Peter & Clark

PRIVACY POLICY

This is the Privacy Policy has been drafted by:

Peter & Clark – Multilingual Communication S.A.
Peter & Clark – Services S.A.
Peter & Clark – Technologies S.A.

In their capacity of Joint-Controllers pursuant to the terms of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

To contact our Data Protection Officer (DPO), please write to dpo@peterandclark.com

In short:

We will not give your data to third parties without asking your permission.

We will never sell your data to any third parties. We will not harvest or buy personal data in bulk and use it without permission from the data subjects concerned. We will not collect data about your behavior on our websites. For all the details about what we will do with your data, please read on.

Peter & Clark entities will use some of your personal data if you purchase or use our products or services, or when you contact us, request a quote or a contract, or when you access certain services or documents on our websites or portal. We also collect personal data when someone applies for a job by e-mail or via our LinkedIn pages.

If you represent an organization that purchases or uses our products and services, your personal data will be used in connection to this organization.

Peter & Clark entities are the data controllers and, in most cases, the data processing agent for your personal data.

We control, process, and protect your personal data according to the Regulation (EU) 2016/679 (General Data Protection Regulation) of the European Commission, domestic data protection regulations and our audited information security management system.

General policies

What personal data do we collect?

In general, we collect the following types of data from you:

Name
E-mail address
Organization (company)
Country
City
Address
Phone numbers

If you purchase or subscribe to products or services, we also collect your billing details.

Whenever we collect personal data from you, as the data subject, we assume that you provide your own details, not the details of someone else. If, however, you fill in someone else’s data, please make sure you have the explicit, written, and voluntary consent of that person or a written authorization if you are filling in data on behalf of your employer or a manager at work.

For more specific information on the data we collect and how we use this data, please read the sections below that apply to you.

 Why do we need your data?

In general, we need your personal data for the following purposes:

  • Processing your translation needs/use of our iTMS platform;
  • Billing you for paid services you purchase or subscribe to;
  • Filling in surveys about our products or services for the purpose of quality assurance as well as more accurate planning.

Storing and keeping some of your data may be required by law – see the section about how long we retain your data.

Processing your data for certain purposes may be required for us to comply with existing contracts. In such cases, opting out of data processing is not possible without terminating the contract in question.

For more specific information on the data we collect and how we use this data, please read the sections that apply to you.

Data processing

We will not disclose your personal data to any unauthorized third-party recipients without your prior explicit consent.

If you are a citizen of the European Union, we will not transfer your data to external data processing agents that store or process data in countries that are not approved by the European Commission due to the lack of appropriate data protection regulations or infrastructure.

Your data will be processed in the European Union or in the United States, by external data protection agents that either comply with the GDPR or are deemed to provide adequate protection.

For more details about the external data processing agents we use, please see the next section.

Who will process your data and where?

For the purposes of mass e-mailing, surveys and recruitment, and translating your documents, we use the following external data processing agents:

  • LinkedIn: Communications and recruitment service. This provider is based in the United States. Their privacy policy is available at https://www.linkedin.com/legal/privacy-policy. In their privacy policy, you are either a ‘member’ or a ‘visitor’.

The aforementioned data processing agents are exclusively used for the specific purposes outlined above. For all other purposes, we store and process your data on servers we host or have hosted in Luxembourg and Ireland.

As of May 24, 2018, we have a data processing agreement with each of the above data processing agents.

How long do we keep your data?

Under Luxembourg law, we are required to keep your billing details and all documents about your business transactions with Peter & Clark entities for 10 years after your last purchase according to the Data Retention Policy.

These documents include offers, quotes, contracts, invoices, banking documents and customer support communications. After this period, your personal data will be irreversibly destroyed.

Any personal data held by us for marketing and service update notifications will be retained by us until such time that you notify us that you no longer wish to receive this information. If you wish to know more about our data retention policy, please contact us.

What are your rights?

Regarding the personal data we collect and use, you have the right to:

  • require us to inform you about the storage and processing of your data;
  • require us to rectify or erase this data (exceptions may apply if required by law or existing contracts);
  • restrict or object to the data processing;
  • transfer your data without restrictions to another data controller. This is called the right to data portability;
  • withdraw your consent to process your data in general or for specific purposes (opt-out). Our right to process your data before the date on which you withdraw your consent shall still remain lawful.
More specifically:

If you believe that any of your personal data we have is incorrect or incomplete, you may request to see this information, and have it corrected or deleted. Please contact us via our DPO.

If you wish to complain about how we have handled your personal data, please contact our DPO Gabriel BLESER by e-mail at dpo@peterandclark.com. Our DPO will then investigate your complaint and work with you to resolve the matter.

If you still feel that your personal data has not been handled appropriately according to the law, you may contact the Luxembourg Data Protection Authority and file a complaint with them.

Exceptions and restrictions

In conjunction with these rights, the following exceptions and restrictions may apply:

  • The above rights may not apply to non-personal data – if the data concerns an organization and is not suitable to identify individuals.
  • For specific (contractual) purposes, you – as an individual – may have the right to opt out of this data processing. However, the organization you represent may not have this right. In this case, you are kindly asked to provide the data of another (consenting) representative to be the contact person for your organization.

What rights do organizations have?

Privacy rights apply to individuals only. Organizations  (legal entities) do not have these rights.

The rights of organizations originate from the General Terms of Service, as well as the Civil Code of Luxembourg, except where an individual agreement specifies otherwise.

Specific policies by service

Please read these sections in order to learn all the specifics about the data we collect from you and how we use this data. Read all sections that apply to you – please note, there may be more than one section.

Are you an individual user of Peter & Clark – Multilingual Communication and/or Peter & Clark – Services?

As an individual user of our services, you have two agreements with us: a quote/contract and a service agreement (see our General Terms of Service via the link provided).

We collect the following data from you:

Name
E-mail address
Organization (company)
Country
City
Address
Phone numbers

What gives us the right to process this data?

  • Tax regulations: For 10 years after a purchase, we must be able to provide proof of the business transaction to the tax authorities. For this purpose, we must retain the billing details and related documents.
  • Contractual obligations: Our agreement requires that you specify valid contact details, so that we can check your eligibility with regard to the related services and communicate with you concerning the products and services you are using. If you ask us to erase your data or restrict this type of data processing, you may only do so if you terminate your agreements with us.
  • Your consent: We may send you e-mails containing general or targeted offers, invitations to events or surveys concerning quality assurance. By entering into a service agreement with us, you consent to receive such information from us. However, you may withdraw your consent at any time, without giving a reason.

Do you represent an organization that uses our iTMS platform (Peter & Clark – Technologies)?

As a representative of a corporate user of iTMS, your organization has two agreements with us: a contract and a service agreement (see the General Terms of Service).

We collect the following data from you:

Name
E-mail address
Organization (company)
Country
City
Address
Phone numbers

In case of purchase: Billing address of the organization (which, depending on the circumstances, may or may not be personal information)

What gives us the right to process this data?

  • Tax regulations: For 10 years after a purchase, we must be able to provide proof of the business transaction to the tax authorities. For this purpose, we must retain the billing details and related documents.
  • Contractual obligations: Both the contract and the related service agreement require that you specify valid contact details, so that we can check your organization’s eligibility for the related services and communicate with you concerning the products and services you are using. Such communications include information about the licenses and services you are using, expiry reminders, update notifications, etc.
  • If you ask us to erase your personal data or restrict this type of data processing, your organization will be required to appoint another contact person and supply us with their details.
  • Your consent: We may send you e-mails containing general or targeted offers, invitations to events or surveys concerning quality assurance. By entering into a contract or service agreement with us, you consent to receive such information from us. However, you may withdraw your consent at any time, without giving a reason. Your organization may also appoint another contact person who will consent to receive such information.

Are you applying for a job?

You will be asked to provide us with your CV and give your consent to process your data. The personal data in the CV will be processed by us.

You may deny or withdraw your consent to process your CV, but that may make you unable to apply for a position at Peter & Clark.