Privacy Policy

Effective date: July 10, 2023

This privacy policy describes the personal data we collect, the purposes for which it is used, and your choices regarding its use.

Personal Data We Collect

We will not collect additional categories of personal data or use the personal data we collected for materially different, unrelated or incompatible purposes without providing you notice.

Information That is Not Personal Data

We may create aggregated, de-identified or anonymized data from the personal data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it amongst Translation Cloud Companies and with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

Tracking Tools, Interest Based Advertising And Opt-Out

Translation Cloud Companies and our third-party providers use cookies and other tracking technologies (“Cookies”) on the Services to collect information. Detailed information about the Cookies used (including the purpose for using them), interest-based advertising, how to manage Cookies, and do-not-track signals, can be found in each Translation Cloud Company’s respective Cookie Policy, which is linked in the respective company’s privacy statement.

Why We Share Your Personal Data Amongst Translation Cloud Companies

Our Shared Purposes

Translation Cloud Companies share your personal data amongst each other:

• To co-market, co-promote and cross sell our Services to you.
• To learn how you use and interact with our Services, for the purposes of improving our Services, including by gathering commercial data and internal analytics on those unique users that subscribe to all or more than one of our Services, and gathering internal analytics on how you engage with one Service when integrated on another Service.
• To measure our progress towards corporate goals and key performance indicators, including gathering commercial data related to our subscription Services.
• To enable Translation Cloud LLC. to allow users to sign up for and sign in to multiple Services across Translation Cloud Companies at one time.
• To enable Translation Cloud LLC. to respond to customer inquiries about our Services, including customer support requests.
• To enable Translation Cloud LLC. to respond to data subject requests under applicable privacy laws.
• To distribute and display your content, which may include your username, across one or more of our Services. “Your content”, for purposes of this paragraph, refers only to user generated content you post on our Services. For example, if you post a question or answer on coursehero.com, it may be distributed and displayed on another Translation Cloud Service, and may include your username.
• To protect the rights, property or safety of you, Translation Cloud Companies, or another party, including doing fraud protection, security and debugging.
• To analyze a Translation Cloud Company’s IT and IT security infrastructure, to assess compliance with Translation Cloud security standards and data migration.

Each Translation Cloud Company is considered a controller of personal data for the purposes described above.

How We Share Your Personal Data Amongst Translation Cloud Companies

Your personal data is shared amongst Translation Cloud Companies, as follows:

• To carry out the activities set forth in the Our Shared Purposes section.
• We also share certain systems and technology; for example, we share systems that provide infrastructure to operate our business and Services, manage subscriptions so that you can choose to subscribe and log on to more than one Service with a single account, systems that manage customer support inquiries and data subject requests, and systems that provide analytics.

Marketing Communications

If you sign up to receive marketing communications from a Translation Cloud Company, that Translation Cloud Company will collect your email address as well as other information on a voluntary basis to help tailor communications to you. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email. Alternatively, you can opt-out of receiving marketing communications either through your account settings or by contacting us (see Contact Us section below). Please note that you will continue to receive transactional or account-related communications.

Data Security

We seek to protect your personal data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of personal data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

Examples of data security measures include scanning our Services on a regular basis for security holes and known vulnerabilities in order to make your visit to or use of our Services as safe as possible; maintaining your personal data behind secured networks that are only accessible by a limited number of persons with special access rights to such systems and who are under obligation to keep the information confidential; and implementing a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal data.

Data Retention

For Services requiring an account, the relevant Translation Cloud Company will retain your personal data for as long as you have an open account or as otherwise necessary to provide you with Services. In some cases we retain personal data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information indefinitely in a de-identified, anonymous or aggregated form where that information would not identify you personally, as described in the policy and permitted under applicable privacy laws.

Changes To This Privacy Policy

We are constantly improving our Services, so we may need to change this policy from time to time, but we will alert you to any material changes by placing a notice on the product specific website to which the changes apply, by sending you an email and/or by some other reasonable means.

Additional Terms For Canadian Residents

If you reside in Canada, the following additional terms apply. If there are any conflicts between this section and any other provision of this policy, the provision that is more protective of personal data will apply.

Transfers of Personal Data Outside Canada

We may share your personal data amongst Translation Cloud Companies, with third party service-providers and other third parties that require such information to assist us in providing Services to you. In the course of providing these Services, your personal data may be accessed, collected, stored and processed in the U.S. or other foreign jurisdictions by a Translation Cloud Company or its third party service providers. Translation Cloud Companies and third-party service providers may disclose your personal data in response to a search warrant or other legally valid inquiry or order or as otherwise required or permitted by Canadian, US, or other law (which may include disclosure to US and foreign courts, law enforcement or governmental authorities). In the case of a transfer of personal data to Translation Cloud Companies or third-party service providers that process or store personal data on behalf of a Translation Cloud Company, the Translation Cloud Company and/or third party recipient will have agreed to safeguard personal data and use the information only for the purpose(s) for which it has been provided.

Canadian Resident Rights

Subject to applicable law, you have the right to access, update and correct inaccuracies in your personal data in our custody or control. You can request this by email or by writing to us at the contact information set out in the Contact Us section below. We may request certain personal data for the purpose of verifying the identity of the individual seeking access to his or her personal data records.

Additional Terms For California Residents

This section provides information in accordance with the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act for California residents about how Translation Cloud Companies handle certain personal data collected over the past 12 months. If you are a California resident, you have the rights set forth in this section. For how to exercise these rights, see the Exercising Your CCPA Rights section. If there are any conflicts between this section and any other provision of this policy, the portion that is more protective of your personal data will apply.

California Resident Rights under the CCPA

• Access/Right to Know. You have the right to request certain information about our collection and use of your personal data over the past 12 months, including:
  1. The categories of personal data that we have collected about you.
  2. The categories of sources from which that personal data was collected.
  3. The business or commercial purpose for collecting or selling your personal data.
  4. The categories of third parties with whom we have shared your personal data.
  5. The specific pieces of personal data that we have collected about you.
• Deletion. You have the right to request that we delete the personal data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your personal data to provide you with the Services or complete a transaction or other action you have requested. Please see the Data Retention section on our purposes for retaining limited personal data.
• Right to Opt-Out of Certain Activities. In some circumstances, you have the right to opt out of the sale of your personal data or the sharing of your personal data specifically for cross-contextual behavioral advertising purposes. Please note, however, that we do not sell your personal data or share your personal data for cross-contextual behavior advertising, and have not done so over the last 12 months.

Exercising Your CCPA Rights. To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected personal data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both criteria will be considered a “Valid Request”. We may deny requests that do not meet these criteria as permitted by applicable data privacy laws. You may appeal any denial by contacting the Translation Cloud Company relevant to your request; you can find the contact details for the relevant company in Part Two below. We will only use personal data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request. Please see the Contact Us section for where to submit a Valid Request.

Authorized Agent. You may authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf. Non-Discrimination. We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of personal data that we receive from you.

Categories of Third Parties We Have Shared Your Personal Data With

For the categories of third parties with whom a Translation Cloud Company shares the personal data it collects and has collected about you over the past 12 months, please read the product specific section in Part Two.

Your Rights under California’s Shine-the-Light Law

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of personal data to third parties for such third parties’ direct marketing purposes. To submit such a request, please see the Contact Us section and specify “California Shine the Light Request” in the subject line.

Additional Terms For Residents of Other US States

This section provides information in accordance with US States other than California that may now or in the future have enacted state data privacy laws, including but not limited to the Virginia Consumer Data Privacy Act (the “VCDPA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CDPA”), the Utah Consumer Privacy Act (“UCPA”), and the Iowa Consumer Data Protection Act (“ICPA”). For residents of these US States, this section provides Information about how Translation Cloud Companies handle certain personal data that we have collected about you. If you are a resident of one of these US States, you have the rights set forth in this section. For how to exercise these rights, see the Exercising Your US State Privacy Rights section. If there are any conflicts between this section and any other provision of this policy, the portion that is more protective of your personal data will apply.

Rights Under Effective US State Laws

• Right to Know/Access/Portability. You have the right to confirm whether or not we are processing your personal data and to access such personal data. You may request for this information to be provided to you in a readily usable format, to the extent it is technically feasible.
• Right to Correct. Residents in certain states have the right to correct inaccuracies in their personal data, depending on the type of personal data and our purposes for processing it.
• Right to Delete. You have the right to request that we delete the personal data that we have collected about you.
• Right to Opt-Out of Certain Activities. In some circumstances, you have the right to opt out from (i) the sale of your personal data, (ii) the processing of your personal data for purposes of targeted advertising, (iii) the processing of your personal data for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. However, please note that we do not sell and have not sold your personal data. Additionally, Translation Cloud does not process and has never processed your personal data for the purposes described in (ii) and (iii) above.

Exercising Your US State Privacy Rights. To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected personal data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both criteria will be considered a “Valid Request.” We may deny requests that do not meet these criteria. You may appeal any denial by contacting the Translation Cloud company relevant to your request; you can find the contact details for the relevant company in Part Two below. We will only use personal data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request. Please see the Contact Us section for where to submit a Valid Request.

Non-Discrimination. We will not discriminate against you for exercising your rights under applicable US State privacy laws. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights. However, we may offer different tiers of our Services as allowed by applicable data privacy laws with varying prices, rates or levels of quality of the goods or services you receive related to the value of personal data that we receive from you.

Additional State Law Privacy Rights

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal data to third parties who intend to license or sell that personal data. Please note that we do not currently sell your personal data as sales are defined in Nevada Revised Statutes Chapter 603A.

Complaints

If you have an unresolved privacy concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request . Under certain conditions, you may also be entitled to invoke binding arbitration for complaints not resolved by other means.

If you are a European Economic Area or UK resident, please see the Additional Terms for European Economic Area and UK Residents section for where to lodge a complaint.

Additional Terms For European Economic Area And UK Residents

If you reside in the European Union, Lichtenstein, Norway or Iceland (collectively, the European Economic Area or ” EEA”) or the United Kingdom, the following terms apply. If there are any conflicts between this section and any other provision of this policy, the provision that is more protective of personal data will apply.

Legal Basis for Use of Your Personal Data

• Contractual Necessity: Each Translation Cloud Company processes personal data as a matter of contractual necessity, meaning that we need to process the data to perform under our product specific Terms of Use or Terms of Service with you, which enables us to provide you with the Service. This includes for the purposes of:
  1. Providing users with the products, services or information they request.
  2. Providing customer support and assistance for the Services.
  3. Personalizing the Services, website content and communications based on users’ preferences.
  4. Creating and managing user accounts or user profiles.
  5. Processing orders or other transactions; billing.
  6. Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Translation Cloud Companies or the Services.
  When we process personal data due to contractual necessity, failure to provide such personal data will result in your inability to use some or all portions of the Services that require such information.
• Legitimate Interest: Each Translation Cloud Company processes personal data when it furthers its legitimate interests. This includes:

  Purposes for Processing Providing support and assistance for the Services. Learning how you use and interact with one or more of our Services for the purposes of improving the Services, including testing, research, internal analytics and product development. To measure our progress towards corporate goals and key performance indicators, including gathering commercial data related to our subscription Services. Personalizing the Services, website content and communications based on users’ preferences. Marketing and selling the Services, including co-market, co-promote and cross sell. Showing you advertisements, including interest-based or online behavioral advertising. Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Translation Cloud Companies or the Services. Sending emails and other communications to you as our customer according to your preferences or that display content that we think will interest you. Preventing, detecting and investigating security incidents and potentially illegal or prohibited activities (such as fraud). Protecting the rights, property or safety of you, Translation Cloud, or another party. Enforcing any agreements with you, including our Terms of Use or Terms of Service. Completion of corporate transactions.

  Legitimate Interest Relied On In our interest to operate and manage our business, including providing customer support. In our interest to understand how our customers use our Services and to improve and develop our products and Services. In our interest to understand how our customers use our Services and to improve and develop our products and Services. In our interest to improve our products and Services for our users, including to personalize the Services for users. In our interest to market, advertise and promote our products and Services to users. In our interest to market, advertise and promote our products and Services to users. In our interest to operate and manage our business, including to handle your requests and inquiries. In our interest to improve our products and Services for our users, including to personalize the Service for users. In our interest, and the interests of our users, to ensure the safety and security of our Services. In our interest to protect our rights and property, and the safety of our staff. It is also in our interest, and the interest of our users, to protect the rights, property and safety of our users. In our interest to ensure that our Services are used in accordance with our terms. In our interest to operate and manage our business in the event of a proposed or actual business sale.

• Consent: In some cases, a Translation Cloud Company processes personal data based on the consent you expressly grant to it at the time it collects such data (which you may withdraw at any time after giving it, as described in this policy). For example, we process your personal data to send you marketing communications where you have consented to such use. We may also obtain your personal data through the use of advertising or tracking cookies based on your prior consent and use your personal data for showing you advertisements, including interest-based or online behavioral advertising. We may furthermore share your personal data amongst Translation Cloud Companies for marketing purposes, with your consent. When we process personal data based on your consent, it will be expressly indicated to you at the point and time of collection. You have the right to withdraw your consent at any time. We refer to the EEA and UK Resident Rights section below for further information.
• Legal obligation: Each Translation Cloud Company processes your personal data where necessary to fulfill its legal obligations under applicable law, regulation, court order or other legal processing (e.g. subpoenas or warrants). This includes for the purposes of:
  1. Fraud protection, security and debugging.
  2. Responding to data subject requests under applicable privacy laws.
  3. Processing orders or other transactions; billing.
  4. Preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
  5. Data retention and administration obligations.
  6. Complying with requests of competent supervisory authorities and legal agencies.
• Other Processing Grounds: From time to time, a Translation Cloud Company may also need to process personal data if it is necessary to protect the vital interests of you or others, or if it is necessary for a task carried out in the public interest.

EEA and UK Resident Rights

• Access: You can request access to the personal data we hold about you.
• Rectification: If you believe that any personal data we hold about you is incorrect or incomplete, you can request that we correct or supplement such data. You may correct some of this information directly by logging on to your account.
• Erasure: You can request that we erase some or all of your personal data from our systems. Under the GDPR and the UK GDPR, this right is subject to certain exceptions. Please see the Data Retention section on the purposes for which we retain limited personal data.
• Withdrawal of Consent: If we are processing your personal data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your personal data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
• Portability: You can ask for your personal data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your personal data for certain purposes, such as for direct marketing purposes.
• Restriction of Processing: You can ask us to restrict further processing of your personal data.

Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include personal data, if necessary to verify your identity and the nature of your request.

If you wish to exercise any of your rights, please see the Contact Us section of this policy.

Cross Border Transfers of Personal Data

Translation Cloud Companies are located in the United States, Bulgaria, Ukraine, and may continue to grow in other countries. We also have service providers both in the United States and throughout the world. As such, Translation Cloud Companies and our service providers may transfer your personal data to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. When we transfer information about individuals based in the EEA or UK outside of those countries, we will take appropriate measures to safeguard the transfer as required by applicable law, including by using the European Commission-approved standard contractual data protection clauses or following an adequacy decision by the EU Commission. If you do not want your personal data transferred outside of the EEA or UK, please do not submit any personal data to us or use our Services. You may always contact us to request a copy of the transfer measures that we have taken to safeguard the transfer of your personal data.

Complaints

You have the right to lodge a complaint about our practices with respect to your personal data before a supervisory data protection authority.

• If you are in Europe, an up-to-date list of data protection authorities is available at https://edpb.europa.eu/about-edpb/board/members_en .
• If you are in the Netherlands, the data protection authority is the Autoriteit Persoonsgegevens, available at: https://autoriteitpersoonsgegevens.nl .
• If you are in the UK, the data protection authority is the UK Information Commissioner’s Office available at https://ico.org.uk/ .

Contact Us

If you subscribed to more than one Service at checkout and would like to exercise any of the rights under applicable privacy law, you can submit your request to Translation Cloud LLC and indicate so on the request; Translation Cloud LLC will process it accordingly. Otherwise, please contact the Translation Cloud company relevant to your request; you can find the contact details for the relevant company.

Translation Cloud LLC
11 Broadway, STE 552
New York, NY 10004 USA