Last updated: 22 May 2018
Translators without Borders US, Inc. (“we”, “us”) is concerned about privacy issues and wants you to be familiar with how we collect, use, and disclose information that identifies you as an individual or relates to an identifiable person (“Personal Information”).
This Privacy Policy describes our practices in connection with information that we collect through:
- Any website, email, mobile application, or other software from which you are accessing this Privacy Policy (“Website”);
- Our social media pages and apps located at Facebook, Twitter, LinkedIn, YouTube, Instagram, WhatsApp, and Telegram (collectively, “Social Media Channels”);
- Formatted email messages that we send to you and that link to this Privacy Policy;
- Off-line;
- Information you send to us (e.g. via email, links to an online drive) (collectively, “Services”).
- This Privacy Policy applies to all users of the Services.
Personal Information
COLLECTION OF PERSONAL INFORMATION
We and our service providers collect Personal Information in a variety of ways, including:
- Through the Services
- We collect Personal Information through the Services, for example, when you sign up for a newsletter, register an account to access the Services, enter into an agreement for services, or contact us.
- Enter into a financial agreement or contract to provide TWB goods or services.
- Offline
- We collect Personal Information from you offline, e.g., when we meet with you, meet you at a trade show or receive a phone call from you.
- From Other Sources
- We receive your Personal Information from other sources, for example:
- publicly available databases
- joint promotional partners, when they share the information with us;
- If you connect your social media account to your Services account, you will share certain Personal Information from your social media account with us. For example, your name, email address, photo, list of social media contacts, and any other information that may be, or you make, accessible to us when you connect your social media account to your Services account.
We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
USE OF PERSONAL INFORMATION
We and our service providers use Personal Information for legitimate business purposes, including when you:
- Contact us with your questions/comments/ideas/complaints: We may collect information, depending on the manner in which you contact us (e.g., if you send us an email, we will collect your email address) and the reason for contacting us (e.g., if you have a complaint). In any case, we will collect your contact details so we can respond to your query.
We use this information to manage our contractual relationship with you, when we have a legitimate interest, and/or to comply with a legal obligation. - Subscribe to our newsletter/mailing list: We will collect your name and your email address if you wish to subscribe to our newsletter.
We will engage in this activity with your consent or where we have a legitimate interest. - When you translate: When you wish to be a TWB translator, we will ask you to fill in our ‘Translator Application Form’ or our ‘In-Kind Expression of Interest’. Therein we will ask you for the information needed to establish your identity and credentials that show your qualifications to become our translator. This includes your name, your contact details, native language, translating abilities (e.g., which languages you are qualified to translate), and relevant educational and professional experience.
We use this information to manage our business relationship with you. - When you volunteer in another capacity (in-kind): When you wish to volunteer in another capacity (such as project manager, graphics or web page designer, or you otherwise wish to give your time, technology, and expertise to support us) we will ask you to fill in our ‘Other Volunteer Application Form’. Therein we will ask you for various information, such as your name, your contact details, your area of expertise, and relevant educational and professional experience (CV).
We use this information to manage our business relationship with you. - When you donate as an individual: We will collect your name, contact and address details, donation amount, payment details (such as credit/debit card/PayPal account number), and any other information you voluntarily choose to provide.
We use this information to manage our relationship with you. - When you become a corporate sponsor or partner: We will collect the name of the contact person, contact and address details, sponsorship/invoice amount, payment details (such as bank account, credit/debit card/PayPal account number), and any other information voluntarily provided to us.
We use this information to manage our relationship with you. - When you report a problem with one of our Services: We will collect your first and last names and your contact details so we can respond to your report. You will also need to describe the problem that you have experienced so we can take care of it.
We use this information to manage our contractual relationship with you, when we have a legitimate interest, and/or to comply with a legal obligation. - When you enter into a financial agreement or contract to provide us services: We will collect your first and last names, contact details, bank account details, and identification to confirm that we are not prohibited from paying you, and residency information to provide to tax authorities.
We may also use the Personal Information to accomplish our business purposes:
- For data analysis, for example, to improve the efficiency of our Services;
- For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;
- For fraud and security monitoring purposes, for example, to detect and prevent cyber attacks or attempts to commit identity theft;
- For developing new products and services;
- For enhancing, improving, or modifying our current products and services;
- For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
- For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests;
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
DISCLOSURE OF PERSONAL INFORMATION
We disclose Personal Information:
- To our affiliates, staff, volunteers, and interns located all over the world for the purposes described in this Privacy Policy. Our affiliates:
- Translators without Borders – US, Inc., 30 Main Street, Suite 500, Danbury, CT USA
- The Rosetta Foundation, Marina House, East Point Office Park, Dublin 3, Ireland
- Translators without Borders – US, Inc. is the party responsible for the management of the jointly-used Personal Information.
- To our third party service providers, to facilitate services they provide to us.
- These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
- By using the Services, you may elect to disclose Personal Information
- On message boards, chat, profile pages, blogs, and other services to which you are able to post information and content (including, without limitation, our Social media channels). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
- Through your social sharing activity. When you connect your Services account with your social media account, you will share information with your friends associated with your social media account, with other users, and with your social media account provider. By doing so, you authorize us to facilitate this sharing of information, and you understand that the use of shared information will be governed by the social media provider’s privacy policy.
OTHER USES AND DISCLOSURES
We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
- To comply with applicable law and regulations.
- This can include laws outside your country of residence
- To cooperate with public and government authorities.
- To respond to a request or to provide information we believe is important.
- These can include authorities outside your country of residence.
- To cooperate with law enforcement.
- For example, when we respond to law enforcement requests and orders or provide information we believe is important.
- For other legal reasons.
- To enforce our terms and conditions; and
- To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
- In connection with a sale or business transaction.
- We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings) Such third parties may include, for example, an acquiring entity and its advisors.
COOKIES AND SIMILAR TECHNOLOGIES
Cookies are pieces of information stored directly on the computer that you are using. We use cookies in accordance with our Cookie Policy.
SECURITY
We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your Personal Information
We give you choices regarding our use and disclosure of your Personal Information for promotional purposes. You may opt-out from:
- Receiving electronic communications from us: If you no longer want to receive promotional emails from us on a going-forward basis, you may opt-out by clicking on the ‘Unsubscribe’ link in each email you receive from us, or by writing to [email protected].
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving promotional emails from us, we may still send you important administrative messages, from which you cannot opt-out.
HOW YOU CAN ACCESS, CHANGE, OR DELETE YOUR PERSONAL INFORMATION
If you would like to request to review, correct, update, suppress, restrict or delete Personal Information that you have previously provided to us, object to the processing of Personal Information, or if you would like to request an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us at [email protected]. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Information you would like to have changed, or whether you would like to have your Personal Information removed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).
If you are a resident of California, under 18 and a registered user of the Services, you may ask us to remove content or information that you have posted to the Services by writing to: [email protected]. Please note that your request does not ensure complete or comprehensive removal of the content or information, as some of your content may have, for example, been re-posted by another user.
RETENTION PERIOD
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.
The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
- Whether there is a legal obligation to which we are subject (for example, certain laws or contracts that we have entered into with donors require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
THIRD PARTY SERVICES
This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with our Social Media Channels.
USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18.
JURISDICTION AND CROSS-BORDER TRANSFER
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
In order to safeguard your information, we will make any such transfers in strict compliance with data protection legislation with all appropriate contractual arrangements (Privacy Shield, Binding Corporate Rules, or Model Contracts) in place. By submitting your personal data for such purposes, you agree to this transfer, storing or processing. TWB will take all reasonable steps necessary to ensure that your personal data is processed securely and in accordance with this Privacy Statement. All information you provide to us is stored on secure servers.
SENSITIVE INFORMATION
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.
THIRD PARTY PAYMENT SERVICE
We may use a third-party payment service to process payments made through the Services. If you wish to make a payment through the Services, your Personal Information will be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use and disclosure of your Personal Information.
UPDATES TO THIS PRIVACY POLICY
The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.
CONTACTING US
Translators without Borders US, Inc., located at Suite 500, 30 Main Street, Danbury, CT 06810, United States, is the company responsible for the collection, use and disclosure of your Personal Information under this Privacy Policy.
If you have any questions about this Privacy Policy, please contact us at [email protected], or:
Translators Without Borders US, Inc.
Suite 500, 30 Main Street
Danbury, CT 06810
United States
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
You may also:
- Contact our Data Protection Officer (DPO) at [email protected].
- Lodge a complaint with a data protection authority for your country or region where an alleged infringement of applicable data protection law occurs. A list of data protection authorities in the EU is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
