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BREADCRUMB

 1. Home
 2. Privacy Policy

PRIVACY POLICY

Scope

– This Privacy Policy applies generally to personal data received by
TransPerfect Global, Inc., TransPerfect Translations International Inc.,
Translations.com and all of their affiliated and subsidiary entities
(collectively, “TransPerfect”, “we”, “us” or “our”) in any format. TransPerfect
will ensure all global data handled by its offices conforms to this Privacy
Policy. However, the details concerning how we process your personal data is
dependent on who you are and what our relationship is to you. Therefore, for
more detailed information concerning our privacy practices with respect to your
personal data, please select one of the following specific categories of data
subjects and its associated Privacy Policy:

 * For consumers and clients, including users of one of TransPerfect’s
   technology platforms, click here.
 * For vendors, click here.
 * For employees, click here.
 * For applicants for employment, click here.
    

Who are we?

TransPerfect may be a data controller of your personal data (also known as
personal information), 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 the data controller’s possession. The collection, use and processing of
your personal data may be subject to various data privacy laws (“applicable
privacy laws), including for European citizens or residents (“EU Personal
Data”), the EU General Data Protection Regulation (referred to herein as the
“GDPR”), and for California residents, the California Consumer Privacy Act (the
“CCPA”), and their implementing regulations.
 

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.”
 

What personal data do we collect?

Please utilize the applicable link above under “Scope” to find more detail
concerning the categories of personal data we collect from you. 
 

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.”
 

Further processing

If we wish to use your personal data for a new purpose not covered by an
existing privacy policy, we will provide you with a new notice explaining this
new use prior to commencing the processing and setting out the relevant purposes
and processing conditions. Where and whenever necessary, we will seek your prior
consent to the new processing. 
 

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.”
 

 

Sale of personal data

We do not sell your personal data. 
 

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, 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)
concerning the transfer of personal identifiable data from the European Union,
including adhering to the requirements effective under the GDPR. The
TransPerfect family of companies have entered into a data protection agreement,
which includes the EU Standard Contractual Clauses, agreeing with each other to
maintain the personal data processed by each TransPerfect entity in compliance
with all applicable data protection and privacy laws of the EU, its member
states, and all other countries. 

TransPerfect complies with the Swiss – U.S. Privacy Shield Framework as set
forth by the U.S. Department of Commerce regarding the collection, use, and
retention of personal information transferred from Switzerland to the United
States. TransPerfect has certified to the Department of Commerce that it adheres
to the Privacy Shield Principles. If there is any conflict between the terms in
this privacy policy and the Privacy Shield Principles, the Privacy Shield
Principles shall govern. To learn more about the Privacy Shield program, and to
view our certification, please visit https://www.privacyshield.gov/.

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.

This Privacy Policy may change from time to time based on changes made to the EU
Standard Contractual Clauses and/or the Swiss – U.S. Privacy Shield Framework.
Any changes made necessary will be reflected in an update to this policy and
disseminated.

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

The TransPerfect website uses cookies, tracking pixels and related technologies.
Cookies are small data files that are served by our platform and stored on your
device. Our site uses cookies dropped by us or third parties for a variety of
purposes including to operate and personalize the website. Cookies may also be
used to track how you use the site to target ads to you on other websites. 

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.
 

Opting-out

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

Depending on your country and/or state of residence, as well as our relationship
to you, you may have the following rights with respect to your personal data:

The right to request a copy of your personal data which TransPerfect holds about
you (for European or United Kingdom residents)

The right to know the categories and purposes of personal data that we collect
about you (for California residents)

The right to request that TransPerfect corrects any personal data if it is found
to be inaccurate or out of date (for European or United Kingdom residents)

The right to request your personal data is erased where it is no longer legally
necessary for TransPerfect to retain such data (for European, United Kingdom and
California residents)

The right to withdraw your consent to the processing at any time (for European
or United Kingdom residents)

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 (for European, United Kingdom or California residents)

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
(for European or United Kingdom residents)

The right to lodge a complaint with governmental agencies or Data Protection
Authorities as provided for in the GDPR (for European or United Kingdom
residents).

To exercise your rights to data rectification, erasure, portability, access
and/or restricted processing, please email privacy@transperfect.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 8,000 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 are 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
in connection with 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 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 (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
Data 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 Data 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 Data 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 mydata@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 Data Privacy Officer. 

Data Integrity – TransPerfect is dedicated to ensuring that all data maintained
is accurate, updated, and relevant for the use contemplated 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
Data 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:

Stacey Watanabe
Data Privacy Officer
TransPerfect
Europe: +48 (22) 104 2990
US/Global: +1 646.589.6769
privacy@transperfect.com

You may file Data Subject Requests or compliance issues via 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, Swiss residents may refer
unresolved Privacy Shield complaints to 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. 
 

Enforcement 

TransPerfect undertakes to verify compliance with its Privacy Policy not less
than once per year and in connection with TransPerfect's annual review and
internal compliance measures. TransPerfect will use its best commercial efforts
to ensure that compliance with this Privacy Policy is maintained and that the
Privacy Policy is accurate, comprehensive, and continues to conform to
applicable law. We encourage CVEs to raise and discuss any issues or concerns
with TransPerfect’s Data Privacy Officer, who address and resolve such
complaints regarding the use of data and noncompliance with our Privacy Policy.
All issues will be officially documented within the framework of our ISO 9001
certified quality management system. 

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 our 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;

With respect to complaints related to our Privacy Policy that cannot be resolved
through our internal process, we agree to abide by the dispute resolution
procedures established by the relevant authorities as designated by applicable
governing regulations. 

  

Effective: May 2021

 

 



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