Privacy Notice

Sentro is software used by licensed Philippine financial advisers and their agencies to manage their client relationships. It is operated by LMI Automata Labs (DTI No. 8438501), Kentucky, Bambang, Taguig City, Metro Manila, Philippines 1630.

This notice explains what we do with personal data, and is given under the Data Privacy Act of 2012 (Republic Act No. 10173).

This distinction matters, and it decides who you should contact.

If you are an adviser or agency staff member, we are the personal information controller for your account. You deal with us directly.

If you are a client of an adviser, your adviser’s agency is the personal information controller. They decided to collect your data and they decide what happens to it. We are only a personal information processor: we hold and process it on their instructions and do not use it for our own purposes. To exercise your rights over that data, contact your adviser or their agency. We will help them respond, but we cannot act on their records without their instruction.

Advisers use Sentro to record the following about the people they serve. We hold this on the agency’s behalf.

Some of what advisers record is sensitive personal information under the Act — in particular health-related details, such as the critical illness, disability or hospital benefits attached to a policy, and anything an adviser notes or uploads about a person’s health.

The Act requires specific consent for this, given by the person concerned. Advisers are responsible for obtaining it, and Sentro records whether consent was given, when, and how it was captured.

Sentro runs on infrastructure located in Singapore (Southeast Asia), and email we send on your behalf is processed in Tokyo, Japan. Your data therefore leaves the Philippines. The Act permits this, and we remain accountable for it wherever it is held: the same protections in this notice apply, and our agreements with those providers require them to keep it secure.

• Connections are encrypted in transit (TLS).
• Passwords are never stored — only an argon2id hash of them.
• Access tokens for connected services, such as Google Calendar, are encrypted at rest.
• Every agency’s data is isolated from every other. Advisers see only their own clients; managers see their team’s; nobody sees another agency’s.
• Changes to records are written to an audit log recording who made them and when.
• Messages between an adviser and a client are private to the people in the conversation. Managers and agency administrators cannot read them.

We do not sell personal data, and we do not use it for advertising.

We use a small number of service providers who process data on our behalf and only on our instructions: a hosting provider, an email delivery provider for notifications and sign-in links, and — only where an adviser explicitly connects it — Google Calendar. A calendar connection is made by the adviser, for their own diary, and can be disconnected by them at any time. What we do with data that comes from Google is set out in full in the next section.

This section covers the data Sentro receives from Google, and is written to meet Google’s API Services User Data Policy.

What we access

• When you sign in with Google: your name, email address, profile picture and Google account ID.
• Only if you connect Google Calendar: the events on your main Google Calendar. Of each event we keep only its title, start and end time, location and Google’s event ID. Sentro does not read your list of calendars, your calendar sharing settings, your contacts, your email or anything else in your Google account.

How we use it

• Sign-in data identifies you, signs you in and shows your name and picture.
• Calendar data keeps your Sentro calendar and your Google Calendar in step. Appointments and to-dos you make in Sentro are added to, updated in and removed from your Google Calendar. Events you make in Google appear in your Sentro calendar, so your whole day is in one place and you are not booked twice. Events that last all day are skipped.
• We do not sell Google user data, use it for advertising, use it to build a profile of you, or use it to train artificial intelligence or machine-learning models. Nobody at Sentro reads it, unless you ask us to for support, it is needed to investigate abuse or a security problem, or the law requires it.

Who we share, transfer or disclose it to

Nobody outside Sentro, except the following.

• Our service providers, who handle it only on our instructions and only to run Sentro: Railway, which hosts the application and its database in Singapore (Southeast Asia); Resend, which delivers our email from Tokyo, Japan (your morning agenda email lists that day’s appointments, which can include events brought in from Google); and Cloudflare, which stores our off-site backups, encrypted before they leave our servers.
• People in your own agency, and only if you choose. Under “Who can see your calendar” you can share your calendar with your leaders or your team, showing either your busy times or the details. Events brought in from Google are part of your calendar, so they are shared the same way. If your agency turns on busy times for leaders, your leaders see when you are busy, never what the event is.
• When the law requires it, or where it is needed to protect someone’s safety or the security of Sentro.
• If Sentro is sold or merged, only after asking for your explicit consent.

How we protect it

It travels encrypted (TLS). The keys Google gives us to reach your calendar are stored encrypted (AES-256-GCM), and are used only by Sentro’s own servers. Your events are kept inside your agency’s records, which no other agency can see.

Keeping it, and deleting it

• Press Disconnect under Google Calendar on your Calendar page, or remove Sentro at myaccount.google.com/permissions. Disconnecting withdraws our access at Google and deletes the stored keys straight away, and syncing stops.
• Events already brought into Sentro stay in your calendar as your own appointments until you delete them, and events we added to your Google Calendar stay there until you delete them in Google.
• When your account is closed, its data is deleted as described under “How long we keep it”, and backup copies expire within 90 days.
• To have your Google user data deleted sooner, write to dpo@mysentroapp.com.

Sentro’s use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

For as long as the agency’s subscription is active and its records are needed for the advisory relationship. Insurance records commonly need to be kept for years after a policy ends, and the retention period is the agency’s decision as controller. When an agency leaves, we delete or return its data on request.

Deleting something removes it from Sentro straight away. An uploaded file is then kept, out of sight, for another 30 days so that a mistake can be undone, and copies held in our backups expire within 90 days. After that it is gone from our systems as well.

Under the Act you have the following rights.

To be informed

You may ask whether your personal data is held, and why.

To access

You may ask for a copy of the personal data held about you.

To object

You may object to processing, including direct marketing, at any time.

To correct

You may have inaccurate or incomplete data corrected.

To erasure or blocking

You may ask for data to be removed or withheld where it is unlawful, unnecessary, or you have withdrawn consent.

To data portability

Where processing is by consent or contract and is automated, you may obtain your data in a structured, commonly used electronic format.

To damages

You may claim compensation for damage caused by inaccurate, unlawfully obtained or unauthorised use of your personal data.

To complain

You may lodge a complaint with the National Privacy Commission.

To exercise any of these, write to dpo@mysentroapp.com. If you are a client of an adviser, contact your adviser’s agency first — they control your records.

If a personal data breach occurs that is likely to put anyone at risk, we notify the National Privacy Commission and the people affected within 72 hours of establishing it, as the Act requires. Where we hold the data as a processor, we notify the controlling agency immediately so they can meet that deadline.

Lawrence Magnaye Ignacio — dpo@mysentroapp.com

You may also complain directly to the National Privacy Commission at privacy.gov.ph.