Privacy Policy – Europe

Last Updated: January 1st, 2020

1. What does this policy cover?

At Summa Linguae Technologies Canada, Inc. (“Summa Linguae”, “us”, “we”, “our”), your privacy is important to us. We want to be transparent about what personal data we process, why-and-how we process it and what your rights are. This privacy policy (“Privacy Policy”) outlines these points and is designed to help you understand our practices with respect to the processing (including collection, use and disclosure) of your personal data in connection with our Robson mobile application (the “Application”) through which we may administer data collection Tasks (“Tasks”). We have appointed a Privacy Officer who is responsible for our compliance with this Privacy Policy. Information on how to contact the Privacy Officer can be found at the end of this Privacy Policy.

This Privacy Policy applies to “personal data”, which means any information relating to an identified or identifiable natural person. For example, this can include an individual’s name, contact information and payment information. We will only process personal data in accordance with this Privacy Policy, and in accordance with laws applicable to the processing of your personal data by us, including the General Data Protection Regulation (“GDPR”).

On the other hand, “anonymous information” is any type of information other than personal data, and is not the subject of this Privacy Policy. Anonymous information is information which does not or no longer relate to an identified or identifiable natural person. We will collect, use or disclose anonymous information in accordance with our ordinary business practices, but always in accordance with any applicable laws.

2. What personal data do we process?

We collect the personal data you provide to us. When you participate in one of our Tasks or use our Application, we collect and store certain personal data, including:

• the date you signed up for our Task(s),
• your basic contact information including name, email address, phone number and sometimes mailing address,
• your personal information including gender, age, home city, region and country, current city, region and country, emigration year, education level,
• the languages you speak and details relating to your accent,
• text, images, voice recordings, and other media which you may upload in connection with a Task while using our Application, and
• depending on our relationship, your basic financial information to process payment.

We may also collect basic user profile information from all of our visitors. When you visit our site, we may collect device information such as connection type, operating system, browser and IP addresses. Summa Linguae and our other parties may also use cookies.

We may automatically collect certain information which may qualify as personal data, such as your IP address, browser type, referring/exit pages, operating system, as well as which aspects of our performance metric indicators available with our technology or our licensees’ products you prefer using. We will only process these personal data with your consent where this is required by law. Specific examples follow:

a. IP, etc.

When using our Application, we may collect information such as the Internet Protocol (IP) address of your computer or device, the IP address of your Internet Service Provider, the date and time you access our Application, the operating system you are using, and the sections of our Application you visit. This information is used for Application and system administration purposes, and to improve the Application.

b. Tracking Information

We may use web beacons or single-pixel gif tags to compile tracking information reports regarding Application user demographics, traffic patterns, and other aggregated statistics, and may be used in our emails to determine which emails and links have been used by recipients. We may then provide these reports to advertisers and others. For our own research purposes we may link tracking information with personal data provided by Application users.

c. Cookies

We may use cookies on our Application. A cookie is a small text file stored on the customer or device’s hard drive for an extended period of time, to recognize future visits using that computer or device. Cookies enhance the convenience and use of the Application. For example, the information provided through cookies is used to recognize you as a previous user of the Application, to offer personalized content and information for your use, to track your activity at the Application, to respond to your needs, and to otherwise facilitate your Application experience.

3. Personal information of children under 16

Summa Linguae does not process any personal data of children under 16 years of age in relation to the offer of information society services to them on the basis of consent without consent given or authorised by the holder of parental responsibility over the child.

4. For what purposes and on which legal basis do we process your personal data?

Summa Linguae will process your personal data for the following purposes and on the basis of the following legal bases:

• We may use your contact information to communicate with you and/or promote to you any new Task opportunities. The legal basis for this is your consent and/or our legitimate interest to communicate with you and/or promote to you any new Task opportunities.
• If you raise a user support query, we will use your contact information to communicate with you and use any additional information that you provided which relates to the issue. The legal basis for this is our legitimate interest to resolve your user support query.
• We may also use your contact information to ask for your feedback or use your basic user information to analyse our Application or our Tasks. The legal basis for this is your consent and/or our legitimate interest to improve our Application or our Tasks.
• We will use and distribute to our clients text, images, voice recordings, and other media which you have uploaded in connection with a Task while using our Application. The legal basis for this is your consent, the performance of a contract we have entered into with you and/or our legitimate interest.
• We may use your payment information to pay you rewards or compensation for your participation in a Task. The legal basis for this is the performance of a contract we have entered into with you and/or our legitimate business interest to pay or compensate you.

5. How long will we store your personal data?

We hold your personal data for only as long as necessary for the purpose for which we process it.

6. With whom will we share your personal data?

Summa Linguae’s employees may have access to your personal data, but only if necessary for the purposes described above. Summa Linguae may also share your personal data with third parties as permitted by law, such as our clients and service providers, including web hosting providers, virtual infrastructure providers and payment processors.

When we provide your personal data to companies that process your personal data on our behalf to provide services to help us with the Application (“Processors”), we take steps to ensure that these Processors are authorized to use your personal data only as necessary to provide these services to us, and in a manner consistent with this Privacy Policy. .

We may also disclose your personal data if this is required by law, such as to comply with a subpoena, or similar legal process.

7. Where do we process or transfer your personal data?

Due to the nature of our services, we will transfer your personal data to locations outside the European Economic Area (EEA). Specifically, your data will be stored in Canada and the United States of America, and may be processed in one or several of the following countries: United States of America, Canada, India, The Philippines, Argentina, Poland.

It may be the case that we employ third parties who are located or have processing facilities outside the EEA. In any case where we transfer personal data outside the EEA, Summa Linguae shall ensure that such a transfer is subject to appropriate safeguards. In most cases, such transfer will be governed by a contract based on the model contract clauses as made available by the European Commission within the meaning of article 47 of the GDPR. You can obtain a link to or copy of the safeguards we use to transfer your personal data outside the EEA by making a request using the contact details below.

8. What are your rights?

You can exercise a number of rights in relation to your personal data, which are explained below. In each case, please use the contact details below if you would like to exercise any of your rights. Note that in many cases, your rights are not absolute and we may not be required to comply with your request

Right of access
You are entitled to a copy of the personal data we hold about you and to learn details about how we use it. Your personal data will usually be provided to you digitally.

Right to rectification
We take reasonable steps to ensure that the personal data we hold about you is accurate and complete. However, if you do not believe this is the case, you can ask us to update or amend it.

Right to erasure
In certain circumstances, you have the right to ask us to erase your personal data, for example where the personal data we collected is no longer necessary for the original purpose or where you withdraw your consent. However, this will need to be balanced against other factors. For example, we may not be able comply with your request due to certain legal or regulatory obligations.

Right to restriction of processing
In certain circumstances, you are entitled to ask us to (temporarily) stop using your personal data, for example where you think that the personal data we hold about you may be inaccurate or where you think that we no longer need to use your personal data.

Right to data portability
In certain circumstances, you have the right to ask that we transfer personal data that you have provided to us to a third party of your choice.

Right to object
You have the right to object to processing which is based on our legitimate interests. Unless we have a compelling legitimate ground for the processing, we will no longer process the personal data on that basis when you file an objection. Note however, that we may not be able to provide certain services or benefits if we are unable to process the necessary personal data for that purpose.

Rights relating to automated decision-making
You have the right not to be subjected to automated decision-making, including profiling, which produces legal effect for you or has a similar significant effect. If you have been subject to an automated decision and do not agree with the outcome, you can contact us using the details below and ask us to review the decision.

Right to withdraw consent
We may ask for your consent to process your personal data in specific cases. When we do this, you have the right to withdraw your consent at any time.

If you wish to exercise any of these rights, please email: help@robson.ai.

You also have the right to lodge a complaint with a data protection authority. You can find an overview of EU data protection authorities: https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

9. Security and Risk of Harm

The security of your personal data is important to us. We follow generally accepted industry standards to protect the personal data submitted to us, both during transmission and once we receive it. We employ physical, administrative, contractual and technological safeguards to protect personal data, and insist that our service providers do the same. We insist that our personnel, and those of our providers, only access and use personal data in order to properly perform those duties, and even then only to the strict extent necessary to perform them.

We follow generally accepted industry standards to protect personal data submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and so you should always exercise caution when disclosing sensitive information over the Internet.

If you have any questions about security on our Application, please contact our Privacy Officer.

10. Changes to this Privacy Policy

Summa Linguae may edit this Privacy Policy from time to time. If we make any material modifications to this Privacy Policy, we will notify you in advance of the modifications taking effect, by: (a) sending you an email at the email address you have provided us, and/or (b) posting a prominent announcement through our Application and/or website.

11. Contact Information

If you have any questions regarding this policy please contact our Privacy Officer at:

595 Burrard St #16-135
Vancouver, BC
V7X 1L4

You can also email us at help@robson.ai or reach us by telephone at 1.855.438.5106.