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Privacy Policy

Last updated: 05/12/18

1. Introduction

This privacy notice is issued on behalf of 3SDL Ltd (‘3SDL’), so when we mention 3SDL , "we", "us" or "our" in this privacy notice, we are referring to 3SDL for processing your data. This privacy notice lets you know what happens to any personal data that you give to us, or any that we may collect from or about you. It applies to all products and services, and instances where we collect your personal data, including any information you may provide through our website, when you contact us for any reason such as:

• joining our marketing list

• provide us you details during face-to-face contact (e.g. Business Card)

• applying for a role with us

• registering for an event

• downloading content

• requesting information about our services

• sending 3SDL a request for proposal or

• filling in a survey.

This privacy notice applies to personal information processed by or on behalf of 3SDL. 3SDL is the data controller.  We have a dedicated data protection officer (“DPO”). You can contact the DPO using the details below or by writing to us, marking it for the attention of the DPO or going to the Contact Us link on our website.

3SDL is firmly committed to privacy, the responsible use of information, the need to safeguard the privacy of our clients and visitors to our website, and to maintaining compliance with privacy legislation.

3SDL will ensure that the data you supply to 3SDL is processed lawfully, and with skill and care. We take our responsibilities in respect of your personal data extremely seriously.

It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

We have a data privacy team who are responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights please contact the data privacy team at 3sdl@3sdl.com

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

2. The data we collect about you

Personal data, or personal information, means any information which identifies an individual. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Contact Data - includes email address, phone number, postal address, job role and company or other information included in CVs

Identity Data - includes first name, last name, photo or other information included in CVs

Marketing and Communications Data - includes your Contact Details for us to send marketing communications to you

Technical Data - includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.

Usage Data - includes information about how you use our website

We also collect, use and share "Aggregated Data" such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3. How is your personal data collected

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us. This includes personal data you provide when you:

- subscribe to our service, events or publications

- request marketing to be sent to you

- send us information about a request for proposal

- contact us in relation to a business, media, supplier or career enquiry

- provide one of our employees your business details (e.g. on a business card)

- engage in direct communications with us

- attend meetings, networking events or conferences where you agree to your details being collected and made available

- apply for a role with 3SDL

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

Third parties or publicly available sources. We may receive personal data about you from analytics providers.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• where we need to perform the contract we are about to enter into or have entered into with you

• where it is necessary for our legitimate business interests (or those of a third party) and your interests and fundamental rights do not override those interests

• where we need to comply with a legal or regulatory obligation

• to match your details with job vacancies at 3SDL, and to engage with you in relation to the recruitment process

Section 5 gives more information about the lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to opt out from marketing at any time by clicking the unsubscribe link in any email you receive from us or by contacting us.

5. Why we use your personal data

Below, we have described all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

* Note, checks will not be undertaken until just before the final stage of the recruitment process. Any information obtained by these checks, which brings your suitability for the applied role into question, will be shared with you so that you will have an opportunity to correct or explain the information before any final decision is made on your application. Information obtained from a check will be not be retained by us should your application not proceed and neither will it be passed to any third party without your consent.

6. Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you no longer want to receive marketing communications from us you can click the unsubscribe link in any email you receive from us or contact us.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.

You will receive marketing communications from us if you:

• have requested information from us

• purchased services from us

• provided us with your contact details when we met you at a 3SDL event, conference or meeting

and, in each case, you have not opted out of receiving marketing communications from us.

7. Opting out

You can ask us to stop sending you marketing messages at any time by clicking the unsubscribe link in any email you receive from us or by contacting us.

Where you opt out of receiving these marketing messages, 3SDL may still hold personal data provided to us as a result of a purchase, service experience or other transaction with 3SDL.

8. Change of purpose

We will only use your personal data for the purposes that we collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

9. Correcting and updating your profile

To help us keep our 3SDL information up-to-date we would be grateful if you would let us know as soon as any of your contact details change or if you notice any inaccuracies in your details.

10. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• External Third Parties as set out in the Glossary.

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We will not disclose any personal data you have given to us other than as described in this statement, unless you have authorised us to so do, or if we are required to do so by law. Please note that if at any time 3SDL is required by law to release information about you, 3SDL will do so and will co-operate fully with the relevant authorities.

11. Third-party links

Our website may include links to third-party websites, plug-ins and applications as well as embedded content such as YouTube videos. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Our website is not intended for children and we do not knowingly collect data relating to children through this website.

12. International transfers

3SDL works internationally, but we only share your personal data within 3SDL Ltd.  This could mean transferring elements of your personal data between 3SDL employees in international locations.

If we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model Contracts for the transfer of personal data to third countries.

• Where we use providers based in the US, we may transfer data to them either based on Model Contracts, or if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

13. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

14. Data retention

How long will you use my personal data for?

• We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

• To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

• By law we keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

• In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

15. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights include:

• Request access to your personal data.

• Request correction of your personal data.

• Object to processing of your personal data.

• Request restriction of processing your personal data.

If you wish to exercise any of the rights set out above, please contact us, or check the Information Commissioner’s Office website (www.ico.org.uk) for your rights.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

16. Glossary

Lawful basis

Legitimate Interest means 3SDL's interest in holding and managing your details to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third parties

External Third Parties

Service providers acting as processors based in the European Union and outside the European Union who provide IT and system administration services.

Professional advisers acting as processors including marketing professionals, lawyers, bankers, auditors and insurers based in the European Union or outside the European Union who provide consultancy, banking, legal, insurance and accounting services.