Privacy Policy

ENTRYSENTRY, INC.

This Privacy Policy is effective as of January 17, 2022. We at EntrySentry, Inc. (variously “we”, “us”, “our”, or “eSentry”) describe here the privacy practices for our application (the “App”), our website, and our services (together, the “Services”). Our Services are intended to facilitate contactless and easy sign-in and registration of open house visitors and prospective real estate purchasers which supports compliance with Covid-19 protocols by real estate agents.

In this Privacy Policy, we discuss the data we collect in connection with the Services, how we use it, the controls we give you over your information, and the measures we take to keep it safe.

1. LEGAL BASES FOR COLLECTING, PROCESSING, AND USING INFORMATION

Our legal bases for collecting, processing, and using information from you in connection with the Services are as follows:

(a) CONSENT

Your use of the App, or your use of our website, or your opening of an account with us, or your use of any of our Services, constitutes your legal consent to collection, processing, and use of information by us in accordance with this Privacy Policy under US law, the GDPR, the CCPA, or any other applicable law in your jurisdiction.

(b) NECESSITY

Collection and use of information by us in accordance with this Privacy Policy is necessary for these purposes:

proper functioning of the App and the website; opening of an account;
use of an account;
logging onto and use of the App;
logging onto and use of our website; and any other use of the Services.

2 INFORMATION WE COLLECT

When you use our Services, we collect the following types of information.
(a) INFORMATION YOU PROVIDE US

Account Information
Some information is required to create an account on our Services and to use such Services, such as your name, mobile telephone number, password, email address, and residential address, among other types of information that we may request from time to time. You may also choose to provide other types of information related to any other Services we may provide in the future.

Personally Identifiable Information (PII)
We collect names, email addresses, phone numbers, and zip codes from users who are using the App for the purpose of entering an open house in compliance with applicable Covid-19 protocols. We also collect your email address if you contact us by email. All of the foregoing information may identify you and is therefore Personally Identifiable Information (“PII”).

Payment and Card Information
If you purchase paid Services, you provide your payment information, including your name, credit or debit card number or PayPal account information, card expiration date, CVV code, and billing address. Such information is tied to your account.

Covid-19 Related Health Information; Inapplicability of HIPAA
We require users of the App to state whether, to the best of their knowledge, they are infected with Covid-19 or have been in contact within the past 10 days with an individual who has been afflicted with Covid 19. We also require users to state whether they are or are not experiencing symptoms of Covid-19, including fever, coughing, shortness of breath, or other symptoms.

For greater certainty, neither we, nor the Services, nor any information you provide to us are covered by the Health Insurance Portability and Accountability Act (“HIPAA”). HIPAA applies only to “Covered Entities” as defined therein. We are not a “Covered Entity” as defined by HIPAA as we do not provide health care, health insurance, or billing services for health care purposes. Accordingly, the standards governing the privacy of information are as described in this Privacy Policy and applicable law.

Additional Information
To help improve your experience or enable certain features of the Services, you may choose to provide us with additional information, such as access to your contact list on your mobile device. If you choose to connect your account on our Services to your account on another service, we may receive information from the other service.

(b) INFORMATION WE RECEIVE FROM YOUR USE OF OUR SERVICES

We also collect data about the devices you use to access the Services, including IP addresses, email addresses, mobile phone numbers and other identifiers, browser type, language, operating system, referring web pages, pages visited, location, and cookie information. among other sources of data collection. Such information may be transferred to our servers which may be operated by third parties.

3. HOW WE USE INFORMATION

We use the information we collect to provide, improve, and develop our Services.

(a) PROVIDING, IMPROVING, AND DEVELOPING SERVICES

We deliver the Services, improve them, and may research and develop new ones using the information we collect. For example, we may use the information to do the following:

provide you with the Services you request;
track usage trends;
provide customer support;
troubleshoot and protect against errors;
perform data analysis and testing; and
develop new features and Services

COMMUNICATING WITH YOU

(b) We also use your PII to respond to you when you contact us.

We use the information we collect to promote the safety and security of the Services, our users, and other parties. For example, we may use the information to authenticate users, facilitate secure payments, protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce our terms and policies.

(d) INFERENCES

We may draw inferences from any of the information received from you in connection with the Services and this Privacy Policy.

(e) NO STORAGE OF PII COLLECTED FROM THE APP

We do not store PII collected from a user of the App on any mobile device or server.

4. HOW INFORMATION IS SHARED

We do not share your information, including your PII, except in the limited circumstances described below.

(a) WITH REAL ESTATE AGENTS RESPONSIBLE FOR AN OPEN HOUSE

PII collected through the App will be shared with the real estate agent who is responsible for the open house for which the App is used. The real estate agent may use such PII to contact you to follow up on your interest in purchasing real property and lead generation.

(b) FOR EXTERNAL PROCESSING
A list of processors and the data processed by them includes the following as of the date of this

Privacy Policy is listed on Exhibit A at the end of this Privacy Policy. The processors are located variously in the United States, or elsewhere. We may engage the services of other similar third- party processors or process other types of data from time to time at our discretion to maintain and enhance the quality of the Services.

We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of the Services or the physical safety of any person.

We will notify you of legal process seeking access to your information, such as search warrants, court orders, or subpoenas, unless we are prohibited by law from doing so. In cases where a court order specifies a non-disclosure period, we provide delayed notice after the expiration of the non- disclosure period. Exceptions to notifying you include exigent or counterproductive circumstances, for example, when there is an emergency involving a danger of death or serious physical injury to a person.

5. HOW TO ACCESS OR DELETE YOUR PERSONAL INFORMATION

You may contact us at hello@entrysentry.com to inquire on the status of any PII that may be in our possession or control and to request that such PII be deleted. Please note that it may take a bit of time to delete your PII, and we may preserve it for legal reasons or to prevent harm, including as described in Section 4, “How Information Is Shared”.

We may delete accounts and their related PII that have been inactive for extended periods of time after the last account activity.

6. ANALYTICS AND ADVERTISING SERVICES PROVIDED BY OTHERS

We work with Google Analytics which provides us with analytics and advertising services in connection with our website. This includes helping us understand how users interact with the Services, serving ads on our behalf across the internet, and measuring the performance of those ads, all of which helps us with continuous improvement of the Services.

To prevent your data from being used by Google Analytics, you can install Google’s opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

7. INFORMATION SECURITY

We use a combination of technical, administrative, and physical controls to maintain the security of your data. No method of transmitting or storing data is completely secure, however. If you have a security-related concern, please contact us at hello@esentry.com.

8. EUROPEAN PRIVACY DISCLOSURES

If you live in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, or are a citizen, national, or permanent resident of the European Union, please review these additional privacy disclosures under the European Union’s General Data Protection Regulation (“GDPR”).

eSentry, Inc. is a corporation organized under the laws of the State of Delaware, United States of America, and is a “Controller” for the purposes of Regulation (EU) 2016/679 (General Data Protection Regulation) (“GDPR”). Please see the end of this Privacy Policy for our contact information.

We recognize the potentially sensitive nature of PII and information provided on the App as it may constitute “personal data” in connection with your health for purposes of Article 9 of the GDPR. Permission to process such “personal data” is provided under Article 9, Sections 2(a), 2(b), 2(g), and 2(i).

We may transfer information to our corporate affiliates, service providers, and other partners that process it for us based on our instructions, all of which are “Processors” for purposes of the GDPR. Such processors must act in compliance with this Privacy Policy, applicable law, and any other appropriate confidentiality and security measures.

As of the date of this Privacy Policy, we do not have a Data Protection Officer for purposes of Article 37 of the GDPR as we do not conduct regular and systematic monitoring users on a large scale or process any special categories of PII on a large scale.

(b) LEGAL BASES FOR PROCESSING PERSONAL DATA

For personal data subject to the GDPR, we rely on several legal bases for processing data each of which are described in Section 1.

Under the GDPR, you have a general right to object to the use of your information for direct marketing purposes. Please see Section 5 above for information on how to exercise your rights under the GDPR to access and control your personal data and marketing communications.

If you need further assistance regarding your rights, please contact us per the information in Section 11 and we will consider your request in accordance with applicable laws. You also have a right to lodge a complaint with your local data protection authority under the laws applicable thereto.

9. CALIFORNIA PRIVACY DISCLOSURES

If you are a California resident, please review the following additional privacy disclosures under the California Consumer Privacy Act (“CCPA”).

(a) HOW TO EXERCISE YOUR LEGAL RIGHTS UNDER THE CCPA

You have the right to understand how we collect, use, and disclose your PII, to access your PII, to request that we delete certain information, and to not be discriminated against for exercising your privacy rights. You may exercise these rights by contacting us at hello@entrysentry.com.

If you need further assistance regarding your rights, please contact us per the information in Section 11 and we will consider your request in accordance with applicable laws.

(b) TYPES OF INFORMATION WE COLLECT, USE, AND DISCLOSE FOR BUSINESS PURPOSES

We collect the types of information listed in Section 2 and in the table in Exhibit A. We receive this information from you, your device, your use of the Services, third parties (including social media accounts linked to your account), and as otherwise described in this policy. We use and disclose these types of information for the business purposes described in Sections 3 and 4.

10. CHANGES TO THIS PRIVACY POLICY

We will notify you before we make material changes to this Privacy Policy and give you an opportunity to review the revised Privacy Policy before deciding if you would like to continue to use the Services.

11. HOW TO CONTACT US

If you have questions about this Privacy Policy, or about our use of your information, please contact us at hello@esentry.net

EXHIBIT A

THIRD-PARTY PROCESSORS

Third-Party Processor / Google Analytics

Purpose of Data Processing / analytics regarding usage

Types of Data Processed:

● IP addresses

● timestamps for website visits

● referring websites

● geographic location

Third-Party Processor / Stripe

Purpose of Data Processing / payment processing

Types of Data Processed:

● name

● email address

● phone number

● IP address

● shipping address

● billing address

● payment card

● information from cookies, stored temporarily