Current version. Last updated - [23.12.2021]
PPCN describes the privacy practices for our website and technology platform, which is located at https://www.smartcat.com/ (“Smartcat Platform”), products and services we offer on Smartcat Platform. This document helps you to understand about the personal data we collect, how we process and use it, the rights you have over your personal data, the measures we take to keep it safe plus the details of the specific consent you give us in respect of your personal data.
PPCN is based on and reflects various mandatory requirements of applicable laws around the world, where Smartcat Platform is operating, that govern the protection of personal data, including but not limited to Regulation (EU) 2016/679 of the European Parliament and of the Counsel 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, and repealing Directive 95/46/EC (the so called “General Data Protection Regulation” or “GDPR” as sometimes abbreviated).
What is a personal data?
Personal data is any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
What personal data of yours we collect?
1) Account Information
There is some mandatory information that you are always giving us as a starter to get registered on Smartcat Platform:
- surname / family name;
- email address;
- account type;
Plus there is supplementary information you may wish to give us to expand your profile and use the most of Smartcat Platform:
- phone number;
- Skype username;
- education, including the country where you graduated, degree received, graduation year and major;
- languages, including native language;
- work experience; skills; rate for translation, interpreting, project management, etc; preferred specialization (industry / subject) for translation, editing, proofreading or MT post-editing jobs;
- country of residency; time zone you are living in;
- bank account details, credit or debit card details, PayPal account details, Yandex Money details, QIWI details, WebMoney details, +ePayments (Smartcat Mastercard) details;
- certificate of registration as self-employed, plus a copy of your relevant work documents, certificates, diplomas, or any other proof of experience, training or special expertise; CV.
2) Additional Information
If you contact us or participate in a survey, Smartcat community discussion, we collect the information you submit such as your name, contact information, and message.
If you decide to participate in one of Smartcat Localization Meetups, we collect the information you submit such as your first and second name, e-mail, your company name and your job title.
3) Information From Third-Party Services
If you choose to connect your account on Smartcat Platform to your account on another service, we may receive information from the other service. For example, if you connect to Facebook or Google, we may receive information like your name, profile picture, age range, language, email address. You may also choose to grant us access to other personal data from another service. You can stop sharing the information from the other service with us by removing our access to that other service.
4) Payment and Card Information
Smartcat Platform supports payments and transactions with third parties. If you want to use this feature, you must provide certain information for identification and verification, such as your name, credit, debit or other card number, card expiration date, and CVV code. For other payment methods using bank transfer, PayPal, Yandex Money, QIWI, WebMoney, Smartcat Mastercard (ePayments) payment systems you may need to provide account and other details.
Your personal data relating to you as a cardholder is stored in a highly secure environment and handled by our payment partner. Its services are certified to PCI-DSS Level 1, which is the highest level of certification within the Payment Card Industry Data Security Standard.
Please note that you can remove this information anytime from your account using your account settings.
Note that third-party payment processors may retain this information in accordance with their own privacy policies and terms.
5) Location Information
We may get your approximate location from your IP address.
6) Usage Information
When you access or use Smartcat Platform, we can receive certain usage data. For instance, files uploaded, profile filled, projects completed, etc. plus records of your user experience (full users' sessions).
We also collect data about the computers and other electronic devices you use to access or use Smartcat Platform, including IP addresses, browser type, language, operating system, the referring web page, pages visited, location and cookie information.
Why and how we use your personal data?
We use the information we collect for the following purposes:
1) To provide and maintain Smartcat Platform and its features
Using the personal data we collect from you, we are able to deliver the services and features of Smartcat Platform to you and perform the Terms entered with you. For example, we need to use your profile information to be able to offer your services to other users, allow other users to find and connect with you using the search engine and possible bring you translation work. The use of your personal data gives you better customer support.
2) To improve and develop Smartcat Platform
We use the personal data we collect from you to improve Smartcat Platform and further develop it. For example, we use the information to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys; and develop new features and services of Smartcat Platform.
3) To communicate with you
We use your personal data when needed to send you notifications and updates and respond to you when you contact us. We also use your information to promote new features or services that we think you would be interested in. You can control marketing communications and most service notifications via the “Unsubscribe” link in the bottom of an email or in your account settings.
4) To promote safety and security
We use the personal data we collect from you to promote the safety and security of Smartcat Platform, our users, and other parties. For example, we may use the information to authenticate users, facilitate secure payments, protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce our terms and policies.
5) To fulfill the Terms
We use your personal data to honor the Terms and make the best of your experience with Smartcat Platform.
Whom is your personal data shared with?
1) With affiliates, partners and providers
Based on the consent you are giving us your personal data may be shared with our partners. However, we only share limited personal data. For example, some of personal data may be disclosed to others when you use our Smartcat forums. For the avoidance of doubt we never share your sensitive personal data like payment details and passwords.
We carefully select our partners to help process our payment orders, and enter into agreements with them that detail points concerning the safety of user data. We do not store your bank card details as they are stored on our payment partner’s side, which has all the necessary infrastructure to ensure the safe storage of this type of information, which is confirmed by the availability of a PCI DSS certificate.
We also transfer personal data to our Smartcat affiliates, service providers, and other partners who process it for us, based on our instructions, and in compliance with this policy and any other appropriate confidentiality and security measures. However, we do not share such personal data as password payment details.
Last but not least, we also analyze your user activities and share it with our partners. For instance we may share your IP address info.
Finally, you may also authorize us to share your information with others, for example, with a third-party application when you give it access to your Facebook or Google account. However, we do not share such personal data as passwords and payment information.
2) Upon valid demands of judicial or governmental authorities
We may preserve or disclose information about you to comply with legal process or other government inquiry, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process served on us.
We may also preserve or disclose information about you to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of Smartcat Platform.
How can you control your personal data?
1) By accessing and exporting your personal data
When you log into your account, you can access much of your personal data. You can also download information using your browser in a commonly used file format supported by your browser.
2) By editing and deleting your personal data
Your profile page on Smartcat Platform allows you change and delete your personal information. For instance, you can edit or delete the profile data you provide and delete your account if you wish.
3) By adjusting the use of your personal data
You have the ability to control your personal data. For example, you can limit the amount of your information visible to other users on Smartcat Platform by simply deleting it anytime.
You can also limit the notifications you receive from us.
4) By restricting the use of your personal data
In addition to the various forms of controls that we offer, you can seek to restrict our processing of your personal data in certain circumstances whereby the search engine will not index your profile and your data will not be shared with other users of Smartcat Platform.
Last but not least you can always delete your account at any time.
5) By requesting all of your personal data
Upon request sent by e-mail to us at firstname.lastname@example.org you may wish to request us to compile all personal data that is stored on you at Smartcat Platform and we are committed to respond and give you such data within 30 days of the request received by us.
How long is your personal data kept?
Personal data may be kept for as long as it is required or advisable for legitimate business purposes, to perform contractual obligations or, where longer, as long as is required to comply with applicable legal or regulatory obligations. Where there are technical limitations that prevent deletion or anonymization, we safeguard personal information and limit active use of it.
Upon your termination of the Terms or deletion of your account subject to your specific request your personal data shall be securely destroyed and/or returned to you within a maximum period of 30 days, unless applicable legislation or legal process prevents it from doing so.
How is your personal data protected?
We work hard to keep your personal data safe. We use a combination of technical, administrative, and physical controls to maintain the security of your personal data. This includes but is not limited to the following:
- use of Tier IV data centers in the U.S. and EU, run by AWS and Microsoft Azure, which are SOC-1, SOC-2, and SOC-3 compliant and it should be noted that this is a much higher level of protection than conventional office servers provide;
- all passwords are stored in hashed and salted form (and several external authorized services are supported via OAuth 2.0);
- all passwords in the production configuration files are encrypted and certificates required to decrypt configs are installed on the production machines by administrators and not accessible for engineers with lower levels of access;
- a limited number of our employees have access to personal data and they are all bound by relevant confidentiality covenants under their employment or civil law services agreements;
- a limited number of our employees who have access to personal your data are thoroughly checked by our security team and can only use your personal data as part of their work plus in addition to this, access is limited by authorization procedures and infrastructure, which does not allow employees with insufficient rights to access personal data.
That being said in modern fast-changing world no method of storing, using and transmitting data is completely secure.
For more technical information on this topic you may wish to contact at customer support email@example.com.
Where is your personal data stored?
Your data is primarily stored on our EU server. At the same time depending on the region you are located in (APAC or America), your data will be duplicated on our servers in China or USA accordingly. In certain cases where you are rendering services to Customers located in APAC or America using Smartcat Platform, your data will be also duplicated on our servers in USA or China accordingly to comply with local regulatory requirements.
Where is your personal data sent?
We operate in a number of countries and may transfer your personal data within, from, to the EU, the U.S. and other countries for the purposes described herein.
Please note that the countries where we operate may have privacy and data protection laws and level that differ from, and are potentially less protective than the laws and level of your country.
If we send your personal information to legal entities located in countries without adequate levels of personal data protection, we may execute data processing agreements with attached model contractual clauses or rely on other solutions under GDPR or another applicable laws in relation to the transfer of data to help ensure your data is protected, wherever it may be.
The consent you give us means that you agree to the above when you create your account at Smartcat Platform and accept PPCN by clicking the “Agree” button.
What is Smartcat under the GDPR terminology?
In relation to your personal data when you are registered as an individual translator Smartcat acts as a controller whereby for certain users who are mainly legal entities Smartcat may act as a processor.
What are the Cookies and why do we use them?
Cookies are small blocks of data, which are sent from a website and stored on user’s device by a web server. These blocks of data contain information about your surfing activity on the website. Cookies help to remember stateful information (like items in a shopping cart at online shop) or to track the user's browsing activity.
How long will these privacy rules for your data protection last?
We may change and modify this PPCN from time to time. Upon modification we will notify you about the new or updated PPCN. In case you have any questions vis-à-vis updated PPCN – please contact us at firstname.lastname@example.org.
What if you still have more questions about your personal data?
2. CONSENT SECTIONBack
The consent you are giving hereby relates to the personal data that was entered on your profile page at Smartcat Platform.
The consent you are giving is a free, willful, clear and explicit consent to:
- process personal data for the purpose of providing, supporting and improving Smartcat’s services and features, using appropriate technical, administrative and organizational security measures as well as for the purposes set forth in the Terms;
- be subject to a decision by any user of Smartcat Platform or any Smartcat affiliate based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you;
- cross-border transfers of your personal data to those countries where Smartcat operates or may operate in future with the understanding that whilst the EU countries and a number of other countries have similar and appropriate rules and level of personal data safeguard and protection there may be transfers of your personal data to those countries that lack the appropriate level and legislative regulation of personal data safeguard and protection.
Please note that you have the right to withdraw your consent at any time by writing to us at email@example.com with clear statement that you withdraw your consent and wish your account to be terminated and all personal data to be deleted.
Please note that you are not obligated to provide us with your personal data completely or partially, however in that way we could not provide you with our services depending on provided personal data volume. If you opt out the processing of your personal data, we will respect that subject to our legal obligations.