WHAT WE DO WHO WE ARE GET IN TOUCH WEB PRIVACY POLICY EU Standard Contractual Clauses (Processors) – 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 to the United States of America. TransPerfect also applies the same principles to data received from Switzerland. 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. Any changes made necessary will be reflected in an update to this policy. 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. Any questions about TransPerfect’s Privacy Policy or for a more detailed description of TransPerfect’s privacy compliance efforts (as outlined in our Privacy Manual) please contact our Privacy Officers, Roy Trujillo and/or Adam Mimeles (privacy@transperfect.com) or by telephone at 212-689-5555 x 1494. Scope – This Privacy Policy applies to all personal information received by TransPerfect in any format. TransPerfect will ensure all global data handled by our offices conforms to this Privacy Policy. 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 CVEs; each separate entity must sign a confidentiality agreement prior to becoming affiliated or working with TransPerfect. TransPerfect maintains personal data regarding CVEs on secure systems. This information is collected to aid TransPerfect in conducting business operations. In addition to the personal data itself, the information which TransPerfect protects includes contact details, billing/invoicing/payment information, services provided to our clients, and information within source and reference files sent to perform translation projects. In regards to our employees and vendors, this information may also include contact details, payment information, professional qualifications, financial information, and information provided by the employee or vendor in its resume or curriculum vitae (“CV”). When requested by a client and permitted under applicable law, TransPerfect may also cause criminal background checks to be conducted on all employees as well as seek such information concerning key vendors or consultants who may be retained by them. If criminal background checks are needed by clients for our vendors, TransPerfect may accommodate this request if permitted under local law and for an additional fee. Please discuss with your Client Services Representative if needed. TransPerfect does not rent, sell, loan or otherwise make available personal data to any third party unless required by law or in the scope of a registrar, regulatory, or financial audit. 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. 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 originating 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 vendors to assist in translation process. Vendors may receive, as part of the assignment, the name of the client they are working on, but Vendors do not receive any personal data about that client, unless such information is needed to perform the assignment (such as the cases of onsite interpretation projects, onsite document review, etc.). These 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 vendors will be subject to confidentiality undertakings in which they undertake to keep such information confidential and only use such information in accordance with their projects, in addition to a Business Associate Agreement and EU Standard Contractual Clauses. All vendors are required to sign an EU Data Protection Agreement prior to working with TransPerfect. This document addresses common requirements concerning Notice, Choice, Onward Transfer, Access, Security, Data Integrity and Enforcement of the personal data. Any vendor has the right to terminate its working relationship with TransPerfect and request the deletion of personal data pertaining to them. However, 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 TransPerfect and its vendors 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 with such employees written consent and will not be used for any other purpose. Onward Transfer – TransPerfect will obtain assurances from employees and vendors that they will safeguard personal data consistent with our Privacy Policy. TransPerfect will take all steps in accordance with the Privacy Policy to prevent, contain, or stop any disclosures contrary to such party’s obligations. Access and Correction – Any individual CVE may request a copy of the personal data TransPerfect has collected 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. 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. Except as may be required by law or during a registrar or regulatory audit, TransPerfect will not provide any CVEs’ personal data to a third party without the consent of the data subject. 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 (such as servers, etc.) 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. 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 directly with TransPerfect’s Privacy Officer, who will 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. With respect to complaints related to our Privacy Policy that cannot be resolved through our internal Corrective/Preventive Action Process, we agree to abide by the dispute resolution procedures established by the EU Data Protection Authorities. 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