Last modified: May 23, 2019
1. Introduction
This Privacy Policy describes how Language Scientific, Inc. collects and uses Personal Data about you through the use of our Website and through email, text, and other electronic communications between you and LS.
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Language Scientific, Inc. (“LS” or “we” or “us”) respects your privacy and is committed to protecting it through our compliance with this policy.
This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit the website https://www.languagescientific.com, including our client portal and vendor portal (the “Website”), when our customers submits translation source files to us in connection with our services (“Translation Files”), and our practices for collecting, using, maintaining, protecting, and disclosing that information. We provide language translation and localization services to our customers for the Personal Data including in Translation Files (the “Services”).
This policy applies to information we collect:
- on our Website;
- in Translation Files submitted to us as part of our customer’s use of our Services;
- in email, text, and other electronic messages between you and our Website.
It does not apply to information collected by:
- us offline or through any other means, including on any other website operated by LS or any third-party (including our affiliates and subsidiaries);
- us or any of our affiliates or subsidiaries related to your or any other individual’s employment or potential employment with us (including any information you submit on or through our application portal). Such information is governed by our Fair Information Processing Notice, which is available through the Contact Information below; or
- any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.
2. Data Controller, Data Protection Officer, and Representative
LS is the data controller of the Personal Data you provide on the Website. Our customers are the controller and we are the processor of information provided in Translation Files. LS has appointed a Data Protection Officer and a representative in the European Union.
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LS is the data controller of your Personal Data that you provide on the Website. However, our customers are the data controller and we are a processor of any Personal Data provided in Translation Files. Our use of Personal Data in Translation files is also governed by our services agreement with our customer that provided the applicable Translation File. Accordingly, if you are the subject of Personal Data contained in one or more Translation Files, you must contact the entity who provided the applicable Translation File regarding their privacy practices.
LS has appointed a Data Protection Officer and a representative in the European Union in compliance with the General Data Protection Regulation. LS, its Data Protection Officer, or its representative may be contacted in any manner set forth below in the “Contact Information” Section of this Privacy Policy.
3. Children Under the Age of 18
Our Website are not intended for children under the age of 18 and children under the age of 18 are not permitted to use our Website. We will remove any information about a child under the age of 18 if we become aware of it.
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Our Website are not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Website or on or through any of its features, including your name, address, telephone number, or email address. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 18, please contact us at through the Contact Information below. Please note, however, that information about children under the age of 18 may be provided by our customers in Translation Files as part of our Services and you must contact them if you believe such information may have been provided from a child under 18.
4. Information We Collect About You and How We Collect It
We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.
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Generally
We collect several types of information from and about users of our Website (“Personal Data”):
- by which you may be personally identified, such as name, company name, postal address, e-mail address, username (for our client portal) and telephone number;
- that is about you but individually does not identify you, as further described below;
- about your internet connection, the equipment you use to access our Website and usage details.
We collect this information:
- directly from you when you provide it to us; and
- automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
Information You Provide to Us
The information we collect on or through our Website are:
- information that you provide by filling in forms on our Website. This includes information provided at the time of requesting quotes or services. We may also ask you for information when you report a problem with our Website;
- records and copies of your correspondence (including email addresses), if you contact us.
The Personal Data we collect from you is required to enter into a contract with LS, for LS to perform under the contract, and to provide you with our products and services. If you refuse to provide such Personal Data or withdraw your consent to our processing of Personal Data, then in some cases we may not be able to enter into the contract or fulfill our obligations to you under it.
Information Provided in Translation Files to Provide our Services
Our customers may upload Translation Files to be used with our Services, including through our client portal on our Website. We do not control or determine the information provided by our customers in Translation Files, and this information may contain special categories of information as described further below. This information is provided to us by our customers for the purpose of us providing our Services to them, and our customers are solely responsible for obtaining all required consents for our processing of this Personal Data.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns:
- details of your visits to our Website. We collect such as traffic data, location data, logs, referring/exit pages, date and time of your visit to our Website, error information, clickstream data, and other communication data and the resources that you access and use on the Website; and
- Information about your computer and internet connection, i.e. your IP address, operating system, and browser type.
The information we collect automatically may include Personal Data, or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service by enabling us to:
- estimate our audience size and usage patterns;
- store information about your preferences, allowing us to customize our Website according to your individual interests; and
- recognize you when you return to our Website.
Details about the automated data collection technologies and the specific cookies that we use can be found in our Cookie Policy.
5. Lawful Basis for Processing Your Personal Data
We have a lawful basis for our processing of your Personal Data, including processing for our legitimate interests (when balanced against your rights and freedoms), to fulfill our obligations to you under a contract with you, and required by law, and with your consent.
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In some jurisdictions, the processing of your Personal Data is lawful only if it is permitted under the applicable data protection laws. For Personal Data you provide to us in our role as a controller, we have one or more of the following lawful bases for each of our processing activities of your Personal Data:
- Consent. By using our Website, you consent to our collection, use, and sharing of your Personal Data as described in this Privacy Policy. If you do not consent to this privacy policy, please do not use the Website;
- Legitimate Interests. We will process your Personal Data as necessary for our legitimate interests. Our legitimate interests are balanced against your rights and freedoms and we do not process your Personal Data if your rights and freedoms outweigh our legitimate interests. Our legitimate interests are to: facilitate communication between LS and you; detect and correct bugs and to improve our Website; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime; promote and market our business; develop our product and services by reviewing how you use our website and the comments you provide us to review and consider suggestions;
- To Fulfill Our Obligations to You under our Services Agreement. We process your Personal Data in order to fulfill our obligations to you pursuant to our services agreement with you to deliver our goods and services to you;
- As Required by Law. We may also process your Personal Data when we are required or permitted to by law; to comply with government inspections, audits, and other valid requests from government or other public authorities; to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our network, or other criminal and tortious activities), defend litigation, and manage complaints or claims.
For Data Provided in Translation Files in Our Role as a Processor. We will process Personal Data provided in Translation Files as a processor and in accordance our services agreement with the applicable customer providing the Translation File. It is our customers’ responsibility to ensure that they have a lawful basis for each of the processing activities they request of us in accordance with the laws of all applicable jurisdictions.
6. Special Categories of Information
We generally do not request you provide and do not process any special categories of Personal Data on our through our Websites.
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LS does not ask you to provide, and we do not knowingly collect, any special categories of Personal Data from you to use our Website such as personal data that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade unions membership, or personal data concerning your health or data concerning your sex life or sexual orientation or history of criminal convictions.
Notwithstanding the foregoing, any such special categories of information provided in Translation Files will be processed in accordance with our services agreement between LS and the applicable customer providing the Translation File, if applicable, in accordance with the EU-U.S. Privacy Shield or the Swiss-U.S. Privacy Shield Frameworks. Our customers are solely responsible for collecting all necessary consents or otherwise ensuring that our processing of such special categories of information in accordance with our services agreement with them is permitted under all applicable laws.
7. Automated Decisions Making
We generally do not use your Personal Data with any automated decision making processes which may produce a legal effect.
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LS does not use your Personal Data with any automated decision making process, including profiling, which may produce a legal effect concerning you or similarly significantly affect you.
8. How We Use Your Information
We use your Personal Data for various purposes described below, including to:
- provide our Website to you;
- provide you with information you request from us;
- enforce our rights arising from contracts;
- notify you about changes; and
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We use information that we collect about you or that you provide to us, including any Personal Data:
- to present our Website and their contents to you;
- to provide you with information, products, or services that you request from us;
- to fulfill any other purpose for which you provide it;
- to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
- to notify you about changes to our Website or any products or services we offer or provide though them;
- in any other way we may describe when you provide the information; and
- for any other purpose with your consent.
If you register for our newsletter, we may also use your information to provide you with our quarterly newsletter. If you wish to unsubscribe from our newsletter, click the unsubscribe link at the bottom of the email containing the newsletter or by contacting us at the Contact Information below and request to be removed.
Personal Data contained in Translation Files. We also use Personal Data provided to us in Translation Files solely for the purposes of carrying out our Services for our customers and in accordance with our services agreement with the customer providing the Translation File. Please note our customers’ use of your Personal Data contained in Translation files is governed by their own privacy policy. We are not responsible for and do not control their collection, processing, use, or disclosure of your Personal Data and you must contact them for further information regarding their collection, processing, use, and disclosure of your Personal Information contained in Translation Files.
LS will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.
9. Disclosure of Your Information
We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. We disclose your Personal Data to a few third parties, including:
- our subsidiaries and our affiliates;
- our third-party service providers that we use to support our business;
- to a company that we merge with, acquire, or that acquires us, or in the event of change in structure of our company of any form;
- to comply with our legal obligations;
- to enforce our rights; and
- with your consent.
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We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose Personal Data that we collect or you provide as described in this Privacy Policy:
- to our subsidiaries and affiliates;
- to contractors, service providers, and other third parties we use to support our business. These entities provide translation services, IT and infrastructure support services, and payment processing services;
- to a potential or actual buyer or other successor in the event of a planned or actual merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Language Scientific, Inc’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Language Scientific, Inc. about our Website’s users is among the assets transferred;
- to fulfill the purpose for which you provide it. For example, if you give us an email address when you request further information, we will send that information to you at that email address;
- for any other purpose disclosed by us when you provide the information; and
- with your consent.
Personal Data contained in Translation Files. We do not share, sell, or otherwise disclose your Personal Data contained Translation Files for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about individuals described in the Translation Files, and information that does not identify such individuals individual, without restriction, as permitted under our services agreement with our customers. We may also disclose Personal Data provided to us in Translation Files as described in this Privacy Policy:
- to our translators and other personnel in their performance of the Services;
- to a potential or actual buyer or other successor in the event of a planned or actual merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Language Scientific, Inc’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Language Scientific, Inc. about our Services is among the assets transferred;
- to fulfill the purpose of providing our Services to our customers.
Please note our customers’ use of your Personal Data contained in Translation files is governed by their own privacy policy. We are not responsible for and do not control their collection, processing, use, or disclosure of your Personal Data and you must contact them for further information regarding their collection, processing, use, and disclosure of your Personal Information contained in Translation Files.
When we disclose Personal Data for one of the above business purposes, we enter a contract that describes the purpose and requires the recipient to keep that Personal Data confidential and not use it for any other purpose except performing the applicable contract.
We may also disclose your Personal Data, whether provided to us on or through the Website or in Translation Files:
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
- to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes; and
- if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Language Scientific, Inc., our customers, or others.
10. Choices About How We Use and Disclose Your Information
We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for third-parties to advertise to you, our advertising to you, and other targeted advertising.
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We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.
In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:
- Newsletters from LS. We will only use your email address to send you newsletters with your express consent. If you wish to consent to such use, can sign up for our newsletter by filling out the box and clicking subscribe on our Website. If you wish to change your choice, you may do so at any time clicking the unsubscribe link at the bottom of our newsletters.
Personal Data contained in Translation Files.
Our customers’ use of your Personal Data contained in Translation files is governed by their own privacy policy. Our customers may provide with you different or additional choices regarding how they use and disclose your Personal Data. We are not responsible for and do not control their collection, processing, use, or disclosure of your Personal Data and you must contact them for further information regarding their collection, processing, use, and disclosure of your Personal Information contained in Translation Files.
11. Your Rights Regarding Your Information and Accessing and Correcting Your Information
You may have certain rights under applicable data protection laws, including the right to access and update your Personal Data, restrict how it is used, transfer certain Personal Data to another controller, withdraw your consent at any time, and the right to have us erase certain Personal Data about you. You also have the right to complain to a supervisory authority about our processing of your Personal Data.
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Applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data that you provide us on or through our Website (not including any Personal Data contained in Translation Files).
- Access and Update. If you have access to our client portal or vendor portal, you can review and change your Personal Data by notifying us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
- Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing but we have retained it as permitted by law.
- Portability. To the extent the Personal Data you provide LS is processed based on your consent, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.
- Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by closing your account. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.
- Right to be Forgotten. You have the right to request that we delete all of your Personal Data. If you have access to the client portal or vendor portal, we cannot delete your Personal Data except by also deleting your user account. We will only delete your Personal Data (and your account, if applicable) when we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies.
- Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
- How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods listed under Contact Information below and through the live chat feature of our Website. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee subject to a maximum set by applicable law.
Personal Data contained in Translation Files. You may have the same or similar rights as described above for your Personal Data provided to us in Translation Files. You must contact the controller of this Personal Data to exercise these rights as we are not able to directly respond or comply with any requests to exercise these rights other than pursuant to instructions from the controller of your Personal Data.
12. Your California Privacy Rights
Under some circumstances, California law may provide you with the right to obtain a list of third parties (if any) that we provide your Personal Data to for their own direct marketing purposes. We do not provide your Personal Data to third parties for their own direct marketing purposes.
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California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Website that are California residents and who provide Personal Data in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Data to third parties for their own direct marketing purposes. Our products and services are not meant for personal, family, or household use and we do not disclose your Personal Data to third parties for their own direct marketing purposes. Therefore, we do not respond to such requests.
13. Do Not Track Signals
We may use automated data collection technologies to track you across websites. We currently do not honor do-not-track signals that may be sent by some browsers.
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We also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.
14. Data Security
Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Website confidential.
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We have implemented measures designed to secure your Personal Data and Personal Data contained in Translation Files from accidental loss and from unauthorized access, use, alteration, and disclosure. Our services agreement with our customers may contain specific requirements for such measures.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
15. Consent to Processing of Personal Data in Other Countries Outside the European Economic Area
We may process your Personal Data outside of your home country, including to the United States. We only do this when we are legally permitted to do so and when we have appropriate safeguards in place to protect your Personal Data.
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If you are a resident outside the United States, including a resident of the European Economic Area (“EEA”), in order to provide our Website, products, and Services to you, we may send and store your Personal Data outside of the of your home country, including to the United States. Accordingly, your Personal Data may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data.
Your Personal Data is transferred by LS to another country only if it is required or permitted under applicable data protection law and provided that there are appropriate safeguards in place to protect your Personal Data. By using our Website, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data that you provide directly to us on our Website. To ensure your Personal Data (other than Personal Data you provide directly to us on our Website) is treated in accordance with this Privacy Policy, LS uses Data Protection Agreements between LS and all other recipients of your data and/or between LS and our customers If you reside in the EEA or in Switzerland, LS has self-certified as compliant with the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield, which the European Commission has determined provides an adequate level of protection for your Personal Data. If you reside in the EEA or Switzerland, please see our Privacy Shield Addendum attached hereto for more information about our commitments to protect your Personal Data. Your Personal Data is transferred by LS to another country only if it is required or permitted under applicable data protection law and provided that there are appropriate safeguards in place to protect your Personal Data. By using our Website, you represent that you have read and understood the above and hereby consent to the storage and processing of Personal Data that you provide directly to us on our Website. To ensure your Personal Data (other than Personal Data you provide directly to us on our Website) is treated in accordance with this Privacy Policy, LS uses Data Protection Agreements between LS and all other recipients of your data and/or between LS and our customers If you reside in the EEA or in Switzerland, LS has self-certified as compliant with the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield, which the European Commission has determined provides an adequate level of protection for your Personal Data. If you reside in the EEA or Switzerland, please see our Privacy Shield Addendum attached hereto for more information about our commitments to protect your Personal Data.
16. Data Retention Periods
We retain your Personal Data for as long as you keep your account open. In some instances, we may keep it after you close your account, for example we may keep it:
- on our backup and disaster recovery systems;
- for as long as necessary to protect our legal interests; and
- and to comply with other legal requirements.
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If you have an account to access our client portal or vendor portal, LS will retain your Personal Data for the entire time that you keep such accounts open. After you close your account, we will retain your Personal Data for at least seven (7) years. Personal Data contained in Translation Files is generally retained for seven (7) years or as otherwise described in our services agreement with our customer. We may additionally retain your Personal Data:
- for as long as necessary to comply with any legal requirement;
- on our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;
- for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies; and
- for data that has been aggregated or otherwise rendered anonymous in such a manner that you are no longer identifiable, indefinitely.
17. Changes to Our Privacy Policy
We will post any changes to our Privacy Policy on our Website. If we make material changes to our Privacy Policy, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes.
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We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website’ home page. If we make material changes to how we treat our users’ Personal Data, we will notify you by email to the email address you have provided us and/or through a notice on the Website’ home page. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.
Personal Data contained in Translation Files. For Personal Data contained in Translation Files, the applicable customers’ privacy policy may describe how they update their privacy policy and notify you of changes. Please consult their privacy policy for this information.
You may contact our Data Protection Officer through the contact information below. If you wish to contact us, you must contact both us and our representative through the contact information below or through the “Contact Us” page on our Website.
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If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you must contact both us and our representative in the European Union at the contact information below or through the “Contact” page on our Website.
To Contact LS (As a Controller)
LS
101 Station Landing, Suite 500
Medford, MA 02155
USA
(617) 621-0940
info@languagescientific.com
To Contact Our Representative
Rickert Rechtsanwaltsgesellschaft m.b.H.
Data Protection Officer
Kaiserplatz 7-9, 53113
Bonn, Germany
Email: info@rickert.net, datenschutz@rickert.net
Phone: +49 (0)228 74 898 0
Fax: +49 (0)228 74 898 66
To Contact Our Data Protection Officer
Joseph Burgio
101 Station Landing, Suite 500
Medford, MA 02155
USA
(617) 621-0940
PrivacyOfficer@languagescientific.com
Privacy Shield Supplemental Policy for Language Scientific, Inc. Website and Translation Files
Effective Date: May 23, 2019
Last modified: May 23, 2019
19. Introduction
This Privacy Shield Policy (“Policy”) describes how Language Scientific, Inc., located in the United States (“U.S.”) (“LS,” “we,” or “us”), collects, uses, and discloses certain personally identifiable information that we receive in the U.S. from the European Union (“Personal Data”). This Policy supplements our Website and Translation Files Privacy Policy, and unless specifically defined in this Policy, the terms in this Policy have the same meaning as the Website and Translation Files Privacy Policy.
Language Scientific, Inc. recognizes that the EU has established strict protections regarding the handling of Personal Data, including requirements to provide adequate protection for Personal Data transferred outside of the EU. To provide adequate protection for certain Personal Data about corporate customers and the subject of Translation Files received in the U.S., Language Scientific, Inc. has elected to self-certify to the EU-U.S. Privacy Shield Framework administered by the U.S. Department of Commerce (“Privacy Shield”). Language Scientific, Inc. adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability.
For purposes of enforcing compliance with the Privacy Shield, Language Scientific, Inc. is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission. For more information about the Privacy Shield, see the U.S. Department of Commerce’s Privacy Shield website located at: https://www.privacyshield.gov. To review Language Scientific, Inc.’s representation on the Privacy Shield list, see the U.S. Department of Commerce’s Privacy Shield self-certification list located at: here.
20. Personal Data Collection and Use
Our Website and Translation Files Privacy Policy describes the categories of Personal Data that we may receive in the U.S. as well as the purposes for which we use that Personal Data. Language Scientific, Inc. will only process Personal Data in ways that are compatible with the purpose that Language Scientific, Inc. collected it for, or for purposes the individual later authorizes. Before we use your Personal Data for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out. Language Scientific, Inc. maintains reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete, and current.
We do not collect sensitive Personal Data from our customers, however, our customers may provide certain categories of sensitive Personal Data in Translation Files, including Personal Data related to genetic data, biometric data, data concerning health or data concerning an individuals sex life or sexual orientation. When we receive sensitive Personal Data from a customer, we will obtain your opt-in consent where the Privacy Shield requires, including if we disclose your sensitive Personal Data to third parties, or before we use your sensitive Personal Data for a different purpose than we collected it for or than you later authorized.
21. Data Transfers to Third Parties
Third-Party Agents or Service Providers. We may transfer Personal Data to our third-party agents or service providers who perform functions on our behalf as described in our Website Privacy Policy. Where required by the Privacy Shield, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process Personal Data in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of Personal Data that we transfer to them.
Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
22. Security
Language Scientific, Inc. maintains reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.
23. Access Rights
You may have the right to access the Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.
24. Questions or Complaints
You can direct any questions or complaints about the use or disclosure of your Personal Data to us at through our Privacy Officer, Joseph Burgio, at 101 Station Landing, Suite 500, Medford, MA 02155, USA, PHONE: +1-617-621-0940, Email: PrivacyOfficer@LanguageScientific.com. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data within 45 days of receiving your complaint. For any unresolved complaints, we have agreed to cooperate with JAMS . If you are unsatisfied with the resolution of your complaint, you may contact JAMS at Jara E. Satterthwaite, Esq., JAMS, 3800 Howard Hughes Parkway, 11th Floor, Las Vegas, NV 89169, https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim for further information and assistance.
Binding Arbitration. You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your compliant directly with Language Scientific, Inc. and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the U.S. Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see U.S. Department of Commerce’s Privacy Shield Framework: Annex I (Binding Arbitration).
25. Changes To This Policy
We reserve the right to amend this Policy from time to time consistent with the Privacy Shield’s requirements.
26. Contact Us
If you have any questions about this Policy or would like to request access to your Personal Data, please contact us as follows:
Joseph Burgio
101 Station Landing, Suite 500
Medford, MA 02155
USA
(617) 621-0940
PrivacyOfficer@languagescientific.com
