Privacy Policy – USA
Last Updated: January 1st, 2020
1. What does this policy cover?
The California Online Privacy Protection Act 2003 (CalOPPA) was the first law in the United States to require commercial websites and online services to post a privacy policy, and applies to mobile applications for smartphones and tablets collecting “Personally Identifiable Information,” as defined below and throughout our Terms of Service, which is fully incorporated by reference herein. In 2013, the law was amended to require privacy disclosures regarding tracking of online visits.
As a result, the Company herein: (1) identifies the types of information that the Application’s operator, or the Company, collects about individual users of the Application; (2) identifies the types of third parties to whom the operator might disclose that information; (3) tells consumers how they can request changes to their personally identifiable information; (4) tells consumers how they will be notified of changes to the privacy policy; and (5) gives the policy’s effective date in the top left hand corner of the first page of this Privacy Policy.
This Privacy Policy applies to “Personally Identifiable Information”, which means information about an identifiable individual. For example, this can include an individual’s name, contact information and payment information. Personal information does not include information that would enable an individual to be contacted at a place of business, for example an employee’s name, position or title, business telephone number, or business address. We will only collect, use or disclose Personally Identifiable Information in accordance with this Privacy Policy, or in accordance with laws applicable to the collection, use and disclosure of your Personally Identifiable Information by us.
On the other hand, “non-Personally Identifiable Information” is any type of information other than Personally Identifiable Information, and is not the subject of this Privacy Policy. For example, non-Personally Identifiable Information would include information that enables an individual to be contacted at a place of business, information that is anonymous or not about an identifiable individual, or aggregate information that anonymizes the underlying data (like the number of users and the average time spent on the Application). We will collect, use or disclose non-Personally Identifiable Information in accordance with our ordinary business practices, but always in accordance with any applicable laws.
2. What information do we collect?
We collect the information you provide to us. When you participate in one of our Tasks or use our Application, we collect and store certain information, including:
- the date you signed up for our Task(s),
- your basic contact information including name, email address, phone number and mailing address, and
- the languages you speak and details relating to your accent.
You authorize us to process payment(s), using the payment information you have supplied. Specifically, you will be required to provide your credit card or bank account details to the Company and/or the third-party service provider, and/or register with the third-party service provider to process payment(s). You agree to provide the Company and/or the third-party service provider with accurate and complete information about you and/or your business; and you authorize the Company to share it and any transaction information related to your use of the Application with the third-party service provider for the purpose of processing payment(s), including but not limited to the service fees owed to Company for the use of the Service.
The Company reserves the right, in its sole discretion (but not the obligation), to: (i) place on hold any payment and out of pocket expenses; and/or (ii) refund, provide credits or arrange for the third-party service provider to do so, as necessary.
If you believe a payment has been processed in error, you must provide written notice to the Company within thirty (30) days after the date of payment specifying the nature of the error and the amount in dispute. If notice is not received by the Company within such thirty (30) day period, the payment will be deemed final and valid.
The Company is not liable for any losses relating to chargebacks, fraudulent charges, or other actions by any User that are deceptive, fraudulent or otherwise invalid. By using the Services, you hereby release the Company from any liability arising from fraudulent actions. You will also use best efforts to promptly notify the Company of any fraudulent actions. The Company reserves the right, in its sole discretion, to terminate the account of any User that engages in, or enables any other User to engage in, fraudulent actions.
While the Company takes what it believes to be reasonable efforts to ensure secure transmission of your information to the third-party service provider that assesses and processes payment(s), the Company is not responsible for any fees or charges assessed by third party service providers, or any errors in the processing of payment(s) by third party service providers, including any errors that result from third-party negligence, improper transmission of payment information, your mistaken submission of payment information, or your submission of erroneous payment information. Your sole recourse is with the third-party service provider which processed the payment(s).
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, 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. Some of this may be Personally Identifiable Information, but in typical cases it is non-Personally Identifiable Information. Specific examples follow:
(a) IP Address
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 Application 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. None of the tracking information in these reports can be connected to the identities or other Personally Identifiable Information of individual users. For our own research purposes we may link tracking information with Personally Identifiable Information voluntarily provided by Application users. Once such a link is made, all of the linked information is treated as Personally Identifiable Information and will be used and disclosed only in accordance with this Privacy Policy.
(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. You may choose to decline cookies if your browser permits, but doing so may affect your use of the Application and your ability to access certain features of the Application or engage in transactions through the Application.
(d) Do Not Track
Your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and online service you visit. The Company’s Website and/or Application does not respond to “Do Not Track” signals or other mechanisms from a visitor’s browser. If, in the future, we create a program or protocol to respond to such web browser “Do Not Track” signals, we will inform you of the details of that protocol in an amendment to this Privacy Policy. If you contact us to opt out of being tracked, we will ensure that new data collected about you will not be used by us for targeted advertising purposes. To find out more about “Do Not Track,” please visit https://www.allaboutdnt.com.
3. Personal information of children under 16
Summa Linguae complies with the requirements of the Children’s Online Privacy Protection Act (COPPA), the FTC’s Rule interpreting COPPA (16 CFR § 512), The California Online Privacy Protection Act 2003 (CalOPPA), and the General Data Protection Regulations (GDPR). The Company’s Application is not marketed or directed to children and does not collect any Personally Identifiable Information of children under 16 years of age without consent by the legal guardian.
Anyone aged 16 or under should not submit any Personal Information without the permission of their parents or guardians. Parents or guardians may, on behalf of their children, submit their children’s Personal Information. By using the Application, you are representing that you are at least 16 years old and that you have the relevant legal authority to submit your Personal Information or that of a third-party minor, to the Company or on the Company’s Application. Please see the Company’s Terms of Service for instruction on how minors may request removal of content or information posted on the Application.
4. How do we use your information?
Summa Linguae will process your information for purposes relating to why we acquired your data, for example:
- We may use your contact information 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,
- 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,
- We will use and distribute your User Content as set out in the Terms, which may include Personally Identifiable Information, and
- We may use your payment information to pay you rewards or compensation for your participation in a Task.
Summa Linguae will only use Personally Identifiable Information about you, when we have been given your consent. Your consent can be implied – for example, if you send us an email requesting information, it is implied that we can use your email address and any Personally Identifiable Information you provided in your email in order to respond to your request – or explicit, depending on the circumstances. If any other need arises outside of the purposes for which we collected your Personally Identifiable Information, for example a published study or article, Summa Linguae will not use your Personally Identifiable Information without obtaining your additional consent.
5. How long will we store your information?
Summa Linguae will retain your Personally Identifiable Information for the duration of our relationship. We hold your Personally Identifiable Information for only as long as necessary for the purpose for which we acquired it, unless we have obtained your clear consent to use your Personally Identifiable Information for another similar purpose. Examples of when this might occur are as follows:
- If you apply to participate in one of our Tasks, Summa Linguae will ask for your consent to use your data to contact you for similar, future Tasks.
- If you join the wider Summa Linguae team, we will ask for your consent to store your Personally Identifiable Information to contact you for future Task opportunities relevant to your skills.
- If you apply for a position at Summa Linguae, we will ask for your consent to add your profile to our talent pool for a maximum of 5 years.
At any point in time, given any of these circumstances, you always have the option to access, remove, or modify your Personally Identifiable Information, or have us delete the same upon request.
6. When will we share your information?
Summa Linguae will never give your Personally Identifiable Information to, or share your Personally Identifiable Information with any third party not affiliated with or owned by Summa Linguae, except as permitted by law or as otherwise set out herein:
(a) Third Party Processors
We may provide your Personally Identifiable Information to companies that provide services to help us with the Application such as web hosting providers, virtual infrastructure, recruitment platforms, payment processors, and other service agencies (“Third Party Processors”). These Third Party Processors are authorized to use your Personally Identifiable Information only as necessary to provide these services to us, and in a manner consistent with this Privacy Policy. We take steps to ensure that our Third Party Processors will only use your information in compliance with this Privacy Policy, but they may have their own specific policies regarding the collection, use and disclosure of Personally Identifiable Information. We will use commercially reasonable efforts to identify such Third Party Processors when we are collecting your Personally Identifiable Information, as well as providing links to the relevant privacy policies that may apply.
Google AdWords
The Company may integrate Google AdWords. Google AdWords is a service for Internet advertising that allows the advertiser to place ads in Google search engine results and the Google advertising network. Google AdWords allows an advertiser to pre-define specific keywords with the help of which an ad on Google’s search results only then displayed when the user utilizes the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, the ads are distributed on relevant web pages using an automatic algorithm, taking into account the previously defined keywords.
The operating company of Google AdWords is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
The purpose of Google AdWords is the promotion of our website by the inclusion of relevant advertising on the websites of third parties and in the search engine results of the search engine Google and an insertion of third-party advertising on our website.
If a data subject reaches our website via a Google ad, a conversion cookie is filed on the information technology system of the data subject through Google. The definition of cookies is explained above. A conversion cookie loses its validity after 30 days and is not used to identify the data subject. If the cookie has not expired, the conversion cookie is used to check whether certain sub-pages, e.g, the shopping cart from an online shop system, were called up on our website. Through the conversion cookie, both Google and the controller can understand whether a person who reached an AdWords ad on our website generated sales, that is, executed or canceled a sale of goods.
The data and information collected through the use of the conversion cookie is used by Google to create visit statistics for our website. These visit statistics are used in order to determine the total number of users who have been served through AdWords ads to ascertain the success or failure of each AdWords ad and to optimize our AdWords ads in the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the data subject.
The conversion cookie stores personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, Personal Information, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These Personal Information are stored by Google in the United States of America. Google may pass these Personal Information collected through the technical procedure to third parties.
The data subject may, at any time, prevent the setting of cookies by our website, as stated above, by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a conversion cookie on the information technology system of the data subject. In addition, a cookie set by Google AdWords may be deleted at any time via the Internet browser or other software programs.
The data subject has a possibility of objecting to the interest based advertisement of Google. Therefore, the data subject must access from each of the browsers in use the link www.google.de/settings/ads and set the desired settings.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.
Google Analytics
The Company has integrated the component of Google Analytics. Google Analytics provides for the collection, gathering, and analysis of data about the behavior of visitors to websites and downloaders of mobile applications. An analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Analytics are mainly used for the optimization of a website and/or application, and in order to carry out a cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
The purpose of the Google Analytics component is to analyze the traffic. Google uses the collected data and information, inter alia, to evaluate the use of our App, and to provide online reports, which show the activities, and to provide other services concerning the use of our App for us.
Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our App. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of Personal Information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.
The cookie is used to store Personal Information, such as the access time, the location from which the access was made, and the frequency of visits to our App by the data subject. With each visit to our Internet site, such Personal Information, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These Personal Information are stored by Google in the United States of America. Google may pass these Personal Information collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies at any time by means of a corresponding adjustment, and thus permanently deny the setting of cookies. Such an adjustment would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time.
In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this App, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.
Facebook Analytics
The Company utilizes Facebook Analytics, which allows us to analyze data, trends and charts related to your use of our mobile app, including but not limited to data related to your launching, viewing content, searching or purchasing. You can learn more about how Facebook Analytics by visiting: https://developers.facebook.com/docs/analytics/faq
Facebook is a social network. A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests.
The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
With each call-up to one of the individual pages of this App, which is operated by the controller and into which a Facebook component (Facebook plug-ins) was integrated, the web browser on the information technology system of the data subject is automatically prompted to download display of the corresponding Facebook component from Facebook through the Facebook component. An overview of all the Facebook Plug-ins may be accessed under https://developers.facebook.com/docs/plugins/. During the course of this technical procedure, Facebook is made aware of what specific part of the App was visited by the data subject.
If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our App by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-site of our Internet page was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our App, e.g. the “Like” button, or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data.
Facebook always receives, through the Facebook component, information about a visit to our website by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the call-up to our App. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then he or she may prevent this by logging off from their Facebook account before a call-up to our App is made.
The data protection guideline published by Facebook, which is available at https://facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject. In addition, different configuration options are made available to allow the elimination of data transmission to Facebook, e.g. the Facebook blocker of the provider Webgraph, which may be obtained under http://webgraph.com/resources/facebookblocker/. These applications may be used by the data subject to eliminate a data transmission to Facebook.
Crashlytics
Our apps work with Crashlytics, Inc. (“Crashlytics”) to report any bug affecting our iOS and Android Apps. Crashlytics is a service of Google (see information above re: Google, Inc.). Crashlytics transmits certain technical information to us concerning your device and your app installation if your app crashes. If either app crashes during normal use, the app will send certain information about the incident to Crashlytics. This information consists of the device type, OS version and certain hardware information about your mobile device, and the time of the crash, the state of the application at the time of the crash, and stack traces. We use this data only in order to determine the reason for the crash and to remove errors in our app.
This data is usually not personal data. Using the upper right switch inside the app on the privacy policy page, you can deactivate the analytical data collection.
We use Crashlytics based on our legitimate interest in recognizing errors in our app, examining them and remedying them, and to thus be able to offer our app in its contractually stipulated form. By agreeing with this privacy policy you also agree with the privacy policy of the Crashlytics service. For more information about the data collected by the Crashlytics service, please refer to the Crashlytics privacy policy under the following address: http://try.crashlytics.com/terms/privacy-policy.pdf.
(b) Further Disclosures
We may also disclose your Personally Identifiable Information if: (a) required by law such as to comply with a subpoena, or similar legal process, (b) when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request, or (c) to any other third party with your prior consent to do so.
(c) Links
The Application may contain links to other sites. Summa Linguae is not responsible for the privacy practices or content of these other sites. We have no control over the nature, content and availability of those sites. The inclusion of any link does not necessarily imply a recommendation or endorse the views expressed within them. We encourage you to read the privacy policies of such other sites to learn how they collect and use your Personally Identifiable Information.
We grant you a limited, non-exclusive, revocable, non-assignable, personal, and non-transferable license to create hyperlinks to download the Application, so long as: (a) the links only incorporate text, and do not use any trademarks, (b) the links and the content on your website do not suggest any affiliation with the Company or cause any other confusion, and (c) the links and the content on your website do not portray the Company or its products or Services in a false, misleading, derogatory, or otherwise offensive matter, and do not contain content that is unlawful, offensive, obscene, lewd, lascivious, filthy, violent, threatening, harassing, or abusive, or that violate any right of any third party or are otherwise objectionable to the Company. The Company reserves the right to suspend or prohibit linking to the Application and/or Services for any reason, in its sole discretion, without advance notice or any liability of any kind to you or any third party.
7. What are your rights?
At any point in time, you have the right to modify your information, request a copy of your information, object to your information being used for certain purposes, or delete your information from our system. If you wish to perform any of these actions, please email: help@robson.ai.
8. California Shine the Light Act
Under California Civil Code Section 1798.83, California customers are entitled to request information relating to whether a business has disclosed Personal Information to any third parties for the third parties’ direct marketing purposes. This code applies to businesses with 20 or more full or part-time employees.
We do not disclose your Personal Information to third parties for their direct marketing purposes. If this changes in the future, we will notify you immediately and you may request and obtain from us once a year, free of charge, certain information about the Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of Personal Information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to help@robson.ai.
At any point in time, you have the right to modify your information, request a copy of your information, object to your information being used for certain purposes, or delete your information from our system. If you wish to perform any of these actions, please email: help@robson.ai.
9. Security and Risk of Harm
The security of your Personally Identifiable Information is important to us. We follow generally accepted industry standards to protect the Personally Identifiable Information submitted to us, both during transmission and once we receive it. We employ physical, administrative, contractual and technological safeguards to protect Personally Identifiable Information, and insist that our service providers do the same. We insist that our personnel, and those of our providers, only access and use Personally Identifiable Information 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 Personally Identifiable Information 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 modifications to the terms and conditions of 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. If you do not agree to the modifications, you must cease use of the Application. Once the modifications take effect, if you continue to access the Application you are deemed to have agreed to such modifications.
10. 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 reach us by telephone at 1.855.438.5106.
Annex I
Introduction
Summa Linguae Technologies Canada, Inc. and its United States parent company, Summa Linguae Technologies S.A. dba Summa Linguae Technologies (“Summa Linguae”, “us”, “we”, “our”, “Company”) provides translation and localization services, emerging tech localization services, testing and validation services, and data collection and annotation services, which are described here and fully incorporated herein (collectively, referred to as our “Services”).
The purpose of our Application is to collect and annotate data for machine learning and AI training. Users may have the opportunity to participate in specific data collection Tasks that we offer through our Application (each, a “Task”). Such Tasks may require users to submit, annotate or rate data, including but not limited to voice recordings, images or text while completing specified tasks, and each Task may have additional terms that a user must review and agree to in order to participate in that specific Task.
1. Scope.
This Annex pertains to the use of our Robson mobile application to upload text, images, voice recordings, and other media in connection with a specific data collection task that we offer through that application (“User Content”). User Content may include your Personally Identifiable Information, as that term is defined in our Privacy Policy, which is fully incorporated by reference herein. Separate Terms for our Website are located here: https://robson.ai/privacy-policy.
2. California Consumer Privacy Act; Deletion Right.
California consumers can request that a business like Summa Linguae delete their Personally Identifiable information and/or User Content, to the extent that it contains Personally Identifiable Information, under California’s new privacy law, which is effective January 1, 2020. Under the California Consumer Privacy Act (“CCPA”), businesses such as Summa Linguae will have 45 days to comply with the request. Businesses such as Summa Linguae will also need to disclose to consumers the availability and limitations of the deletion right in their Privacy Policy. Summa Linguae herein references and incorporates fully our discussion regarding your deletion rights in, among others, Sections 2, 6, and 8 of our Privacy Policy.
However, there are exceptions to the deletion right under the CCPA, one of which is an exception to complete the transaction for which the Personal Identifiable Information was collected; an exception to provide a good or service requested by the consumer; or an exception where Personally Identifiable Information was reasonably anticipated within the context of a business’s ongoing business relationship with the consumer; or an exception where Personally Identifiable Information was used to otherwise perform a contract between the business and the consumer.
As discussed above and in Section 1 of our Privacy Policy, you may sell us your Personally Identifiable Information for a fee, pursuant to this Annex 1, Par. 3. You herein agree that Summa Linguae may then distribute your User Content and/or Personally Identifiable Information to other users of our Services.