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Who are we?
TransPerfect Global, Inc. and its affiliates and subsidiaries (collectively, “TransPerfect”) may be a “data controller” of your personal data, which means that TransPerfect has control of your personal data and may utilize it for various purposes, including sending your information to “data processors” we work with. Alternatively, depending on who you are and our relationship to you, TransPerfect may be a “data processor” or a “sub-processor” of your personal data.
Your personal data – what is it?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or which is likely to come into such possession. The processing of personal data of European citizens or residents (“EU Personal Data”) is governed by the EU General Data Protection Regulation (referred to herein as the “GDPR”).
How do we process your personal data?
TransPerfect complies with its obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorized access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
The personal data that you provide (or have previously provided) to TransPerfect may be stored in TransPerfect’s data center in the United States. For details concerning the purposes and locations with respect to which we process your personal data, please utilize the applicable link above under “Scope.”
Why are we collecting your personal data?
For details concerning the purposes with respect to which we process your personal data, please utilize the applicable link above under “Scope.”
What is the legal basis for processing your personal data?
For details concerning the legal bases with respect to which we process your personal data, please utilize the applicable link above under “Scope.”
Sharing your personal data
For details concerning third parties with whom we may share your personal data, please utilize the applicable link above under “Scope.”
How long do we keep your personal data?
We will keep your personal data for no longer than reasonably necessary for our ongoing business relationship and for record keeping purposes and in case of any legal claims or complaints.
Onward Transfers and Transfer of Data Abroad
As part of its overall global privacy compliance efforts, TransPerfect has elected to adhere to enforcing the EU Standard Contractual Clauses (Processors) and the Privacy Shields concerning the transfer of personal identifiable data from the European Union to the United States of America, including adhering to the requirements effective under the General Data Protection Regulation (GDPR).
The term "processing" of personal data includes any operation or set of operations performed upon personal data such as collecting, storing, retrieving, consulting, using, disclosing, disseminating, and otherwise making available the personal data.
TransPerfect's privacy practices are self-certified and reflect current guidance concerning the optimal manner of reaching data privacy compliance in accordance with current legal and regulatory guidance.
Cookies and Website Privacy Practices
When any clients visit TransPerfect's website, TransPerfect does not track Personal Data, names or email addresses. Instead, TransPerfect only tracks which Internet Service Provider has accessed the site as well as statistics that show the number of site visitors, those requests received and the country origin of those requests. This information is used to improve our site in order to better serve our clients, but this information does not constitute Personal Data.
TransPerfect's cookie provider is a member of the Network Advertising Initiative (NAI) and adheres to the NAI Codes of Conduct. You may use the NAI opt out tool here, which will allow you to opt out of seeing targeted ads from us and from other NAI approved member companies.
Further, if you want to opt out of receiving communications from us, please visit TransPerfect’s Opt-Out Portal. If you opt-out, you will not be able to receive further communications about business opportunities or services and you will no longer be able to access applications within TransPerfect’s technology suite.
Your rights and your personal data
If you are an EU citizen or resident, your rights under the GDPR include the following (unless subject to an exemption):
- The right to request a copy of your personal data which TransPerfect holds about you
- The right to request that TransPerfect corrects any personal data if it is found to be inaccurate or out of date
- The right to request your personal data is erased where it is no longer necessary for TransPerfect to retain such data
- The right to withdraw your consent to the processing at any time
- The right to request that TransPerfect provide you, as the data subject, with your personal data and where possible, to transmit that data directly to another data controller
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing
- The right to lodge a complaint with governmental agencies or Data Protection Authorities as provided for in the GDPR.
To exercise your rights to data rectification, erasure, portability, access and/or restricted processing, please email email@example.com.
Notice – TransPerfect treats all material sent to us from our clients, vendors, and employees (collectively, "CVEs") as confidential in accordance with its current confidentiality undertakings with CVEs. Confidentiality provisions are required as part of all of our contracts with all of our clients vendors and employees; each separate entity must sign a confidentiality agreement prior to becoming affiliated or working with TransPerfect.
All emails sent to TransPerfect (globally) are routed through a third party SPAM filter (AppRiver) which is located in the United States. This means all email correspondence originated outside of the United States with an end destination other than the United States still must travel through the United States before arrival at the desired location.
TransPerfect utilizes a network of over 4,000 freelance vendors to assist in the process of translation. They may receive, as part of the assignment, the name of the client they are working on but no Personal Data about that client, unless such contact information is needed to perform the assignment (such as the cases of onsite interpretation projects, onsite document review, etc.). These freelance vendors may also have access to any Personal Data within the source documents and reference material sent to them for translation. However, in all cases, the freelance vendors will be subject to confidentiality undertakings in which such freelance vendors undertake to keep such information confidential and only use such information in accordance with their projects.
All vendors who will be processing Personal Data of EU citizens or residents are required to sign the EU Data Protection Agreement and EU Standard Contractual Clauses. These documents address common requirements concerning Notice, Choice, Onward Transfer, Access, Security, Data Integrity and Enforcement of the Personal Data with respect to the Personal Data. Any EU vendor has the right to terminate its working relationship with TransPerfect and request the deletion of Personal Data pertaining to them. However, as permitted by applicable law, TransPerfect will continue to maintain its historical business records in such a way so that TransPerfect may retain its historical knowledge and relationships concerning any legal or regulatory inquiries which may later arise. This practice is in the best interests of both parties so that identifying information relating to a particular matter is accessible but sufficiently discrete so that TransPerfect does not accidentally contact them for projects in the future.
Choice – TransPerfect's clients have the choice concerning what Personal Data is accessed, used or retained. In order to conduct business with our clients it is necessary to maintain contact information and specific billing information, but the extent of the information stored can always be discussed with a TransPerfect Client Services Representative. Additionally, if there is a specific concern about the Personal Data found in the information provided to process a language services project (such as source, reference material, etc.), we recommend redacting this information prior to sending it to TransPerfect or discussing alternative solutions with your TransPerfect Client Services Representative. In addition, other steps may be taken which may include the forced anonymization of information and limitation of translation efforts to de-identified data only.
In order to better serve our client's needs and provide further information concerning services, TransPerfect may, from time-to-time, send information on additional services we provide. Should any client decide that this information is not desirable, a client may opt-out of receiving this information by informing their Client Services Representative or by contacting the TransPerfect Privacy Officer.
TransPerfect employees have a choice concerning what information is shared with other employees, affiliates and third parties (such as clients). Such information will only be provided pursuant to such employees written consent and not used for any other purpose.
Access and Correction – Any individual CVE may request a copy of the Personal Data TransPerfect has collected from TransPerfect's Privacy Officer in accordance with applicable law, in addition to receiving confirmation of the contents of any Personal Data relating to the individual. Under applicable law, such individual CVE then has the right to correct, amend or delete information when it is inaccurate.
Clients may do so by contacting their Client Services Representative or by contacting the TransPerfect Privacy Officer.
Except as may be required by law or during a registrar or regulatory audit, TransPerfect will not provide this data to a third party without the consent of the CVE.
Vendors can do so by contacting EDPA@transperfect.com, a dedicated e-mail address to which such inquiries can be sent directly.
Employees can do so by contacting the TransPerfect Human Resources department or the TransPerfect Privacy Officer.
Data Integrity – TransPerfect is dedicated to ensuring that all data maintained is accurate, updated, and relevant for the use contemplated by the CVE and will take all required steps to ensure the data is accurate, complete and current. This process is accomplished by regular email and written correspondence with CVEs; however, it is highly recommended that CVEs continue to monitor the information provided to TransPerfect and remain proactive with requesting access to any Personal Data and advising TransPerfect of the need for corrections as needed.
Data Security – TransPerfect has strict physical and logical security procedures to ensure that all digital and paper records are secured (such policy is available for dissemination to clients upon written request to the TransPerfect Privacy Officer). These records are accessible only by approved staff. All critical systems (e.g., servers) are accessible only by a small number of authorized staff. TransPerfect's information security is managed internally and is routinely audited to ensure conformity with TransPerfect procedures and recommended industry standards.
Independent Recourses for Privacy Complaints and Contact Information
In compliance with the Privacy Shield Principles, TransPerfect commits to resolve complaints about our collection or use of your personal information. To exercise all relevant rights, queries or complaints, please contact:
Data Privacy Officer
You may file complaints via an online form (click here)
TransPerfect is committed to resolve all complaints in timely manner. If you do not receive timely acknowledgment of your complaint from us (to be acknowledged within 45 days of receipt), or if you are not satisfied with our response, or if contacting us does not resolve your complaint, EU individuals may request TransPerfect to refer unresolved Privacy Shield complaints to, or you may bring a complaint before, the United States Council for International Business (USCIB). The USCIB is the American affiliate of the International Chamber of Commerce, the Business and Industry Advisory Committee to the OECD, and the International Organization of Employers, and has agreed to act as a trusted third party on behalf of the European Union (EU) Data Protection Authorities. Information about how to file a complaint before the USCIB can be found at uscib.org. As a last resort, EU individuals may seek redress through binding arbitration. Swiss individuals may request TransPerfect to refer unresolved Privacy Shield complaints to, or you may bring a complaint before, the Federal Data Protection and Information Commissioner (FDPIC), which serves as the Alternative Dispute Resolution body (ADR) according to the Swiss-US Privacy Shield Framework. The services of this process are provided at no cost to you.
TransPerfect is committed to cooperate with EU data protection authorities (DPAs) as well as FDPIC, and comply with the advice given by such authorities with regard to human resources data transferred from the EU and/or Switzerland in the context of the employment relationship.
TransPerfect provides information regarding the below through policies and trainings:
- TransPerfect is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC)
- The possibility, under certain conditions, for the individual to invoke binding arbitration
- The requirement for your organization to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements
- TransPerfect's liability in cases of onward transfers to third parties
Effective: June 2018