Privacy Policy – Online Translation Services

Manpower Language Solutions

Updated: June 2020

All capitalized terms not defined in the text shall have the meanings ascribed to them in the Definitions section or in the Terms of Use.

This privacy policy (the “Privacy Policy”) provides a framework for understanding about the personal information that is collected on our platform for translation and other language services operated by Manpower Language Solutions (“MLS”, “we”, “us”, “our”), available at: www.app.manpowerlanguage.com, (together, the “Platform”). This Privacy Policy forms an integral part of our Terms of Use (the “Terms”) available at https://app.manpowerlanguage.com/en/terms-of-use.

This Privacy Policy applies to our Platform through which we deliver our Services (as defined below). The Platform can be accessed directly or through our general company website available at www.manpowerlanguage.com (the “Company Website”). However, please note that the Company Website is subject to it’s own privacy policy which does not cover the Platform and Services. Personal information collected by MLS on the Platform, will be controlled and processed in accordance with the terms of this Privacy Policy.

This Privacy Policy describes the types of personal information we collect, how we use the information, how we process and protect the information we collect, for how long we store it, with whom we share it, to whom we transfer it and the rights that individuals can exercise regarding our use of their personal information. We also describe how you can contact us about our privacy practices and to exercise your rights. In general, our privacy practices conform with applicable laws and regulations, including where applicable Israeli privacy legislation and the provisions of the European Union’s General Data Protection Regulation (GDPR).

You have no legal obligation to provide us your personal information. However, without the provision of personal information, we will not be able to respond to any inquiry sent by you and/or provide you with the respective service you requested (all, as the case may be).

By using the Platform you agree to have your personal information included in our Database (as defined in the Israeli Data Protection Legislation). If you do not agree to the terms of this Privacy Policy, please do not use our Platform.

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Definitions

Applicable Laws” means the Israeli Data Protection Legislation, the GDPR and any data protection, privacy and other laws and regulations applicable to MLS.

User Data Subject” means a Data Subject whose information is included in User Content.

GDPR” means the EU General Data Protection Regulation 679/2016.

Israeli Data Protection Legislation” means the Privacy Protection Law 5741-1981, any regulations promulgated thereto and the guidelines of the Privacy Protection Authority.

Language Services” means any services offered by us, including but not limited to Translation Services, content writing, editing and other services.

The terms “Personal Information”, “Data Subjects” “Controller”, “Processor”, “processing”, shall have the meanings ascribed to them or to similar terms in the Applicable Laws.

The terms “User” and “User Content” shall have the meanings given to them in the Terms.

All capitalized terms which are not defined herein shall have the meanings given to them in the Terms of Use of our Platform.  

 

Information We Collect

We collect Personal Information on our Platform (as permitted under Applicable Laws) through various ways including automated means, as detailed herein. We normally collect information from visitors to our Platform (“Visitor(s)”), business representatives of our associates, partners or clients, (“Business Contact(s)”), and individuals whose Personal Information is included in the User Content uploaded to the Platform or otherwise transmitted and made available to MLS for translation through the Platform (“User Data Subject(s)”).

We may collect the following types of Personal Information about Visitors and Business Contacts:

  • contact information (such as name, email address, telephone number, the services you are interested in, the organization you work for and your position there) “Contact Information”;
  • other information you may provide us in the free text section on the “Contact Us” webpage. Please do not provide us with any information which is not necessary in order for us to contact you.

We may collect the following types of Personal Information about Users:

  • Contact Information
  • Payment Information including bank details, credit card information.
  • Data relating to the use of the Platform and Services.

MLS may collect Personal Information about User Data Subjects, which is included in User Content provided to us. User Content may include any type of Personal Information such as name, identification number, information included in CVs, certificates, diplomas; financial information, health information, information about an individual’s legal status, personal preferences and habits, religious and political beliefs and any information which can identify an individual, directly or indirectly; including information from which inferences can be made about an individual. MLS cannot predict what types of Personal Information its User will upload to the Platform and therefore this information cannot be specified.

How We Use the Information We Collect

The information collected is used for the following purposes (as permitted under Applicable Laws):

  1. initiating and managing our business partner, client and vendor relationships;
  2. sending promotional materials;
  3. communicating about, and administering participation in, special events, promotions, programs, offers, surveys, contests and market research;
  4. responding to individuals' inquiries;
  5. delivering the Services;
  6. operating, evaluating and improving our Platform (including developing, enhancing, analyzing and improving our Platform; managing our communications; performing data analytics;
  7. protecting against, identifying and seeking to prevent fraud and other unlawful activity, claims and other liabilities; and
  8. complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies.

All processing of Personal Information will be carried out based on adequate legal grounds (as required by Applicable Laws) which may fall into a number of categories, including:

  • consent or explicit consent from the Data Subject, where required by Applicable Laws;
  • to ensure that we comply with a statutory or contractual requirement, or a requirement necessary to enter into a contract; or
  • it is essential and necessary for the legitimate interest of MLS, as described in more detail below (e.g. allowing access to a website in order to provide the services offered).

Use of Automated Data Collection Methods

When you visit our Platform, we may collect certain information by automated means, such as cookies, web beacons and web server logs. The information we may collect in this manner includes IP address, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our Platform, dates and times of visits to our Platform and other usage statistics.

For more information please see our cookie policy available at: https://www.manpowerlanguage.com/cookie-policy/.

Our Platform are not designed to respond to "do not track" signals from browsers.

Information collected through third-party plug-ins and widgets on the Platform (such as information relating to your use of a social media sharing tool) is collected directly by the providers of the plug-ins and widgets. This information is subject to the privacy policies of the providers of the plug-ins and widgets, and MLS is not responsible for those providers' information practices.

Legitimate Interest

MLS may process Personal Information for certain legitimate business purposes, which includes some or all of the following:

  • where the process enables us to enhance, modify, personalise or otherwise improve our services/communications for the benefit of our visitors;
  • to identify and prevent fraud;
  • to enhance security of our network and information systems;
  • to better understand how people interact with our Platform;
  • for direct marketing purposes (except were consent is required for such activity in which case we will obtain the Data Subject’s consent prior to sending such communications);
  • to provide postal communications to you which we think will be of interest to you; and
  • to determine the effectiveness of promotional campaigns and advertising.

Whenever we process data for these purposes we will ensure that we take account of your rights. If you are an EU resident, you have the right to object to such processing, and may do so by contacting us as described below. Please bear in mind that if you exercise your right to object, this may affect our ability to carry out and deliver services to you for your benefit.

 

How We Process and Protect Personal Information

We process the Personal Information we collect, also by automated means, for the purposes defined above and for a specific period of time, which complies with our internal retention policy, in order to ensure that the personal data are not kept longer than necessary.

We maintain administrative, technical and physical safeguards designed to protect the Personal Information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

For information regarding the major data security measures taken by the owner of the third party servers (as may be updated from time to time) please visit https://www.smartcat.ai/terms/.

 

How Long We Store Data We Collect

We store in our systems the Personal Information we collect in a way that allows the identification of the Data Subjects for no longer than it is necessary in light of the purposes for which the data was collected, or for which that data is further processed.

  • The necessity to retain the Personal Information collected, in order to offer services established with the user;
  • The legitimate interest of the MLS, as described in the purposes above; and
  • The existence of specific legal obligations that make the processing and related storage necessary for specific period of times.

Information We Share

We do not disclose Personal Information that we collect about you, except as described in this Privacy Policy or in separate notices provided in connection with particular activities. We may share Personal Information with vendors who perform services on our behalf based on our instructions. We do not authorize these vendors to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. We also may share your Personal Information (i) with our subsidiaries and affiliates.

In addition, we may disclose Personal Information about you (i) if we are required to do so by law or legal process; (ii) to law enforcement authorities or other government officials based on a lawful disclosure request; and (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer Personal Information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, reorganization, dissolution or liquidation).

Data Transfers

We also may transfer the Personal Information we collect about you to countries outside of the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the Personal Information. When we transfer your information to other countries, we will protect that data as described in this Privacy Policy and such transfers will be in compliance with applicable law.

The countries to which we may transfer the Personal Information we collect about you may be:

  • Within the European Union
  • Outside the European Union

When we transfer Personal Information from within the European Union to countries or international organizations that are based outside the European Union the transfer takes place on the basis of:

  1. An adequacy decision by the European Commission; or
  2. In the absence of an adequacy decision, other legally permitted grounds: (a) a legally binding and enforceable instrument between public authorities or bodies; (b) binding corporate rules; or (c) standard data protection clauses (formerly called the Model Clauses) promulgated by the European

Your Rights as a Data Subject

In all of the above cases in which we collect, use or store your Personal Information, you may have the following rights and, in most cases, you can exercise them free of charge. At any time, you may contact us at: projects@manpowerlanguage.com and request to know what Personal Information we keep about you. We will make good-faith efforts to locate the data that you request to access.

Where we are the Processor, we will forward your response to the Controller of your Personal Information who shall be responsible to respond to you.

When you ask us to exercise any of your rights under this Policy and the applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of Personal Data related to others and to ask you questions to better understand the nature and scope of data that you request to access.

We may redact from the data which we will make available to you, any Personal Data related to others. In addition, we may delete information if required by Applicable Laws.

Where the GDPR, and when authorized by Applicable Laws, a Data Subject which is an EU resident may exercise certain specific rights, such as:

  1. Right of access: A Data Subject may access his or her Personal Information in order to verify that his or her Personal Information is processed in accordance with the Applicable Law
  2. Right to rectification: A Data Subject may request the rectification of any inaccurate or incomplete data held about him or her, in order to protect the accuracy of such information and to adapt it to the data processing.
  3. Right to erasure: A Data Subject may request that MLS erases information about him or her and to no longer process that data.
  4. Right to restriction of processing: A Data Subject may request that the MLS restricts the processing of his or her data.
  5. Right to data portability: A Data Subject may request data portability, meaning that the Data Subject can receive the originally provided Personal Information in a structured and commonly used format or that the Data Subject can request the transfer of the data to another MLS.
  6. Right to object: A Data Subject who provide a MLS with Personal Information may object, at any time, to the data processing on a number of grounds as set out under GDPR without needing to justify his or her decision.
  7. Right not to be subject of automated individual decision-making: A Data Subject may request not to be subject to a decision based solely on automated processing, including profiling, if such profiling produces a legal effect concerning the Data Subject or similarly significantly affects him or her.
  8. Right to lodge a complaint with a supervisory authority: A Data Subject may have the right to lodge a complaint with an applicable data protection supervisory authority; in particular in the EU Member State of his or her habitual residence, place of work or place of the alleged infringement if the Data Subject considers that the processing of Personal Information relating to him or her infringes GDPR.

Whenever data processing is based on consent as described in Article 7 of the GDPR, the Data Subject may withdraw his or her consent at any time.

If you require more information about the processing of your Personal Information, please refer to the How to Contact Us section below.

Updates to Our Privacy Notice

This Privacy Policy may be updated periodically to reflect changes in our privacy practices and legal updates. For significant changes, we will notify you by posting a prominent notice on our Platform indicating at the top of each notice when it was most recently updated.

Our Policy Towards Children

Our Platform is not meant to be used by or for persons under 18, as such, we do not knowingly collect Personal Information from minors younger than 18. Insofar as Personal Information may be collected based on your consent, the Data Subject must be above the age of 16 (or above the age of 13 if this is the legal requirement in your country). If these age requirements are not met, you are required to obtain the consent of the parent or guardian to provide and process information in accordance with this Policy; lacking such consent, please do not use the Platform.

Applicable Law and Dispute Resolution

This Privacy Policy shall be governed by and construed in accordance with the laws of the State of Israel, without regard to its conflict of law provisions. 

The courts of the Tel Aviv – Jaffa district shall have exclusive jurisdiction in all disputes and proceedings arising from this Privacy Policy.

 

How To Contact Us

If you have any questions or comments about this Privacy Policy, or if you would like to exercise your rights, please contact us at the contact information provided below and we will make good-faith efforts to address your concerns. We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from us, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, we will provide you with the contact information for that regulator.

Contact details:

17 Ha'Mefalsim St.
Petah Tikva 49514
Israel
Tel: +972 3 9244410
Fax: +972 3 9244420

 

DPO@manpowergroup.co.il