Privacy Policy

A. Definitions

• “Personal Information” means data that identifies you; identifies a particular individual; refers to personally identifiable information, personal information, or personal data; or identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

• “Service Provider” means a “Service Provider” under the CCPA, a “Processor” under the GDPR and US state privacy laws, or any natural person, legal entity, or other body that operates under a service-provider contract with us to process Personal Information from us under contractual obligations prohibiting the retention, use, or disclosure of Personal Information collected by us for any purpose other than the purpose specified in the contract or any other purpose permitted under any applicable data privacy laws (i.e. a person or entity who processes any Personal Information we collected on behalf of us).

• “Sensitive Personal Information” means Personal Information that includes your social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership; contents of your mail, email, and text messages unless we are the intended recipient of the communication; genetic data; biometric information; Personal Information concerning your health; Personal Information collected and analyzed concerning your sex life, sexuality, or sexual orientation, Personal Information collected from a known child.

B. How we collect your personal information.

Directly from you.
We collect your Personal Information directly from you when you provide such information directly to us, for example, when you submit information through a form on our website, send us emails, or when you apply for a job.

Tracking technologies. 
When you visit our website, use our mobile app, open or click on the emails we send you, or interact with our advertisements, we or third-parties we work with, automatically collect certain information using online tracking technologies such as pixels, web beacons, software developer kits, third-party libraries, and cookies.

D. Information we collect from website visitors.

When you visit our website, we or third-parties we work with (like advertising networks, analytics providers, and social media platforms and networks), may collect certain information using online tracking technologies such as pixels, web beacons, software developer kits, third–party libraries, and cookies (collectively, “Tracking Technologies”). These Tracking Technologies only collect your Personal Information when you consent by clicking your preference on the Privacy Banner that is displayed on our website.

The Website Tracking Technologies we use include:

• Necessary Cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. These cookies to not store any Personal Information.
• Preferences Cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.
• Statistics cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
• Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers. This information may include your IP address, browsing history, and device information. Depending on your preferences, it may be shared with third-party advertising providers like LinkedIn and Google.
• Uncategorized cookies that are being analyzed and do not belong to any of the categories listed above.

Additional information about the specific cookies in each category may be found in our Privacy Consent banner. Once you select a preference on the banner, you can view the information or modify your cookie preferences and opt-out of the collection, sale, or sharing of this information by clicking the icon displayed in the bottom left-hand corner of our website.

E. Why we use your personal information.

In addition to the disclosures above about our use of Tracking Technologies, we collect and use Personal Information for the following purposes:

Identifying information, and technical information:

• To engage in commercial transactions with you;
• To prevent and detect fraud;
• Other processing necessary to comply with professional, legal and regulatory obligations that apply to us;
• Screening for financial and other sanctions or embargoes;
• Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies;
• Ensuring business policies are adhered to, e.g. policies covering security and internet use;
• Operational reasons, such as improving efficiency, training and quality control;
• Ensuring the confidentiality of commercially sensitive information;
• Statistical analysis to help us manage our business, e.g. in relation to our financial performance;
• Preventing unauthorized access and modifications to systems;
• Ensuring safe working practices and staff administration and assessments;
• External audits and quality checks, e.g. for accreditation and the audit of our accounts;

Employment information:

• To assess your eligibility for employment, onboard and enroll you as an employee, evaluate your performance, operate our business, comply with laws, communicate with you, and to provide you with compensation and benefits.

F. Who we share your personal information with.

We share or disclosed your Personal Information for a business purpose as described below:

• We share or disclose Personal Information with our Service Providers to process this data on our behalf in order to help deliver our services to you. For example, we use a third-party software provider to allow you to apply for work with Sendero and to manage your records.
• We may also disclose and exchange Personal Information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
• As set forth in Section D (Information We Collect from Website Visitors).

G. Personal information we sell.

We do not sell any Personal Information. However, some jurisdictions consider the sharing or disclosing of Personal Information collected by Website Tracking Technologies with third-parties like LinkedIn to be a “sale” of Personal Information. To the extent this information is considered a sale, we share some of the Technical Information gathered when you browse our website with third-parties who process it to deliver content or advertisements that are more relevant to your interests, but only if you consent to the use of the applicable cookies. For additional information, please refer to Section D (Information We Collect from Website Visitors).

H. How long your personal information will be kept.

We will keep your Personal Information for the period necessary to fulfill the purposes outlined in this privacy policy, unless a longer retention period is required or permitted by law.

We will also keep your Personal Information for as long as is necessary:

• To respond to any questions, complaints or claims made by you or on your behalf;
• To show that we treated you fairly; or
• To keep records required by law.

When it is no longer necessary to retain your Personal Information, we will delete or deidentify it.

I. Where your personal information is held.

Information may be held at our offices and those of our Service Providers in the United States.

J. Global privacy control.

We honor Global Privacy Control, a browser-level signal, maintained either by a browser or browser extension, that a user can configure to opt out of the sale or sharing of Technical Information with third-parties. More information about Global Privacy Control is available at https://globalprivacycontrol.org/.

K. Important notice for children under the age of sixteen (16).

We do not intentionally collect the Personal Information of individuals under sixteen years of age. IF YOU ARE UNDER THE AGE OF 16, your parent or legal guardian must agree to this Policy.  Also, WE WILL NOT RETAIN ANY PERSONAL INFORMATION OF ANY PERSON UNDER THE AGE OF THIRTEEN (13) IF KNOWINGLY COLLECTED WITHOUT PARENTAL OR LEGAL GUARDIAN SUPERVISION AND CONSENT.  If we learn that we have collected Personal Information from someone under the age of 13 that was not provided with the supervision and consent of the minor’s parents or legal guardian, we will promptly delete that Personal Information.  If you believe we have impermissibly collected Personal Information from someone under the age of 13, please contact us immediately.

L. Available rights to you

1. Your rights in general.

For you if you are in the EEA, the UK, or Switzerland.

We do not offer our services in the EEA, the UK, or Switzerland. However, in the event that we collect Personal Information of a resident of these jurisdiction, we process that Personal Information on the following legal bases: consent; as necessary to perform our agreement to provide services or other applicable agreements; as necessary for compliance with a legal obligation to which we are subject; or as necessary for our legitimate interests and the Companies who use our Software.

Residents of the  EEA, UK, or Switzerland have the following rights.

Right to access
The right to be provided with a copy of your Personal Information (the right of access)

Right to rectification
The right to require us to correct any mistakes in your Personal Information

Right to be forgotten
The right to require us to delete your Personal Information—in certain situations

Right to restriction of processing
The right to require us to restrict processing of your Personal Information—in certain circumstances, e.g. if you contest the accuracy of the data

Right to data portability
The right to receive the Personal Information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

Right to object
The right to object:

• at any time to your Personal Information being processed for direct marketing (including profiling);

• in certain other situations to our continued processing of your Personal Information, e.g. processing carried out for the purpose of our legitimate interests.

Right not to be subject to automated individual decision-making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

Right to lodge a complaint
Users that reside in the EEA, the UK, or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en

Right to independent dispute resolution body designated to address complaints and provide appropriate recourse free of charge to you
We commit to resolve complaints about privacy and its collection or use of your Personal Information. European Union or Swiss individuals with inquiries or complaints regarding this Policy should first contact Us at marketing@senderoconsulting.com. If we are acting as the Processor pursuant to instructions from a Controller, it may refer you to the applicable Controller to exercise your rights with respect to the data we are processing on its behalf.

Furthermore, we have committed to refer unresolved privacy complaints under the Privacy Shield Principles to JAMS (Judicial Arbitration & Mediation Services), an independent alternative dispute resolution provider located in the United States and recognized for this purpose by the U.S. Department of Commerce. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit JAMS at: https://www.jamsadr.com/eu-us-data-privacy-framework for more information and to file a complaint.

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation.

United State privacy law provide residents with certain rights that may be applicable to you:

Disclosure of personal information we collect about you

You have the right to know:

• Whether we are processing your Personal Information;
• The categories of Personal Information we have collected about you;
• The categories of sources from which the Personal Information is collected;
• Our business or commercial purpose for collecting or selling Personal Information;
• The categories of third parties with whom we share Personal Information, if any; and
• The specific pieces of Personal Information we have collected about you.

Please note that we are not required to:

• Retain any Personal Information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;

• Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Information; or

• Provide the Personal Information collected to you more than twice in a 12-month period.

Personal information sold or used for a business purpose

You have the right to know:

• The categories of Personal Information about you that we sold and the categories of third parties to whom the Personal Information was sold; and
• The categories of Personal Information that we disclosed about you for a business purpose.

Right to opt-out
You have the right to opt-out of the sale of your Personal Information to third parties or Service Providers, the use for targeted advertising, and profiling in furtherance of a decision that produces a legal or similarly significant effect concerning you.

Right to access
The right to be provided with a copy of your Personal Information (the right of access)

Right to limit the use and disclosure of sensitive personal information.
The right to limit the use and disclosure of any Sensitive Personal Information about you.

Right to rectification or correct personal information
The right to require us to correct any mistakes in your Personal Information

Right to be forgotten or deleted
The right to require us to delete your Personal Information

We may deny the request if the information is necessary to:

• Complete providing a service requested or reasonably anticipated by the Opt-In Participant
• Detect and protect against security incidents, malicious, deceptive, fraudulent, or illegal activity, or take action against those responsible for such activity
• Debug to identify and repair errors impairing intended functionality
• Engage in research in the public interest adhering to applicable ethics and privacy laws where the Opt-In Participant has provided informed consent
• Enable solely internal uses reasonably aligned with the Opt-In Participant’s expectations based on the Opt-In Participant’s relationship with us
• Comply with any legal proceeding, court order, law, legal investigation, regulatory body, or other legal obligation
• Otherwise use the information internally in a lawful manner compatible with the context in which the Opt-In Participant provided the information

Right to restriction of processing
The right to require us to restrict processing of your Personal Information—in certain circumstances, e.g. if you contest the accuracy of the data

Right to data portability
The right to receive the Personal Information you provided to us in a portable and readily usable format. If the Personal Information is in a platform, you may have the right to receive the information in a format that allows the transfer to another platform.

Right to object
The right to object:

• At any time to your Personal Information being processed for direct marketing (including profiling)
• In certain other situations to our continued processing of your Personal Information, e.g. processing carried out for the purpose of our legitimate interests

Right not to be subject to automated individual decision-making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

Right not to be discriminated against
You have the right to not be discriminated against by us because you exercised any of your rights.  This means we cannot, among other things:

• Deny goods or services to you;
• Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• Provide a different level or quality of goods or services to you; or
• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of goods and services to you, if that difference is reasonably related to the value provided to our business by your Personal Information.

Right to appeal the denial of an enforcement of your right by us
You have the right to appeal the denial or failure to enforce any request of your rights listed above by us.

You can appeal any data privacy decision or indecision we make concerning your Personal Information by emailing us and including the word “Appeal” in the subject line of the email with information sufficient to allow us to identify the original request.

2. How to Contact us or Exercise Your Rights. 

If you would like to contact us or exercise any of your rights as described in this Policy, please call us at (972) 388-5760 or email us at marketing@senderoconsulting.com.

Not all of the rights listed above may apply to you depending on your state of residence and other factors, including restrictions on the number of times per year you can make certain kinds of requests. We reserve the right to evaluate your request to determine our responsibilities for complying with the request.

If you choose to contact us directly by, you will need to provide us with:

• Enough information to identify you (e.g., your full name, email address and phone number);
• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
• A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any Personal Information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

M. General Information

• Changes to This Privacy Notice. 
  We may change this Policy from time to time.

• Do You Need Extra Help? 
  If you would like this Policy in another format (for example: audio, large print, braille), please contact us (see “How to contact us” above).