Privacy Policy for SENTIO Offline Surveys

Last updated: 05-05-2025

This Privacy Policy explains how SENTIO Offline Surveys ("we", "our", or "the Company") collects, uses, and protects information from users ("User/s") who participate in surveys through our app. All surveys are conducted anonymously and do not allow for user identification.

1. Data Controller

The data controller is Tommaso Pronunzio, CEO of Ales Market Research Srl, with registered office in Via Valtellina 20, 20159 - Milano - Italy (hereinafter, the "Owner").

email: privacy@alesresearch.com

2. Anonymous Nature of Collected Data

The app is designed not to collect personal identifying data, such as names, email addresses, or phone numbers—unless the user voluntarily provides them (e.g., through open comments or optional feedback).

All survey responses are recorded in anonymous or pseudonymized form and cannot be traced back to the user's identity.

3. Technical Data That May Be Collected

To ensure technical operation and security of the app, we may collect limited data such as:

• Log data (access date/time, device type, operating system)

• IP address, processed solely for security and stored temporarily

• Device information (e.g., model, OS version)

This technical data is never linked to survey responses and is treated separately, in an aggregated and anonymous manner.

4. Purpose of Data Processing

• Provide and improve the anonymous survey experience

• Generate statistical and research reports (in aggregate, non-identifiable form)

• Ensure security and prevent service abuse

5. Legal Basis for Processing

The legal basis is the user’s implicit consent, expressed by voluntarily completing surveys and providing anonymous data. No identifiable personal data is processed that would require additional legal bases under the GDPR.

6. Data Retention

Anonymous survey data may be stored indefinitely for research and statistical purposes, as it does not qualify as personal data. Technical data, if collected, is retained for a maximum of 90 days, unless needed for security purposes.

7. Data Disclosure

Aggregated and anonymous data may be shared with:

• Research or commercial partners

• Service providers (e.g., cloud hosting, analytics tools) under strict security and anonymity standards

• No individual-level data is ever commercially exploited

8. International Data Transfers

Where data is processed on servers outside the EU, we ensure that service providers offer an adequate level of data protection (e.g., via adequacy decisions or standard contractual clauses).

9. User Rights

As no personal data is processed, the rights granted under the GDPR (e.g., access, correction, deletion, portability) are not applicable. For concerns or questions, users can contact us using the information provided below.

10. Policy Updates

Any updates to this Privacy Policy will be communicated through the app or official channels.

11. Contact

For any requests or questions, please contact:
📧 privacy@alesresearch.com