Privacy Policy. Last Updated: September 10, 2018

Transcription

1 Privacy Plicy Last Updated: September 10, 2018 Babel Street understands the imprtance f privacy and values the trust that ur custmers, ur partners and ur website visitrs place in us. Therefre, Babel Street, Inc. ( Babel Street ) wants yu t be familiar with hw we handle infrmatin relating t yu as an individual, knwn as persnal infrmatin. This Privacy Plicy describes ur practices fr the infrmatin we cllect, use and disclse. This infrmatin is gathered thrugh the means listed belw, which we cllectively refer t as ur Services : ur website ur search and analytics prducts described at which we refer t as ur Prducts ; ur LinkedIn page lcated at and crprate events, such as technlgy cnferences, netwrking events, tradeshws r trainings. Abut Our Prducts The missin f ur cmpany is t help ur custmers lcate relevant and timely publicly and cmmercially available infrmatin withut the limits f language r rigin. Our custmers direct their infrmatinal queries using the Babel Street Sftware as a Service (SaaS) platfrm and decide what infrmatin they need and frm which surces. Types f Infrmatin We Cllect Babel Street cllects infrmatin abut yu, as a visitr t ur website and/r crprate events, user f digital cntent, custmer, supplier, r partner in cnnectin with ur Prducts r Services, r when yu therwise interact with us. This can include: Infrmatin vluntarily prvided t us by website visitrs, custmers, suppliers, partners, event participants and ther individuals, such as: cntact details, including name, address, cmpany name, and telephne number, accunt infrmatin, if applicable, 1

2 cmments n ur LinkedIn pstings, and financial and transactin data, including purchase histry, payment and billing infrmatin. Infrmatin required t perate ur Services, such as: infrmatin necessary t secure yur accunt, including yur user name, ther infrmatin relating t yur interactins with ur Services, including requests fr supprt, feedback, payment and the executin f the purchase f ur Prducts, and infrmatin frm publicly and cmmercially available surces, and ther infrmatin which custmers chse t search fr using ur Prducts, including identificatin and backgrund infrmatin, interactins thrugh nline platfrms, interests, prfessinal and persnal data, psts and user sentiment. Usage and navigatinal infrmatin: clickstream infrmatin, such as which search engines ur visitrs use, interactins with digital and ther cntent, IP address, and brwser type. T the extent infrmatin that we cllect, receive r use is infrmatin which relates t an identified r identifiable individual in the Eurpean Ecnmic Area ( EEA ), we will treat such infrmatin as persnal infrmatin as required by applicable law. If yu disclse t us r search fr any infrmatin relating t ther peple in cnnectin with yur use f the Services, yu represent that yu have the authrity t d s and t permit us t use the infrmatin in accrdance with this Privacy Plicy. When yu becme a Babel Street custmer and access ur Prducts, yur use f the Prducts is subject t Babel Street s subscriptin terms and cnditins. If yu d nt want t share the necessary infrmatin t prcess a business transactin with us r if yu d nt accept the applicable terms, yu will nt be allwed t access ur Prducts. The Ways We Cllect Infrmatin We cllect persnal infrmatin in the fllwing ways: Thrugh ur Services: We cllect infrmatin thrugh ur Services, fr example, when yu use a Babel Street prduct, register an accunt with us, visit ur website r ffices, attend a technlgy event, r cntact ur custmer supprt team. 2

3 Frm ther surces: We receive yur infrmatin frm ther surces, at the instructin f ur custmers, such as: publicly and cmmercially available data surces, including news utlets, blgs, message bards, cnsumer sites, scial media pages and platfrms, and traditinal web r deep web searches and custmers and ther individuals, such as referrals r ther cntacts. Hw We Use Infrmatin We use persnal infrmatin fr legitimate business purpses including: Prviding r facilitating the use f ur Prducts: arranging access t ur Prducts creating and administering accunts fulfilling and recrding transactins We engage in these activities t manage ur cntractual relatinship with yu, with yur cnsent, where we have a legal bligatin r authrizatin (such as a public interest) t d s, and/r where we have a legitimate interest. Prduct imprvement: t better understand yu and yur Prduct transactins and uses s that we can fine tune ur fferings t maintain, develp, market and/r imprve ur Prducts and Services We engage in these activities where we have a legitimate interest t d s. Prduct and custmer supprt: t reslve custmer issues r answer custmer questins t infrm and cmmunicate with custmers abut imprvements r updates t ur Services and terms t prvide general custmer supprt We engage in these activities t manage ur cntractual relatinship with yu r where we have a legitimate interest t d s. T deliver marketing cntent and enable scial sharing: t deliver marketing s and cntent with infrmatin abut ur Prducts and ur cmpany t facilitate a scial sharing functinality that yu chse t use If yu are nt a current custmer, but yu have reached ut t us in the past, r we have received yur persnal infrmatin thrugh a technlgy event r ther 3

4 avenue, we may use yur infrmatin t infrm yu abut ur services r future events we will be hsting r attending. If yu are lcated in the EU, we will btain yur cnsent befre sending these types f cmmunicatins. If yu d nt wish t receive such material, r have specific cntact preferences, please cntact us at inf@babelstreet.cm. Please nte that if yu pt-ut f receiving marketing-related s and ther messages frm us, we may still send yu imprtant administrative messages, frm which yu cannt pt-ut. We engage in these activities with yur cnsent r where we have a legitimate interest t d. Participatin in ur crprate events: Where yu chse t attend ur crprate events, such as technlgy cnferences, netwrking events, tradeshws r trainings. We engage in these activities t manage ur cntractual relatinship with yu r where we have a legitimate interest. Aggregating and/r annymizing: We may aggregate and/r annymize infrmatin s that it will n lnger relate t an identified r identifiable individual. We d s t generate ther data fr ur use, which we may use and disclse fr any purpse. We engage in these activities where we have a legitimate interest. Accmplishing ur business purpses: fr accunting, bkkeeping and audits, t verify that ur internal prcesses functin as intended and are cmpliant with legal, regulatry r cntractual requirements fr website administratin, analytics and security t imprve the safety and reliability f ur Services fr fraud and security mnitring purpses, and t address technical issues, fr example, t detect and prevent cyberattacks t prepare r execute a business transactin, such as an investment, rerganizatin, merger, sale, jint venture, assignment, transfer r ther dispsitin f all r any prtin f ur business, assets r stck (including in cnnectin with any bankruptcy r similar prceedings) ( Business Transactin ) t prtect ur rights and t defend against lawsuits t meet ur legal duties, such as requests frm public and gvernment authrities 4

5 We engage in these activities where we have a legal bligatin r authrizatin and/r legitimate interest t d s. Disclsure f Infrmatin We disclse infrmatin in the fllwing ways: T ur third-party service prviders, t facilitate services they prvide t us: These can include prviders f services such as data hsting, payment prcessing, infrmatin technlgy and related infrastructure prvisin, delivery, auditing, and ther services. T a dedicated rganizatin administratr: If yu are a custmer f Babel Street and yur rganizatin has dedicated an Administratr f the Babel Street accunt, that individual may have access t sme f yur infrmatin, such as yur username and the details f yur use f ur Services. T cmply with applicable laws and regulatins r t cperate with gvernment authrities, including law enfrcement: T respnd t a legal r administrative request r rder, r t prvide infrmatin we believe is imprtant. This can include authrities utside yur cuntry f residence. Fr ther legal reasns: T enfrce ur terms and cnditins r t prtect ur rights, privacy, safety r prperty, and/r that f ur affiliates, emplyees, yu r thers. In cnnectin with a Business Transactin: We have a legitimate interest in disclsing r transferring yur Persnal Infrmatin t a third party in the event f a Business Transactin. Such third parties may include, fr example, investrs in Babel Street r an acquiring rganizatin and its advisrs. Security N methd f transferring data ver the internet is ever 100% secure. Hwever, we emply a variety f apprpriate technical and rganizatinal security measures designed t ensure the security f ur Prducts. Yur Rights If yu wuld like t request t review, crrect, restrict r delete persnal infrmatin that yu have previusly prvided t us, bject t the prcessing f persnal infrmatin, r if yu wuld like t request t receive an electrnic cpy f yur persnal infrmatin, yu may cntact us by sending an t inf@babelstreet.cm. We will respnd t yur request cnsistent with applicable law. 5

6 In yur request, please make clear t what persnal infrmatin yur request relates. Fr yur prtectin, we may nly implement requests with respect t the persnal infrmatin assciated with the particular address that yu use t send us yur request, and we may need t verify yur identity befre implementing yur request. We will try t cmply with yur request as sn as reasnably practicable. Please nte that we may need t retain certain infrmatin fr recrdkeeping purpses and/r t cmplete transactins initiated prir t the request. Additinal infrmatin fr the EEA: yu may ldge a cmplaint with a data prtectin authrity fr yur cuntry r regin r where an alleged infringement f applicable data prtectin law ccurs. A list f data prtectin authrities is available at Retentin We retain persnal infrmatin fr as lng as needed r permitted in light f the purpse(s) fr which it was btained and cnsistent with applicable law. The criteria used t determine ur retentin perids include: The length f time we are prviding ur Services t a custmer, r as the custmer instructs. Whether there is a legal bligatin t which we are subject (fr example, certain laws require us t keep recrds f transactins fr specific time perids befre we can delete them). Whether retentin is advisable in light f ur legal psitin (such as in regard t applicable statutes f limitatins, litigatin r regulatry investigatins). Ckies Like mst websites tday, we use ckies n ur website. Ckies are small files that a web server transfers t an individual's cmputer fr functinality and recrdkeeping purpses while visiting that site. We use ckies t imprve yur user experience and the verall quality f ur services, and t facilitate yur nging access t and use f ur site, amng ther things. Ckies may als cnvey infrmatin t us abut hw frequently yu access the Services and allw us t evaluate usage f the Services ver time. Yu can view and manage ckies in yur brwser, including blcking and deleting ckies, thugh brwsers fr mbile devices might nt ffer this visibility. Babel Street has a legitimate interest in understanding hw custmer and ptential custmers use ur website. This infrmatin assists us with prviding mre relevant prducts and services, cmmunicating value t ur custmers and prviding apprpriate staffing and resurces t meet ur custmers needs. We use several types f ckies in ur Services: Analytics ckies, which cllect infrmatin abut the usage f ur website and related statistics n hw users interact with ur site. 6

7 Perfrmance ckies, which help us understand and imprve hw the Services perfrm. Specifically, these ckies allw us t gather data n technical errrs, cllect infrmatin s we can analyze lad balancing n ur site, cnfirm that users can stay lgged in t ur Prducts and cntinually ensure that ur Services remain up and running fr ur custmers and partners. Security ckies, which prcess infrmatin t help us secure ur Prducts, as well as detect fraud and abuse. D Nt Track Signals We currently d nt hnr D Nt Track brwser signals. Links t Other Web Sites This site may cntain links, references r make calls t ther websites. Please be aware that we are nt respnsible fr the privacy practices f thse websites and this Privacy Plicy des nt apply t thse sites. We encurage yu t read the privacy plicy f any website yu visit if yu have questins. Sensitive Infrmatin Unless we request it, we ask that yu nt send us, and yu nt disclse, any sensitive infrmatin (e.g., scial security numbers, infrmatin related t racial r ethnic rigin, plitical pinins, religin r ther beliefs, health, bimetrics r genetic characteristics, criminal backgrund r trade unin membership) n r thrugh the website. Crss-brder Transfers Yur persnal infrmatin may be stred and prcessed in any cuntry where we have facilities r in which we engage service prviders, and, by using and interacting with the Services, yu understand that yur persnal infrmatin will be transferred t cuntries utside f yur cuntry f residence, including the United States, which may have data prtectin rules that are different frm thse f yur cuntry. In certain circumstances, curts, law enfrcement agencies, regulatry agencies r security authrities in thse ther cuntries may be entitled t access yur persnal infrmatin. Sme f the nn-eea cuntries are recgnized by the Eurpean Cmmissin as prviding an adequate level f data prtectin accrding t EEA standards (the full list f these cuntries is available here). Fr transfers frm the EEA t cuntries nt cnsidered adequate by the Eurpean Cmmissin, we design ur Services and terms s that adequate measures are in place, such as standard cntractual clauses adpted by the Eurpean Cmmissin t prtect yur persnal infrmatin. Yu may btain a cpy f these measures by fllwing this link r by cntacting us as set ut in the Cntact Us sectin belw. 7

8 Califrnia Privacy Law If yu are a Califrnia resident, Califrnia Civil Cde sectin permits yu t request infrmatin regarding the disclsure f yur persnal infrmatin by a cmpany t a third party, fr the third party s direct marketing purpses. As we d nt make such disclsures, we are exempt frm this requirement. Children s Privacy Due t the nature f ur business, Babel Street s website and Services are intended fr use strictly by adults. We d nt knwingly slicit r cllect any persnal infrmatin frm children. Changes t Our Privacy Plicy We reserve the right t update r amend this Privacy Plicy frm time t time. The Last Updated date at the tp f this Plicy indicates when the Plicy was last revised. Cntact Us If yu have any questins abut this Privacy Plicy r the privacy practices f Babel Street and yu are in any lcatin utside f the EEA, please cntact us at inf@babelstreet.cm: Babel Street, Inc Library Street, Suite 500 Restn, VA (703) If yu are lcated in the EEA, we have appinted ur EU affiliate, Babel Street, Limited, t act as an EU representative fr Babel Street, Inc. Babel Street, Limited des nt serve as a separate cntrller f persnal data. The nly rle f Babel Street, Limited is that f an EU representative. Fr thse lcated in the EEA, please cntact us at: Babel Street Limited 4th Flr 7/10 Chands Street, Cavendish Square, Lndn, W1G 9DQ 8