Last Updated: June 19, 2020
Protecting the privacy and Personal Data of our users is of utmost importance to SYSTRAN. SYSTRAN is collecting and processing personal data in compliance with the General Data Protection Regulation (GDPR) put in place by the European Commission since May 25th 2018 and with the French personal data regulation including the law n° 78-17 of 6 January 1978 as amended and the law n° 2018-493 on the protection of personal data (hereafter designed as “Data Protection Regulation”).
For the purposes of this Policy, the term “Personal Data” refers to any data that relates to you and allows to identify you directly or indirectly, regardless of the Device you use. The term “Device” refers to the physical equipment (computer, tablet, smartphone, telephone, etc.) that you use to view and navigate on SYSTRAN websites and/or to use our Services.
- Visitors to our websites ;
- Users of our online Services.
1. Data controller
SYSTRAN has control over the collection and the processing of Personal Data collected during the visit of its websites and use of its Services.
Our data controller is:
5 rue Feydeau – 75002 Paris – France
Tél. : +33 (0)1 44 82 49 00
For any questions on personal data protection please contact email@example.com.
2. Personal Data collected and/or processed by SYSTRAN
The information in relation to you which is collected, processed or stored by SYSTRAN through your use of the Services is of different types:
- Personal Data you voluntarily supply when you subscribe, order, complete a form or register for certain Services:
- First Name, Last Name, Email Address, Company (if applicable), Phone Number, Country.
- Additional Billing Information (e.g.: Postal Address) if the payment for the Services is directly managed by SYSTRAN.
- Non-personally identifiable information, which includes tracking information collected as you navigate through our Services:
- IP Address, access logs
- Financial and payment data:
- information about your orders, VAT number
- Payment related information:
- if payment of the Services is directly managed by SYSTRAN: wire-transfer ID or check number, bank name;
- if payment is done through Third-Party – transaction ID
SYSTRAN will never access, process nor store your credit card information.
- Personal preferences;
- User Interface (UI) and/or Cookie preferences.
Cookies are small pieces of text sent by your web browser to a website during your visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognize you and make your next visit easier and the Service more useful to you.
You can find detailed information about how Google uses your data in Google’s privacy statement: www.google.com/policies/privacy/
The legal basis for using Google Analytics is your consent. You can disable Google Analytics at any time by downloading and installing a browser module available at: http://tools.google.com/dlpage/gaoptout.
User event data associated with cookies on Google Analytics is deleted after thirteen (13) months.
B. Personal Data
SYSTRAN does not collect information that personally identifies you as an individual except when you provide such specific information on a voluntary basis. There may be occasions where specific Personal Data (Name, Email, Phone Number, Company) are requested before you can enter certain sections of SYSTRAN’s website as part of the registration process for the Services, or as part of your continued use of the Services. In all such cases, SYSTRAN will collect only Personal Data that is voluntarily provided by you and undertakes that such information will be kept strictly confidential.
3. Consent to processing your Personal Data by SYSTRAN
By returning or submitting a form with your Personal Data to SYSTRAN, you consent that SYSTRAN processes your Personal Data for the purposes described in clause 4 below.
4. Purposes of the Personal Data processing by SYSTRAN
A. Anonymous information
The log file information allows SYSTRAN to attempt to better target your preferences.
Cookies allow us to personalize the Services. For instance, once you register for a Service online, a cookie is written to your computer to record your personal choices (e.g. language pair).
Anonymous Collected Information obtained through log files is used and analyzed only at an aggregate level to help SYSTRAN understand subscribing and purchasing patterns trends and patterns and to perform statistical analyses to improve the Services. SYSTRAN also uses anonymous Collected Information for Services’ development purposes.
If you do not want anonymous Collected Information used in this manner, you can disable or delete the cookies on your computer.
B. Personal Data
Once you have accepted to provide your Personal Data, it will be used by SYSTRAN first to provide you with the Services, but also to attempt to better meet your needs, inform you of company news and new Services, target and provide personalized offers and Services that SYSTRAN knows you may be interested in.
If you change your mind and do not want your Personal Data to be used in this manner anymore, you can opt-out during the registration process or change your account information.
5. Legal bases of the Personal Data processing by SYSTRAN
Your Personal Data is collected and processed on the following legal bases:
- In the context of the execution of a contract;
- For purposes of legitimate interest;
- On the basis of your consent as set forth in Article 3 above;
- In order to ensure compliance with our legal and regulatory obligations.
6. Recipients of your Personal Data
Your personal data collected from our website is mainly processed by SYSTRAN internal services. However, part of your personal data can be transferred to the following recipients, depending on the processing:
- PayPal and/or Stripe for payment processing;
- Zendesk for managing support cases;
- Salesforce for Customer Relationship Management.
For these use cases only, your personal data may be transferred to a country outside the European Union. In this case, SYSTRAN undertakes to ensure that these transfers are carried out in compliance with the Data Protection Regulation or with regulations offering an adequate and equivalent level of protection.
7. Retention period of your Personal Data
Your personal data are only retained for as long as strictly necessary to fulfil the purposes for which they are collected and processed, in particular to offer you the Services.
For subscribed users to SYSTRAN Translate offers, account information (login and email address, company information) are stored for as long as the service is provided and deleted after five (5) years of inactivity.
It is reminded that content or submitted for being processed by our services will be stored only for the time technically required to provide the services. However, SYSTRAN will create and store meta information necessary for security, subscription management and billing purposes (such as number of requests, language pairs and model used and quantity of text submitted to process). As provided in Article 10, you are not allowed to process content containing Personal Data.
Anonymous navigation and traffic information are stored for thirteen (13) months in Google Analytics (see chapter 2A).
Personal Data for a prospective customer that does not respond to any solicitation may be retained for three (3) years.
Nevertheless, your personal data may be kept for a longer period of time when legal and regulatory obligations impose it on SYSTRAN.
8. SYSTRAN’s obligations in relation to Personal Data
Any Personal Data you submit through SYSTRAN’s websites will be held in the strictest confidence. To ensure this, all forms on our websites that send Personal Data to a database that may be used in the future, e.g. mailing lists, registration, etc., have check boxes where you specify whether or not you would like to receive information from us in the future. Forms used just to send emails, post messages, etc., do not include the option, but will never be used to send information. If you choose to receive information from us, each message will also include instructions on how to “unsubscribe” from future mailings should you wish to cancel.
SYSTRAN complies with the principles of the General Data Protection Regulation (GDPR) put in place by the European Commission since May 25th, 2018.
In accordance with the Regulation, SYSTRAN identifies all the processing operations carried out in a register of operations that we leave at the disposal of the CNIL (French Supervisory Authority).
SYSTRAN has implemented technologies and put in place physical, electronic and managerial procedures to ensure the confidentiality, integrity and security of the processing of Personal Data and protect the stored Personal Data against accidental or unlawful alteration, unauthorized disclosure or access or improper use. SYSTRAN’s employees, processors or any other person acting under the authority of SYSTRAN as controller, who have access to Personal Data, are obliged to respect your privacy and the confidentiality of your Personal Data.
SYSTRAN will not sell, make available to, or share Personal Data relating to you with, third parties without your consent, unless (i) required to do so by law or by judicial order or (ii) if SYSTRAN in good faith believes that such action is necessary to (1) comply with the law or with legal process; (2) protect and defend SYSTRAN’s rights and property; (3) protect against misuse or unauthorized use of the Services; or (4) protect the personal safety or property of SYSTRAN’s users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions).
9. Your rights in relation to your Personal Data
You have the following rights in relation to your Personal Data:
- A right to be informed: you are entitled to receive information from SYSTRAN (please contact firstname.lastname@example.org) regarding the processing of your personal Data. The information will be provided in a concise, transparent, intelligible and easily accessible document, written in clear and plain language, and free of charge;
- A right to access to your Personal Data, without constraint at reasonable intervals and without excessive delay. A right to rectify: you are entitled to have your Personal Data rectified if inaccurate or incomplete and SYSTRAN will respond to a rectification request within one (1) month if not deemed complex;
- The right to erasure: if you request SYSTRAN to erase your personal data, we must comply easily and securely, as long as there is no compelling reason for possession and continued processing.
- A right to object, on legitimate grounds, and to withdraw your consent, to the processing of your Personal Data. You also have the right to object, on request and free of charge, to the processing of Personal Data that SYSTRAN anticipates being processed for the purposes of direct marketing.
- A right to cancel or limit the processing of your Personal Data, which entails that in certain cases you can request us to temporally suspend the processing of the data or that we keep them longer than necessary when you may need it;
- A right to provide instructions regarding the storage, deletion or disclosure of your personal data after your death;
- A right to request the portability of your personal data: you are entitled to receive the personal data that you made available to us in a structured, commonly used and machine-legible format, to be able to transmit them to another entity directly.
You may exercise your rights free of charge by sending to us an e-mail (to a single e-mail address email@example.com), simply informing us of the reason of your request and the right that you wish to exercise. If we consider necessary to identify you, we may request you to provide us with a copy of a document evidencing your identity.
Finally, we inform you that you have the right to file a claim before the responsible data protection regulatory authority, in particular, before the French Data Protection Authority (Commission Nationale de l’Informatique et des Libertés).
10. Texts and Translations
The data that you translate with our online services is not stored permanently and not shared to any of our customer nor third party. When using our services in an anonymous way (for free SYSTRAN services that do not require to sign in), we may store the texts and translations for a limited period of time for algorithm improvements purposes. The texts submitted and translations logged are not linked in any way to any personal information, such as an IP address.
Any text submitted to our Services while signed in with a SYSTRAN Account aren’t stored and are used only for the necessary purpose of generating the translation and providing the service.
For more information on our online translation tools usage, please refer to SYSTRAN’s Terms of Service: https://www.systransoft.com/systran/policies/terms-of-service/.
Nevertheless, please remind that you must not use our online translation tools to translate texts containing personal data of any kind and that you should check out our professional secured solutions catalog here: https://www.systransoft.com/translation-products/ for GDPR compliance. In case of non-compliance with this obligation, you solely bear liability for GDPR compliance. SYSTRAN shall not be held liable on this basis.
11. Contact SYSTRAN