“Personal Information”* means any information that (i.) relates to a natural person or individual, and (ii.) is transferred to HT LOCALIZATION in the U.S. from the European Economic Area or Switzerland, (iii.) is recorded in any form, (iv.) relates to an identified or identifiable customer, and (v.) can be linked to that individual. Personal Information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.
“Sensitive Personal Information”* means Personal Information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life, the commission or alleged commission of any offense, any proceedings for any offense committed or alleged to have been committed by the individual or the disposal of such proceedings, or the sentence of any court in such proceedings.
HT LOCALIZATION generally does not collect - nor seeks to collect - Personal Information from prospects or clients, and never collect Sensitive Personal Information from prospects or clients. If Personal Information is gathered, it is limited to business contact information, See below:
Why We Collect Personal Information We may collect and use your personal information to give you superior customer service, to provide you with convenient access to our products and services, and to make a wider range available to you. In addition, we use your personal information to keep you up to date on the latest service announcements, special offers, and other information we think you’d like to hear about. This may occasionally include information about products and services that can add value to your experience. From time to time, we may also use your personal information to contact you to participate in a market research survey, so that we can gauge customer satisfaction and develop better products and services.
How We Collect Personal Information We may collect information about you in several ways. For example, we might ask for your contact information when you correspond with us, call us to request service, participate in an online survey, or ask to be included in an email mailing list. We store the information you provide in a secure database.
When We Disclose Personal Information At times we may be required by law or legal process to disclose your personal information. At any other time, if we are going to use your personal information differently from that stated at the time of collection, we will try to contact you via email using the most recent information we have. If you have not given us permission to communicate with you, you will not be contacted, nor will we use your personal information in a new manner.
How We Protect Your Personal Information We safeguard the security of the data you send us with physical, electronic, and managerial procedures. We urge you to take every precaution to protect your personal data when you are on the Internet.
Collecting Other Personal Information When you browse HT LOCALIZATION’s website, you are able to do so anonymously. Generally, we don’t collect personal information when you browse – not even your email address. Your browser, however, does automatically tell us the type browser you are using, and which country you are visiting from.
SAFE HARBOR PRINCIPLES – As part of its overall global privacy compliance efforts, HT LOCALIZATION is committed to conducting business in a manner that complies with the US/EU and US/SWISS Safe Harbor Frameworks and the Safe Harbor Privacy Principles as set out by the United States Department of Commerce. This statement outlines our general policies and practices in relation to the Principles of Safe Harbor, including the type of data we collect and how we process it.
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.
NOTICE – We treat all material sent to us from our clients, vendors, and employees (collectively,“interested parties”) as confidential in accordance with its current confidentiality undertakings with interested parties. 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 HT LOCALIZATION.
HT LOCALIZATION maintains Personal Data regarding interested parties on secure systems. This information is collected to aid us in conducting business operations. In addition to the Personal Data itself, the information which we protect 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. When requested by a client and permitted under applicable law, HT LOCALIZATION may also cause 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, we may accommodate this request if permitted under local law.
HT LOCALIZATION 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 HT LOCALIZATION’s website, we do not track Personal Data, names or email addresses. Instead, HT LOCALIZATION 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 HT LOCALIZATION (globally) are routed through a third party SPAM filter 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.
HT LOCALIZATION utilizes a network of third party vendors to assist in the production process. These third party vendors 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 third party 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 third party vendors will be subject to confidentiality undertakings in which such third party vendors undertake to keep such information confidential and only use such information in accordance with their projects.
All vendors are required to sign a Vendor Services Agreement, which includes confidentially, intellectual property, and data protection provisions prior to working with HT LOCALIZATION. Any vendor has the right to terminate its working relationship with us and request the deletion of Personal Data pertaining to them. However, we will continue to maintain its historical business records in such a way so that HT LOCALIZATION may retain its historical knowledge and relationships concerning any legal or regulatory inquiries which may later arise. This practice is in the best interest of both parties so that identifying information relating to a particular matter is accessible but sufficiently discrete so that HT LOCALIZATION does not accidentally contact them for projects in the future.
CHOICE – HT LOCALIZATION’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 your HT LOCALIZATION 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 HT LOCALIZATION or discussing alternative solutions.
In order to better serve our client’s needs and provide further information concerning services, HT LOCALIZATION 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 contacting us. HT LOCALIZATION employees and contractors 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 and/or contractors written consent and not used for any other purpose.
ACCESS AND CORRECTION – Any individual interested parties may request a copy of the Personal Data HT LOCALIZATION 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 interested parties then has the right to correct, amend or delete information when it is inaccurate. Interested parties may do so by contacting us.
DATA INTEGRITY – HT LOCALIZATION is dedicated to ensuring that all data maintained is accurate, updated, and relevant for the use contemplated by the interested parties 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 interested parties; however, it is highly recommended that interested parties continue to monitor the information provided to HT LOCALIZATION and remain proactive with requesting access to any Personal Data and advising us of the need for corrections as needed.
DATA SECURITY – HT LOCALIZATION has strict physical and logical security procedures to ensure that all digital and paper records are secured. These records are accessible only by approved staff. All critical systems (such as servers, back-up tapes, etc.) are accessible only by a small number of authorized staff. HT LOCALIZATION’s information security is managed internally and is routinely reviewed to ensure conformity with HT LOCALIZATION procedures and recommended industry standards.
Thank you for your confidence.
- Last Modified: January 28, 2016