Last updated August 2023
Personal Data means any information related to a ‘Data Subject’, that can be used to
directly or indirectly identify the Data Subject.
Community (Editors, Evaluators and Annotators): Unbabel uses Personal Data to connect each editor, evaluator and annotator (“Community”) with the tasks they are more likely to achieve a better end result, including to monitor the usability of our platform during the provision of such tasks. Unbabel may use their Personal Data to communicate with its Community if there is an inaccuracy or complaint related to an assigned translated work. Unbabel may also require our Community’s payment details to perform and register payment over work provided on the platform. The following Community Personal Data is collected by Unbabel: – Email address – First name – Last name – Country – Birthdate – Language skills – Clickstream and access times
Clickstream and access times are used by Unbabel to provide general statistics regarding use of the platform and compliance with terms of service. For this purpose, we do link this automatically collected data with other Personal Data, such as First and Last name and Email address.
Prospects: Unbabel uses Personal Data to provide information or demos about our products and services to potential clients (“Prospects”), to communicate with them and answer to their requests as well as to keep them updated about such products and services, by means of periodical emails or messages. For the above purpose, Unbabel collects the following Personal Data from the Prospects (related to individuals):
Clients: In order to provide reporting, e-mail communications and billing to its
clients, Unbabel collects the following Personal Data from its Clients’ accounts
(related to individuals):
Clickstream, URL referral and access times of Clients’ agents are used by Unbabel to provide general statistics regarding use of the platform. This information will not be used to identify any individual, being stored and visualized in an aggregate, de-identified format.
Unbabel proceeds to the pseudonymization, via a software tool called “Eraser”, of any Personal Data that may be included in the original works subject to translation. This pseudonymization occurs prior to any disclosure of data to our Community. Once translated works are received back from the Community, the Personal Data is re-inserted by Unbabel for secure transmission to the Client. Afterwards Personal Data might be permanently deleted from Unbabel systems. Where a translation is used for the retraining of machine learning engines, data is retrained in an anonymized format.
Sources: All Personal Data processed by Unbabel regarding its Community, Prospects or Clients is either contributed/uploaded by them or, regarding Prospects, collected by our search technology while scanning the web or through market research surveys.
Purposes: Unbabel will collect and use Personal Data solely for fulfilling the above specified purposes and for ancillary purposes of the same.Personal Data should not be further processed in a manner that is incompatible with the purposes that governed the processing, and, to the extent necessary for those purposes, it should be accurate, complete, and up-to-date. Unbabel does not sell any Personal Data.
Legal basis for the processing: Unbabel processes the Personal Data of its Community either to perform their contractual relationship (or taking steps before entering into a contract) or to pursue its legitimate interest of ensuring the quality of assigned translated work.Unbabel processes the Personal Data concerning its Prospects either based upon their consent or relying in its legitimate interest to communicate news or updates on its products and services, without prejudice to their right to object at any time to processing of Personal Data for marketing purposes. We promptly honor such opt-out requests.
Finally, Unbabel processes the Personal Data related to its Clients pursuant to their contractual relationship (or taking steps before entering into a Contract) or in order to achieve its legitimate interest of providing a top-notch service, namely, to respond to enquiries, to send administrative information or to provide customer service.
Should you not provide us with all the Personal Data mentioned above, we may not be able to enter into or execute a contract with you.
To support the delivery of our services, Unbabel relies on service providers. Any service provider engaged by Unbabel that might have access or process data that may contain Personal Data is considered a Processor. Despite the Unbabel translation pipeline was designed taking in consideration privacy and security measures, Unbabel still performs a security and privacy review of the practices of any Processors before engaging with them.
Contractual safeguards & due diligence for our Processors: Any processor and subprocessor used by Unbabel are put under a rigorous scrutiny to assess their security, confidentiality and privacy policies, as well as the adoption of adequate safeguards. We require all our Processors to have signed a DPA with us, similar to the DPA that our Clients sign with us, including but not limited to the requirements to:
Unbabel only discloses Personal Data to service providers where the disclosure is absolutely necessary to provide the services that our Clients request. Unbabel will not sell any kind of Personal Data.
Notwithstanding, in restricted and signaled circumstances, we may disclose Personal Data to service providers for marketing purposes. We subject the transfer to prior consent of Data Subjects or, at least, we acknowledge that the Data Subjects have the right to object at any time to processing of Personal Data for marketing purposes.
Legal reasons: Unbabel may disclose Personal Data to comply with lawful requests, subpoenas, search warrants or orders by public authorities, including to meet national security or law enforcement requirements. Unbabel may also disclose Personal Data in order to address a violation of the law or to exercise its legal rights or respond to a legal claim.
Unbabel complies with the principle of data minimization. Therefore, Personal Data shall only be kept while it is adequate, relevant and limited to what is necessary in relation to the purposes of processing.For instance, Personal Data will be stored during the contractual relationship with our Community or with our Clients (“active accounts”) or as long as a valid consent is ensured by our Prospects, notwithstanding the need to preserve data for compliance with legal obligations during the term prescribed by law.
Unbabel allows the Data Subjects to access and rectify their Personal Data and also to object to and restrict the processing of their Personal Data in their user’s profile. If you want to make a request regarding the Personal Data that Unbabel holds from you without accessing our platform, follow the procedure below:
To maintain and improve service continuity and quality, data is deleted upon account termination or by explicit request either on our platform or by email, provided and insofar that such deletion does not prevent Unbabel or the Data Subject to comply with their legal or contractual obligations. If you want us to delete your data without accessing our platform, follow the procedure below:
In compliance with applicable data protection regulations, Unbabel enables Data Subjects to export their data via our platform or by explicit request. If you want to export all the Personal Data that Unbabel holds from you, please follow the procedure below:
In compliance with applicable data protection regulations, the Data Subjects have always the right to withdraw any provided consent upon any time, without affecting the lawfulness of processing based on consent before its withdrawal.
Also, the Data Subjects may lodge a complaint with a relevant Data Protection Authority regarding any processing carried out by Unbabel.
In the section below you can find an overview on how we enforce data security at Unbabel.
By data breach we mean a breach of Unbabel’s security that leads to an accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored or otherwise processed on Unbabel’s systems. We don’t consider a Personal Data breach any unsuccessful attempts or activities that do not compromise data security as unsuccessful log-in attempts, pings, port scans, denial of service attacks or other attacks on our systems.
In the event of a Personal Data breach that is likely to result in a high risk to the rights and freedoms of natural persons, Unbabel commits itself to notify all Data Subjects without undue delay after the incident discovery. Unbabel also commits itself to notify the data protection authority without undue delay and, where feasible, no later than 72 hours after having become aware of it if a breach may result in a risk to the rights and freedoms of natural persons. Finally, Unbabel shall promptly provide the Controller with reasonable cooperation and assistance in respect of a data breach, in accordance with legal and contractual obligations.
Whenever your personal data is transferred outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
The Federal Trade Commission has jurisdiction over Unbabel’’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF).
Unbabel has a Data Protection Officer (DPO), which (i) monitors compliance of data processing with applicable standards, (ii) is a point of contact with the Data Subjects to clarify questions regarding the processing of your data by Unbabel, (iii) cooperates with the data protection authority, (iv) provides advice about Unbabel’s obligations regarding privacy and data protection.
If you have any inquiries or complaints about our handling of your personal data or about our privacy practices generally, please contact us at: firstname.lastname@example.org.
In compliance with the EU-U.S. DPF, Unbabel commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF should first contact Unbabel’s Data Protection Officer.
In compliance with the EU-U.S. DPF, Unbabel commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF.
Per the Recourse, Enforcement and Liability Principle, if a complaint has not been resolved satisfactorily through the above redress mechanisms, data subjects can invoke binding arbitration under certain circumstances. Additional information regarding this avenue can be obtained from https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2
Unbabel shall be liable to the data subject, and the data subject shall be entitled to receive compensation, for any material or non-material damages Unbabel causes the data subject for any breach of the third party beneficiary rights under these Clauses.
Unbabel may not invoke the conduct of a sub-processor to avoid its own liability.
For any enquiries or requests please use the following e-mails according to subject:
Unbabel Inc. is a U.S. based company with registered office at 595 Pacific Ave 4th floor, San Francisco, CA 94133, USA. Should you prefer, you can also contact us via this mail address.