our security posture and third-party processor arrangements.

No method of electronic transmission or storage is completely secure. While we take our obligations seriously and apply industry-standard protections, we cannot guarantee absolute security. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours of becoming aware of it, as required by Article 33 GDPR, and we will notify affected individuals without undue delay where the breach is likely to result in a high risk to your rights and freedoms, in accordance with Article 34 GDPR.

13. Children's Personal Data

Our website and services are directed at business professionals and are not intended for use by individuals under the age of 16. We do not knowingly collect personal data from children. If you believe that we have inadvertently collected personal data from a child, please contact us immediately at hello@sentrios.dk and we will take prompt steps to delete such data.

14. Links to Third-Party Websites

Our website may contain links to third-party websites, resources, or services. This Privacy Policy applies only to our website and does not cover the privacy practices of any third-party site. We encourage you to review the privacy policies of any third-party sites you visit. We are not responsible for the content or privacy practices of linked sites.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. When we make material changes, we will update the "Last updated" date at the top of this page. We encourage you to review this policy periodically.

Where a change materially affects how we use data that you have already provided to us, we will take reasonable steps to notify you directly, for example by email if we hold your contact details.

16. Contact Us

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or have any concerns about how we process your personal data, please contact us:

Sentrios
Copenhagen, Denmark
Email: hello@sentrios.dk

For complaints relating to our processing of your personal data, you may also contact Datatilsynet as described in Section 11 above.