1. INTRODUCTION

1.1 This Privacy Notice is intended to provide you with information on how EasyTranslate A/S, Titangade 9, 11, 2200 N Copenhagen, CVR 33240562 ("EasyTranslate", "we", "us", "our") collects and processes your personal data which you have given to us, or we have collected from you. 

1.2 We will only process your personal data in accordance with this Privacy Notice and applicable law to which we are subject, including the General Data Protection Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the "GDPR") and the Danish Data Protection Act No. 502 of 23 May 2018 supplementing the GDPR, any amendments thereto and other such legislation supplementing these rules. 

1.3 EasyTranslate is the data controller in relation to your personal data in the below situations. You can contact EasyTranslate by sending an email to gdpr@easytranslate.com. 

1.4 EasyTranslate may also act as a data processor for our customers in some cases. For more information see below Section 8. 

1.5 We use third party suppliers who are directly contracted with you. Apps and websites offered by third parties are subject to terms and conditions and privacy notices which are not under EasyTranslate’s control, and EasyTranslate is not a data controller for the processing of personal data in any such apps or websites. This also applies to third parties that are linked to or otherwise promoted at our website. We have not checked and approved the content of third-party apps or websites or the terms and conditions or privacy notices governing the use of third-party apps or websites and we have no liability for any third-party apps or websites you sign up to and use in connection with our services. We recommend that you carefully review and consider terms and privacy notices offered by any third parties before using those apps or websites, including providing them with the personal information they require. 

EasyTranslate AS THE DATA CONTROLLER.

2. THE DATA WE COLLECT, THE PURPOSE, AND THE LEGAL BASIS FOR PROCESSING

2.1 When you use our website, we collect personal data about you, including your referral URL, your browser type, your search terms used and other user behaviour on our website, your IP address including your network location and information about your computer, date, and time of your visit. 

2.1.1 The purpose of our processing is to optimise the user experience, our digital services, and applications and to market our services to you. 2.1.2 The legal basis for our processing of your personal data follows article 6 (1) (f) (legitimate interest) of the GDPR. 

2.1.3 We collect data automatically by use of cookies. Our use of cookies other than technical necessary cookies are subject to your prior consent. The information will not be used to identify you. You may read more about the use of cookies in our cookie policy here. You may withdraw or change your consent by rejecting cookies in the “Consent settings” or by blocking cookies in your web browser. 

2.2 When you sign up for direct marketing/newsletters, we collect personal data about you, including your contact information, your search terms used and other user behaviour, your IP address including your network location, and information about your computer, date, and time of your visit. 

2.2.1 The purpose of our processing is to send you direct marketing/newsletters which you have signed up for. The purpose of our processing is also to optimise your direct marketing experience, which is in our legitimate interest. 

2.2.2 The legal basis for our processing of your personal data follows article 6 (1) (f) (legitimate interest) of the GDPR. 

2.3 When you communicate with us via e-mail or use the chat-function on our website, we may collect data about your identity, such as your name and email address and the information you have provided when contacting us. 

2.3.1 The purpose of our processing is to communicate with you and respond to your questions and other requests. 

2.3.2 The legal basis for our processing of your personal data follows article 6(1) (f) (legitimate interest) of the GDPR. 

2.4 When you order a translation, we collect personal data about you, including your contact, professional and billing information. We further collect information concerning your purchases. 

2.4.1 The purpose of our processing is to perform the service(s) you have requested. We use your information to create and manage your order, to communicate in regards and assist you in your order, and to invoice you. We further collect information to customise your experience. The purpose of our processing is to perform our contract, and it is in our legitimate interests to optimise your customer experience. We also process the information to comply with our legal obligations under applicable tax and bookkeeping legislation. 

2.4.2 The legal basis for our processing of your personal data follows article 6 (1) (b) (performance of contract), (c) (legal obligation) and (f) (legitimate interest) of the GDPR. 

2.4.3 We will collect the personal data directly from you. 

2.5 When you subscribe to the platform, we collect personal data about you, including your contact, professional and billing information. We further collect information concerning your purchases. Your payment data is administered by Stripe, acting as a third-party data controller. We refer to Stripe’s Privacy Policy for further information on their processing of your personal data. 

2.5.1 The purpose of our processing is to perform the service(s) you have requested. We use your information to create and manage your order, to communicate in regards and assist you in your order, to create and manage your platform account, to assist you in the platform usage, and to invoice you. We further collect information to customise your experience. The purpose of our processing is to perform our contract, and it is in our legitimate interests to optimise your customer experience. We also process the information to comply with our legal obligations under applicable tax and bookkeeping legislation. 

2.5.2 The legal basis for our processing of your personal data follows article 6 (1) (b) (performance of contract), (c) (legal obligation) and (f) (legitimate interest) of the GDPR. 

2.5.3 We will collect the personal data directly from you.

2.6 When you, as a subscriber to the platform, make use of the translation tools and services available at the platform, including the HumanAI Translate tool, machine translation and content generation and edit tools hosting of material prior and subject to translation, sourcing of external translators etc. we will act as a data processor to you. For more information see below Section 8. 

2.7 When you, as a subscriber to the platform, make use of other functions available we will act as data controller. This includes: 

2.7.1 When you use the chat function to communicate with external translators that you have sourced through the platform, we will process your name and contact details and the content of the communication only to provide you and the external translator the ability to communicate through the platform. We may access the communication to ensure that deadlines agreed between you and external translators are being met and generally to ensure timely and proper delivery. We will not access or process the content of your communication for other purposes than to provide the service and to ensure compliance with our policies for the use of the platform. You are urged to limit the inclusion of personal data in the communication to what is necessary for the purpose. The legal basis for our processing is to perform our contract and to pursue our legitimate interest to monitor compliance with agreements and our policies cf. article 6 (1) (b) (performance of contract) and (f) (legitimate interest) of the GDPR.

2.7.2 If you leave testimonials or make use of the option to rate your satisfaction and general experience with an external translator, we will process your testimonial or rating to make it available to other users of the platform for transparency purposes and for our general monitoring and quality assessment to maintain a high level of quality among the external translators using the platform. The legal basis for our processing is our legitimate interest to ensure transparency and quality cf. article 6 (1) (b) (performance of contract) and (f) (legitimate interest) of the GDPR. 

2.7.3 At the request of you or the external translator we may assist to resolve disputes between you, including in relation to the quality of the translation. If so, we will process your identity, the agreement you have concluded with the external translator and the content of the translation to evaluate the quality and to mediate and seek to resolve the dispute between you and the external translator. The legal basis for our processing is our legitimate interest to assist our users to resolve disputes cf. article 6 (1) (f) of the GDPR. 

2.7.4 To ensure and maintain a high level of quality among the external translators available in the platform we may from time-to-time access translations performed by one or more specific translators. This may include translations performed for you. We do this only to evaluate the quality of the translation and have no intention or purpose to process any personal data included in the translation. The legal basis is our legitimate interest to maintain a high level of quality cf. article 6 (1) (f) of the GDPR. 

3. DISCLOSURE OF YOUR PERSONAL DATA

3.1 Your personal data is disclosed to third parties who process personal data on behalf of EasyTranslate, and therefore acts as our data processors. We use third parties for customer support, customer relationship management, email marketing, invoicing, web analytics, business analytics and as hosting providers. We may also use third party translators to assist us in performing the translation service(s) you have requested from us or in relation to specific or general quality assessments. When you are using the HumanAI Translate tool and content generation and edit tools we also disclose your data to third parties who process personal data on behalf of EasyTranslate, and therefore acts as our data processors. We have entered into data processing agreements that comply with article 28 of the GDPR with all our data processors to ensure that such data processors implement appropriate organisational and technical security measures in such a way that the processing complies with the requirements of the GDPR and ensures the protection of your rights. 

4. TRANSFER OF YOUR PERSONAL DATA TO THIRD COUNTRIES

4.1 Some of our data processors, such as Open AI, HubSpot and Twilio (Aircall), are established in the United States of America (USA). We also use external translators which may be established in a non-EU/EEA country. The appropriate safeguards to transfer personal data to the USA or other non-EU/EEA countries which are not considered by the EU commission to provide an adequate level of data protection are secured by EU Commission's Standard Contract Clauses (article 46 of the GDPR). If you would like further information about our data processors established outside the EU/EEA and the safeguards in place to transfer personal data, you can request documentation hereof by sending us an email to gdpr@easytranslate.com. 

Please also be advised that your personal data may also be transferred to a country outside the EU/EEA by our use of cookies on our website. You can read more on this in our cookie policy here. 

5. YOUR RIGHTS

5.1 Under certain circumstances, you have a number of rights in relation to our processing of your personal data.

5.2 If you want to make use of your rights, please contact EasyTranslate by sending an email to gdpr@easytranslate.com.

5.3 Please note that your platform account settings give you full control over your data. Here you can see, edit, export, and delete your data, at the click of a button.

5.4 The right of access by the data subject

5.4.1 You have the right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 

5.5 The right to rectification

5.5.1 You have the right to request correction of your personal data that we hold about you. If you become aware that the personal data we process is inaccurate, we encourage you to contact us in writing which will enable you to have any incomplete or inaccurate information we hold about you corrected. 

5.6 The right to erasure ("the right to be forgotten")

5.6.1 You may have the right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. To the extent the continued processing of your personal data is necessary, for example in order for us to comply with our legal obligations or for legal requirements to be established, enforced or defended, we are not required to delete your personal data. 

5.7 The right to restriction of processing

5.7.1 You may have the right to request the restriction of processing of your personal data to consist only of storage. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it. 

5.8 The right to data portability

5.8.1 You may have the right to obtain personal data that you have provided us with, in a structured, commonly used, machine-readable format and have the right to request a transfer of that information to another data controller. 

5.9 The right to object

5.9.1 You have the right to object to our processing of your personal data at any time when it relates to our direct marketing efforts towards you. 

5.9.2 Furthermore, you have the right to object to our processing of your personal data at any time, for reasons relating to your personal life, where we are relying on a legitimate interest as legal basis for processing, cf. section 2. 

5.10 The right to withdraw your consent

5.11 You have the right to withdraw a consent you have provided us with for the purpose of processing your personal data. If you wish to withdraw your consent, please contact us by using the contact information specified below. For cookies, you can withdraw your consent by changing your settings here.

5.12 The right to lodge a complaint

5.13 You have the right to lodge a complaint regarding EasyTranslate's processing of your personal data. A complaint can be lodged with the Danish Data Protection Agency (Datatilsynet) at www.datatilsynet.dk or any other supervisory authority in your country.

6. DATA RETENTION

6.1 The personal data stored based on your user behaviour on our website will be deleted at the latest according to our cookie policy, which can be accessed here.

6.2 Personal data about you collected when you order a translation or subscribe to the platform, will be stored for the current year plus five years.

6.3 Personal data about you collected when you sign up to our platform will be stored until you delete your account or have been inactive for 1 year. 

6.4 We do further reserve the right to retain your personal data for an extended period of time if deemed necessary to establish, exercise, or defend a legal claim or in order to meet a legal obligation.

7. DATA SECURITY

7.1 We have put in place appropriate security measures to prevent your personal data from an accidental or unlawful destruction, loss, alterations, unauthorised disclosure, or misuse of, or access to personal data transmitted, stored, or otherwise processed. 

7.2 We have limited access to your personal data to employees and contractors who have a relevant and reasonably required need to access your personal information to perform their work. 

8. EasyTranslate AS A DATA PROCESSOR

8.1 Performing translation tasks, EasyTranslate acts as the data processor for our customers if the document that is translated contains personal data. We also act as a data processor in the provision of the translation tools and services available in the platform, including the HumanAI Translate tool, machine translation and content generation and edit tools, hosting of material prior and subject to translation, sourcing of external translators, etc. For a detailed description of EasyTranslate‘s role and responsibilities as a data processor, please refer to the Data Processing Agreement (DPA). You can find EasyTranslate‘s DPA here. 

8.2 EasyTranslate encourages you, the data controller, to anonymise or pseudonymize files before transferring them to EasyTranslate to minimise the flow of personal data (Data Minimisation, article 5 of the GDPR). 

We encourage you, the data controller, to use AI responsibly, ensuring that it aligns with ethical standards and respects user privacy and fairness. We recommend that data controllers implement practices such as regular monitoring for bias, transparency in AI decision-making, and adherence to data protection regulations, like GDPR. Content processed through AI should avoid including any racial, political, or otherwise sensitive material to ensure neutrality and inclusivity. By using AI thoughtfully, data controllers can help build trust, minimise risks, and enhance the value of AI-driven translations while upholding integrity and accountability in all operations.

9. CONTACT INFORMATION

9.1 If you have any questions regarding this Privacy Notice or wish to exercise your rights, please send us an email to gdpr@easytranslate.com.

10. CHANGES TO THIS PRIVACY NOTICE

10.1 We may make changes to this Privacy Notice; the latest version of this Privacy Notice will be available at any time on our website www.easytranslate.com.

10.2 This Privacy Notice has last been updated on November 12th, 2024.