Privacy Policy
This Privacy Policy (the “Privacy Policy”) describes our data protection process over the data obtained on the Platform and applies to Kéntro and the companies of its group, as data controllers. This Privacy Policy includes information about what data we collect, what data we process, the reason, the term and your rights as a data subject.
While creating an Account in Kéntro and using our Platform, in accordance with the Terms of Use for Users or the Terms and Conditions for Kéntrors, as applicable, you agree to this Privacy Policy. Moreover, you give your full and complete consent for Kéntro to collect your personal data and to use, transfer, store and assign it, in accordance with this Privacy Policy. Please read it carefully.
In some cases, we may send additional specific data privacy policies for certain services, practices or geographical regions which shall be complementary to this Privacy Policy.
We determine how we process your personal data, for what purposes and by what means.
Please note that our Platform may contain links to other third-party websites and by clicking on these links, you agree to do so. We are not responsible for the privacy practices of such other third-party websites.
Should you have any questions on data protection at Kéntro please contact us by email at: [email protected].
- Definitions
“Account” shall have the meaning ascribed in the Terms of Use for Users or the Terms of Use for Kéntrors, as applicable
“Penetration Test(s)” means the penetration tests performed by the Kéntrors via the Platform over the Users’ applications to test them against possible cyberattacks, as requested by the Users.
“Platform” means https://kentro.uk/
“Kéntro”, “we”, “us”, “our” means Kéntro Monperne LLC, a corporation duly organized and incorporated under the laws of United Kingdom, The Minster Building, Great Tower St, London EC3R 7AG,
“Kéntror(s)” means an individual who is a certified ethical hacker and uses the Platform to perform the Penetration Tests. The Kéntrors can use the Platform and perform the Penetration Tests if they are duly registered on Kéntro and comply with the requirements provided in the Terms of Use for Kéntrors.
“User(s)” means any individual or legal entity who accesses the Platform to request for Services. Users can use the Platform and engage Services if they are duly registered on Kéntro and comply with the requirements provided in the Terms of Use for Users.
“You” means the Kéntrors and the Users.
- Who we are?
Kéntro offers an online platform that connects Kéntrors willing to Perform Penetration Tests with Users who want to test their applications against cyberattacks and find out the vulnerabilities present at the exact moment they are discovered.
- What personal information we collect from you and for what reason?
Personal information is information that can identify you or even make you identifiable.
Information | Explanation |
Registration information | Information you enter to create your account in Kéntro such as, name, email address, password, telephone number, interests, demographic information, payment information (payment method, pseudonymized credit card information, bank account details). |
Device and access information | Device ID, device identification, operating system and corresponding version, time of access, configuration settings, information on Internet connection (IP address). |
Transactional Information | Information when you request or perform (as applicable) Penetration Tests such as: services specifications, amount of Penetration Tests requested or performed, etc. |
Communication | Information sent by you to the Stiker or the User, as applicable, or to Kéntro, via the communication channels made available on the Platform by Kéntro, provided that we are allowed by law to do so. |
Use of the Platform | We also collect data about your use of the Platform, including your login user, queries, comments and complaints you send us in relation to our business relationship. |
Other information | Information that you voluntarily provide to us while using the Platform and information from other sources such as social networks or applications that use our login interface or other public databases. |
You guarantee and are responsible, in any case, for the truthfulness, accuracy, validity and authenticity of the personal information provided, and undertake to keep it duly updated.
- How do we use your data?
We process your personal data when the purpose is lawful and you can reasonably expect it to be processed. If the processing of the personal data cannot be reasonably expected, we will collect your express consent.
Use | Explanation |
Providing the services | We use your information to provide, personalise, maintain and improve the services we offer to you and to carry out the following activities:
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Fraud prevention and security | We use your personal data to maintain the safety, security and integrity of Kéntro, our Platform, the Users and the Kéntrors. We also use the information to prevent fraud or any use of the Platform which is not in accordance with the law or the Terms of Use for Kéntrors or the Terms of Use for the Users. |
Product enhancement | We may use the information we collect to test, research, analyse and develop products. This allows us to improve in terms of security and to develop new features or services. |
Advertising and Marketing | We may use your information for advertising Kéntro or to send you offers or promotions that can be of your interest. You can opt out these communications. |
Support | We may use your personal information to resolve any complaint you present to us on the Platform. |
Prosecuting authorities and legal proceedings | We may use your personal information if we are required to do so by court order or administrative, regulatory, arbitral or judicial decision, and generally when required to do so by any governmental authority. |
- Disclosure of your personal data
In the ordinary course of our business we may need to disclose your information to third parties. Should that be the case we will do so in compliance with this Privacy Policy and applicable law.
5.1. Which third parties have access to personal data
- Companies of the Kéntro Group
In some cases we use our affiliates to provide some of the services so we can use our resources in a more efficient way. We may share data to our affiliates to perform the activities indicated in section 4 above.
- Kéntrors
We share strictly necessary data of the Users with the Kéntrors in order for them to perform the Penetration Tests in accordance with the Terms of Use for Users and the Terms of Use for Kéntrors.
- Users
We may share strictly necessary data of the Kéntrors who will perform the Penetration Tests to the Users so you can communicate within the performance of the Services.
- Service providers
Kéntro may provide information to its suppliers, consultants, marketing partners, research companies and other service providers or business partners. By way of example, Kéntro may provide information to:
- Payment processors and facilitators.
- Cloud storage providers.
- Marketing partners and marketing platform providers.
- Data analytics providers.
- Research providers, including those who implement studies or research projects in collaboration with or on behalf of Kéntro.
- Consultants and other professional service providers.
All of these service providers process your data in accordance with the applicable local requirements.
- Authorities
We may be obliged to disclose your personal information if requested by a competent authority or if needed to protect and defend our rights or your rights within the use of Kéntro.
- Others
Kéntro may share your information other than as described in this Privacy Policy if we notify you and you expressly agree to this.
- Merger or acquisition
By accepting the Privacy Policy, you acknowledge that in the event of a sale, merger, consolidation, change of corporate control, substantial transfer of assets, reorganization or liquidation of Kéntro, we may transfer, dispose of or assign your personal data to one or more relevant parties, including affiliates or third parties.
- To which countries we transfer your data
We process your data primarily within the USA, UK, Spain, Mexico, Colombia, Portugal, France and Uruguay. However, the use of our Platform and it’s content may imply the international transfer of your data to the countries where the Users, the Kéntrors or any of the third parties indicated in 5 above are located. In that case it may happen that the applicable regulation is not the same as the one where you are based. In any event, Kéntro will always use and protect the data as per this Privacy Policy.
- Your rights
You always have the right to choose what information you want to share with us. In some cases. some of the information is mandatory to enter into a relationship with us as otherwise you would not be able to use our Platform, for example, some of the information needed to create your Account.
If you want to disclose less information to us you can always block unnecessary cookies by setting this in your browser. This way you will avoid personalized advertising.
Also, you have the following rights which you can exercise at any time:
- Disclosure
You have the right to be informed which data we store about you and how we process this data.
- Correction
If you notice that stored data is incorrect, you can always ask us to correct it.
- Request deletion
You can ask us to erase or cease to use the data we have stored about you if the data has been used or acquired in violation of applicable laws, and you can also ask us to cease third party provision of the data we have stored about you if the third party provision is in violation of applicable laws.
- Cookies
A cookie consists of a small text file sent by a web server to a web browser, and stored by the browser in your device. The information is then sent back to the server whenever the browser requests a page from the server. This enables the server to identify and track the web browser.
There are different types of cookies which we use:
Session cookies
This helps us recognise you and the information you provided when using our Platform. Session cookies will be deleted from your device when you close your web browser.
Permanent cookies
We will use permanent cookies to enable our Platform to recognise you when you visit it. Permanent cookies will remain stored on your device until you delete them, or until they reach a specified expiry date.
Most web browsers allow you to refuse the acceptance of cookies. This is achieved through the settings of the particular browser. This will, however, have a negative impact on the usability of our Platform.
- How long we store your data
We will retain your data: (i) until we fulfil the reason why we collected it, including providing the Services, legal, accounting and reporting obligations, etc. (ii) for as long as you consented to it.
Your data will be deleted if you request so or if your account is inactive for 8 years.
However, we may be obliged to certain legal retention periods which shall be complied by us. Should that be the case, even if you request the deletion of your data, we may still need to store some of it due to legal requirements.
Additionally, we will continue to store your data if allowed by applicable local laws.
- Security of your personal data
All information collected on the Platform will be treated in compliance with the law and the data will be used only for the purposes consented to herein or those that you consent to in due course. Kéntro expresses its commitment to protect the security of your personal information. To that end, Kéntro uses a variety of security technologies and procedures to protect personal information from unauthorized access, use, modification or disclosure. However, data transmission over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet. Kéntro has no control over the privacy of communications while in transit to it. Therefore, we recommend that you do not include confidential, secret, compromising, sensitive data or sensitive personal information that you do not wish to disclose in these communications (including e-mails). You are also responsible for keeping your password and user details confidential.
- Minors
This Platform is not directed at minors, as we are very concerned about protecting their privacy. Therefore, we do not wish to collect any personally identifiable information from minors. If a minor has provided us with personally identifiable information, their parents and/or guardians should contact us at [email protected]. If we become aware that data of a minor (under the age of 18) has been provided to Kéntro, we will delete such information as soon as possible.
- Link to third party websites
The Platform may contain links to other websites beyond our control. Please remember that we have no control over these websites and that our Privacy Policy does not apply to these sites. We recommend that you read the privacy policies and terms and conditions of the linked or referenced websites that you access. Nothing in this Privacy Policy shall create or add any right or claim (whether legal, equitable or otherwise) that any individual or person may have at law, or otherwise, against Kéntro, any third party, or their respective directors, officers, delegates, employees, agents or representatives; nor shall the existence of this Privacy Policy or its application impose or add any obligation or liability on any of the foregoing that they do not currently have under the applicable law.
- Contacting us, questions and complaints
If you have any complaints, questions, comments or requests, please email us at [email protected]
- Modifications to our Privacy Policy
We reserve the right to change this Privacy Policy from time to time by uploading to our Platform an updated version and, where appropriate, notifying you by email. Please make sure you frequently review the Privacy Policy so you always are informed of the most updated version.