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The Privacy Policy below governs your Sentenial account and any information you provide to Sentenial.

1.  General

1.1.  Sentenial

Sentenial Ltd. a company registered in Ireland and based at Unit 16F, Maynooth Business Campus, Maynooth, Co. Kildare, Ireland, Eircode: W23DD86

Sentenial provides a range of payment and related services to organisations based within the EEA and the UK. Regulated payment services are provided by its Nuapay subsidiaries based in London and Paris.

1.2.  Sentenial Data Handling

All data processing carried out by Sentenial is compliant with the EU 2016-679 regulation known as the General Data Protection Regulation, GDPR and any successors thereof.

For data relating to individuals within or associated with a customer of Sentenial, Sentenial acts as the data controller within the terms of the above-mentioned regulations.

Where data relates to individual clients of the customer, the customer acts as the data controller and Sentenial acts as the data processor.

1.3.  What Sentenial does with data

Sentenial requires access to personnel data for a variety of purposes as below:

  • Delivering the range of Sentenial Services
  • Assisting with the support of Sentenial Services
  • Maintain high levels of security within the Sentenial environment
  • To protect Sentenial and our customers from the risk of fraud or financial loss
  • To enable Sentenial to meet its regulatory and legal obligations

Sentenial collects and stores the minimum amount of data required to achieve the above objectives. The required data is defined by the scheme rules relating to services being requested or by the various regulations covering the prevention of money laundering, terrorist financing and financial crime.  Data is held for the minimum period required by the regulations under which Sentenial operates.

1.4.  Data Storage.

Sentenial stores data at its various data centres which are based within either within the European Economic Area or within the UK. Sentenial neither stores nor transfers any personal data outside of the European Economic Area or the UK. The data processing carried out by Sentenial is certified as being compliant with ISO 27001.

1.5.  Data Access.

Access to all personnel data held by Sentenial is available strictly on a need-to-know basis, data is only made available to personnel who require the data to provide the various Sentenial services requested by the customer.

All Sentenial personnel accessing data are security screened and undergo regular training on matters relating to data security and privacy.

1.6.  Data Sharing. 

Sentenial may share personal data with other companies within the EML group of companies. Such transfers are carried out under strict contractual control and such transfers are only used where strictly necessary for the provision of the services requested by the customer.

To fulfil the requirements of its licence, Sentenial may pass data relating to individuals associated with a customer to external service providers for the purpose of confirming identity. Data may also be shared with external organisations such as a credit bureau, such transfers are only used where strictly necessary for Sentenial to meet its regulatory requirements.

Sentenial may, from time to time, be subject to requests to share data with government, regulators or law enforcement bodies to meet obligations under law. Should such a request be received by Sentenial, when possible, the customer will be informed of the nature of the request.

Sentenial does not sell or rent any data stored to third parties for any purpose. Personnel data is not used for any purpose other than for the provision of the services requested by the customer.

2.  Customer Details

Sentenial is required to hold detail of the representatives of the customer that have permission to access the Sentenial platform as well as details of various individuals within the customer’s organisation. Such information is required to enable Sentenial to securely deliver services to the customer as well as being required to meet regulatory requirements.

When dealing with this data Sentenial acts as the data controller.

2.1.  Data held

The information collected may include: –

  • Name
  • Telephone number
  • Email address

In addition to the above, Sentenial has a statutory duty to carry out identity checks on various members of customer organisation. The data collected in this respect is dependent on the structure of the organisation and may include data relating to the beneficial owners, senior management and those individuals authorised to instruct Sentenial to carry out financial transactions. Such information may include the following: –

  • Name
  • Address
  • Date and place of birth
  • A Government issued identity document.

All such information held is periodically refreshed as required by legislation.

2.2.  Data Retention. 

Sentenial is obliged to retain details of some elements of the data collected for a period defined by the appropriate regulations. Typically, specified data will be held for a period of 5 years following termination of any agreement between the customer and Sentenial.

2.3.  Customer rights. 

Individuals have the right to see data held by Sentenial about them. Copies of all data held is available from the Sentenial Customer Support team who can also correct any errors contained there within.

Individuals can request, via the Sentenial Customer Support team, to have their details removed from the Sentenial platform. Such requests will be processed immediately where this can be carried out legally.

3.  Customer’s Clients

To enable Sentenial to carry out instructions issued by a customer, the customer must provide and manage data within the Sentenial platform. With all such data the customer acts as the data controller and Sentenial acts as the data processor.

3.1.  Data held. 

To process payments and associated instructions customers must provide Sentenial with sufficient information to enable a transaction to be completed. The data required varies with the type and geographical location of the transaction, below lists the elements relating to the client that may be required.

  • Name
  • Bank account details
  • Address
  • Email address

3.2.  Data retention. 

The treatment of data relating to financial transactions is subject to financial crime law. Such regulations, amongst other things, define how long Sentenial must keep copies of the data. Data is automatically deleted at the end of the statutory period.

3.3.  Client rights. 

Clients have a right to view data held about them and to have this corrected if wrong. The management of this process is the responsibility of the customer and tools are provided to the customer to support this requirement. Sentenial provides no mechanism for customer’s clients to directly request details of data held about them from Sentenial.

It should be noted that the financial crime legislation will usually override client rights as given in data privacy laws.

Privacy Policy

Sentenial reserves the right in its sole discretion to amend this privacy statement at any time, and you should regularly check this privacy statement for any amendments.
We will post the amended Privacy Policy prominently on our Website so that you can always review what information we gather, how we might use that information, and whether we will disclose it to anyone. Please check the Sentenial website ( at any time for the most current version of our Privacy Policy.