Draft for review — this policy has not been reviewed by legal counsel. Do not treat it as a final published document.
Privacy Policy
SENTINEL by ST NUBIAN · Last updated 2 September 2026
1. Who this policy applies to
This policy applies to (a) visitors to this website, and (b) the personal information Sentinel processes on behalf of its customers, the debt collection agencies that use the product. For agency data, the agency is the responsible party under POPIA and Sentinel is the operator; this policy describes our operator role, which is set out in full in the operator agreement signed with each agency.
2. Personal information we process as an operator
Under each agency’s instructions we process: call recordings and their metadata (agent, dialler, date and time); transcriptions of those recordings; compliance findings derived from them; and the personal information of debtors and agents that appears in the recordings, including names, identity numbers, account references and amounts, only to the extent present in the audio.
The purposes are limited to producing the compliance analysis the agency commissioned: transcription, scoring against the agency’s rubric, and the evidence anchoring of findings. We do not use this data to build profiles of individuals, for marketing, or to train or improve any model.
3. Website data
When you visit this site or request a demo, we process the information you give us — name, email address, agency name, and the contents of your message — to respond to your enquiry. The demo form opens a pre-filled email in your own mail client; the message is transmitted by your mail provider, not by a form on this site.
This website uses cookie-less usage analytics (Vercel Analytics, processed by Vercel outside South Africa) to understand which pages are visited. It does not use advertising cookies or cross-site trackers.
4. Grounds for processing
For agency data, processing is carried out on the agency’s instructions as its operator, for the agency’s lawful grounds of compliance monitoring and quality assurance. For website enquiries, processing serves to respond to your request and, where you proceed, to take steps toward a contract with your agency.
5. Disclosure
We do not sell personal information. We disclose it only to: the agency that owns it; sub-processors that host or transmit data on our behalf under written contracts with equivalent safeguards; and authorities where the law requires it.
6. Storage, security and retention
Recordings, transcriptions and findings are encrypted in transit and at rest. Access is role-based and least-privilege, with agent-level restrictions. Retention follows the agency’s policy as recorded in the operator agreement; data is deleted when retention expires, and returned or destroyed when the agreement ends.
Website enquiry data is kept only as long as needed to handle the enquiry and, if it leads to a contract, the resulting relationship.
7. Cross-border transfer
Recordings and their derived data are stored with our cloud hosting and database providers, and transcription and scoring are performed by hosted AI inference services, some of which are hosted outside South Africa. Personal information therefore leaves South Africa in transit. The sub-processors and their hosting locations are set out in the operator agreement, which the agency reviews before signing.
8. Your rights as a data subject
Data subjects may request access to, correction or deletion of their personal information, object to processing, or lodge a complaint with the Information Regulator. Requests concerning data processed on behalf of an agency should be directed to that agency as the responsible party. Requests concerning this website, and any request where we are the responsible party, may be sent to the Information Officer at demo@sentinel.novosense.africa.
9. Changes to this policy
Material changes will be posted on this page with a revised date. Where a change affects how agency data is processed, it is handled through the operator agreement, not unilaterally through this page.