Privacy notice

1Who is responsible for your personal data?

This English version is provided for convenience; in case of any discrepancy, the Spanish version prevails.

Enrique Garza Cantu, an individual doing business under the trade name Sentinela, who offers the Sentinela PTT service (push-to-talk radio over the internet), located at Río Álamo No. 329, Col. San Francisco, ZIP 87350, H. Matamoros, Tamaulipas, Mexico («Sentinela»), is responsible for processing the personal data described in this notice, in accordance with Mexico's Federal Law on the Protection of Personal Data Held by Private Parties (LFPDPPP) and other applicable regulations.

Privacy contact: [email protected] · phone +52 868 822 5875 · Monday to Friday 9:00 a.m. to 6:00 p.m. and Saturday 9:00 a.m. to 1:00 p.m. (Central Time, Mexico).

2Two kinds of data, two different roles

Sentinela PTT involves two groups of people, and our role is different for each one:

3What personal data do we process?

About you, as the customer

• Identification and contact: name or company name, representative's name, phone, email and address.
• Tax data (customers in Mexico): RFC, tax regime, tax ZIP code and CFDI use, to issue invoices.
• Payment: references, receipts, payment history and outstanding balances. Sentinela does not store full card numbers: when you pay online, that data is captured directly by the payment processor.
• Communications: the messages you send us by WhatsApp, email or phone.
• Free trial sign-up: name, company, mobile phone, email, city, industry and how many people would use the radio, to send you the trial access, follow up and offer you the service. If you do not subscribe, you can ask us to delete it.
• Browsing this website: only technical cookies needed for it to work. We do not use advertising cookies.

About the radio users (on your behalf)

• Radio account: the name or alias you give each user (for example, «Guard 1»), their username and access key, and the channels they belong to.
• Technical connection data: connection and disconnection times, IP address and app version, to provide the service and protect it from unauthorized access.
• Voice: what each user transmits over the radio travels in real time to the other people on their channel. In the Radio plan, voice is not recorded.
• Location and work status (all plans): the phone's location (coordinates, accuracy and time) only while the user has their shift active in the app; the work status they select (available, on the way or on a job), and the alerts of the emergency button (SOS), which include the location. Other users of your company's radio can see this information in the app.
• Only if you subscribe to the Radio + Map plan: the recording of what is said on the channels and its transcription to text, and the location history shown on your computer dashboard.

We do not request sensitive personal data. Sentinela PTT is not intended for minors.

4What do we use the data for?

Purposes required for the service

1. Subscribing, activating, providing and supporting the Sentinela PTT service: creating your company's dedicated radio server and your users' accounts, and delivering the QR access codes.
2. Transmitting voice among users of the same channel; showing in the app the location and work status of users on shift; sending emergency (SOS) alerts to your team and, if you subscribe to it, showing your dashboard and storing and transcribing recordings.
3. Activating your free trial, emailing you the information and access, and following up to learn whether you wish to subscribe.
4. Billing, collecting payments, issuing tax receipts (CFDI, for customers in Mexico), applying payments and following up on balances, including suspending and reactivating the service as agreed.
5. Answering your messages, questions, reports and complaints, and sending you service notices (outages, maintenance and payment due dates).
6. Keeping the service secure and reliable: detecting failures, unauthorized access and abuse.
7. Complying with legal and tax obligations and with requests from competent authorities.

Additional purposes (you may opt out)

8. Sending you promotions, satisfaction surveys and information about new services.

If you do not want us to use your data for purpose 8, email the address in section 1 with the subject «No advertising». Opting out does not affect the service you have subscribed to.

What we never do: Sentinela does not listen to your radio conversations, does not use your users' voice, location or recordings for its own purposes, and does not sell or share them for commercial or advertising purposes. We only access them when you ask us in writing (for example, to retrieve a recording) or when a competent authority orders it under the law.

Automated assistance with artificial intelligence. Some messages you send us by WhatsApp or through the chat on this website are answered first by SentiBot, our virtual assistant. To understand and answer your message, the text (and the audio, if you send a voice note) is processed by an artificial intelligence service from a technology provider, acting on Sentinela's behalf and only for that purpose. SentiBot does not make decisions about your contract, payments or data, and you can ask to be served by a person at any time. This does not apply to your radio's voice: recordings and their transcription are processed on Sentinela's servers.

5Who do we share the data with?

Providers that process data on our behalf (processors), only for the purposes in this notice:

• Messaging platforms: Meta (WhatsApp).
• SentiBot's artificial intelligence provider (only for the messages you send us, not for your radio's voice).
• The CFDI certification provider (PAC) that stamps invoices for customers in Mexico.
• Banks and payment processors (Stripe and Mercado Pago). When you pay by card, they receive the card data directly.
• Technology infrastructure providers (internet links, domain names and IT security).

The radio servers, recordings and your users' location are hosted on Sentinela's servers in Mexico.

Transfers that do not require your consent, as permitted by law:

• To Mexico's Tax Administration Service (SAT), to issue and validate tax receipts.
• To competent authorities that require them under the law.

We do not sell or rent personal data.

6Your radio users' data: your responsibilities

When you add a person to your radio, you decide which data is processed and for what. As the controller of that data, it is your responsibility to:

• Inform each user, before adding them, that their voice is transmitted over the company radio; that their location is shared with the team while their shift is active in the app; and, if you subscribed to the Radio + Map plan, that channel conversations are recorded. At the end of the Spanish version of this notice we provide a template notice you can adapt.
• Use the radio for work purposes only and in accordance with the law, including labor law.
• Handle your users' requests about their data. If we receive one, we will forward it to you and help you answer it.
• Remove anyone who should no longer use the radio. Their QR code stops working immediately.

Sentinela, as your processor, undertakes to process that data only according to your instructions and to provide the service, to keep it protected, to keep it confidential and not to share it except with the providers in section 5 or by order of a competent authority.

How location works: it is shared only while the user has their shift active in the app; outside of the shift nothing is sent. While it is shared, the phone shows a persistent notification, so the user always knows when it is active.

7How long do we keep the data?

• Channel recordings, their transcription and location history (Radio + Map plan): 90 days, after which they are deleted automatically.
• Technical connection data: 90 days.
• Radio user accounts: for as long as you keep them active. When you remove a user, their account is deleted.
• When the service ends: your company's radio server is deleted together with all its accounts, recordings and locations.
• Your data as a customer: for the duration of the service relationship and afterwards only as long as needed to meet legal obligations; for example, tax and accounting information is kept for the periods required by tax law. When those periods end, the data is blocked and then deleted.

8Your rights: access, rectification, cancellation and objection (ARCO)

You can find out what data we hold, correct it, ask us to delete it or object to its use for specific purposes. You can also revoke your consent and limit the use or disclosure of your data.

Send your request to [email protected] including:

• Your name and a way to reply to you.
• An official ID (or, if you act on behalf of someone else, the document proving that representation).
• A clear description of the data and the right you wish to exercise.
• Any document that helps locate your data (for example, your contract number).

We will reply within 20 business days at most and, if applicable, carry it out within the following 15 business days. Some data cannot be deleted while there is a legal or contractual obligation to keep it (for example, invoicing or an outstanding balance).

If you are a user of a company's radio, send your request to the company that added you. If you write to us, we will forward it to that company and help it respond.

If you believe your right to data protection has been violated, you may contact the Mexican personal data protection authority (Secretaría Anticorrupción y Buen Gobierno).

9Changes to this notice

If we change this notice, we will publish the new version at https://sentinelaptt.com/en/privacy (and the Spanish version at https://sentinelaptt.com/privacidad), with the date of the last update. If the change is significant, we will also let you know through the contact details we have on file.

For Sentinela's other services (alarms, internet, GPS tracking and online store) see sentinela.mx/privacidad (in Spanish).