Effective Date: 2025-03-05
Privacy Policy
• Our website
• Professional advisory services
• Client and stakeholder communications
• Business development and collaboration activities
Sentivery (“Sentivery”, “we”, “us”, “our”) is committed to protecting personal data in accordance with applicable data protection legislation, including the EU General Data Protection Regulation (GDPR) (EU) 2016/679 and relevant Lithuanian data protection laws.
1. Introduction
This Privacy Policy explains how we collect, use, disclose and protect personal data in connection with:
Sentivery
Last Updated: 2026-02-21
Sentivery operates as an independent advisory practice providing delivery governance and programme coordination services.
2. Data Controller
For the purposes of GDPR, the Data Controller is:
MB Cosmic Fabric
Sentivery
If you have questions regarding this Privacy Policy or your personal data, please contact us at the above email address.
Registered in Lithuania
Website: www.sentivery.com
Email: enquiries@sentivery.com
3. Types of Personal Data We Collect
We collect only data necessary for professional engagement and legitimate business operations.
This may include:
3.1 Identification & Contact Data
• Name
• Professional title
• Company / organisation name
• Email address
• Telephone number
• Business address
3.2 Professional & Business Information
• Role within organisation
• Project involvement details
• Engagement communications
• Contractual information
3.3 Website Data
• IP address
• Browser type
• Device information
• Website usage data (via analytics tools, if implemented)
We do not knowingly collect special category data unless strictly required and contractually justified.
4. How We Collect Data
Personal data may be collected through:
• Direct email correspondence
• Website contact forms
• Professional networking platforms (e.g., LinkedIn)
• Contractual engagement processes
• Business meetings and events
• Referrals and introductions
5. Lawful Basis for Processing
We process personal data under one or more of the following lawful bases:
• Contractual necessity – to perform or prepare for professional services
• Legitimate interest – business development, professional communication, advisory delivery
• Legal obligation – regulatory, tax, or accounting compliance
• Consent – where explicitly required (e.g., optional communications)
6. Purpose of Processing
We process personal data strictly for legitimate professional purposes, including:
• Delivery of advisory and governance services
• Contract negotiation and execution
• Project coordination and stakeholder communication
• Compliance with legal and regulatory obligations
• Maintaining professional relationships
• Business development and strategic partnerships
• Website functionality and security monitoring
We do not use personal data for automated decision-making or profiling.
7. Data Sharing & Disclosure
We may share personal data only when necessary and proportionate, including:
• Professional advisors (legal, accounting)
• IT and secure hosting providers
• Project partners (under confidentiality agreements)
• Regulatory authorities (if legally required)
We do not sell personal data.
All third parties engaged are required to maintain appropriate confidentiality and security standards.
8. International Transfers
Where personal data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, such as:
• Standard Contractual Clauses (SCCs)
• Adequacy decisions by the European Commission
• Project partners (under confidentiality agreements)
• Contractual confidentiality and security commitments
9. Data Retention
We retain personal data only as long as necessary for:
• Contractual obligations
• Legal and regulatory compliance
• Professional record keeping
• Legitimate business interests
Retention periods vary depending on the nature of engagement but typically align with statutory limitation periods and accounting requirements under Lithuanian law.
10. Data Security
Sentivery applies appropriate technical and organisational measures to protect personal data, including:
• Secure email and encrypted communications (where applicable)
• Access control and device protection
• Confidentiality obligations
• Secure hosting environments
• Data minimisation practices
We apply a risk-based approach consistent with the scale and sensitivity of our advisory activities.
11. Your Rights Under GDPR
Where applicable, you have the right to:
• Access your personal data
• Rectify inaccurate data
• Request erasure (“right to be forgotten”)
• Restrict processing
• Object to processing
Requests may be submitted via email at: enquiries@sentivery.com
• Request data portability
• Withdraw consent (where processing is based on consent)
We will respond within the timeframe required under GDPR.
12. Cookies & Website Analytics
Our website may use limited technical cookies necessary for functionality.
If analytics tools are implemented, they will be configured to:
• Minimise personal data collection
• Anonymise IP addresses where possible
• Comply with GDPR requirements
A separate Cookie Notice may be provided where required.
13. Confidentiality & Professional Integrity
As an independent advisory practice, Sentivery operates under strict professional confidentiality principles.
Information obtained during client engagements is treated as confidential and handled in accordance with contractual obligations and applicable law.
14. Complaints
If you believe your data protection rights have been violated, you have the right to lodge a complaint with:
State Data Protection Inspectorate of Lithuania
We encourage individuals to contact us first so we may address concerns directly.
15. Updates to This Policy
We may update this Privacy Policy periodically to reflect:
• Legal changes
• Operational adjustments
• Regulatory developments
The updated version will be published on our website with a revised effective date.
For questions regarding Privacy Policy or formal contracting matters, please contact:
© 2026 Sentivery