Last revised October 19, 2022
To ensure you have an awesome experience using our products, we collect some information about you. We understand that you care about your privacy and the protection of your Personal Data, and so do we. We are committed to the lawful, fair, transparent, accountable, accurate, confidential, and limited collection and processing of your Personal Data.
1. What Personal Data do we collect?
a. The Personal Data you voluntarily provide to us:
We collect Personal Data that you voluntarily provide to us when you register on the Websites or the Platform, express an interest in obtaining information about us or our products and Services, when you use the Services, or when you otherwise contact us. We may collect and process the following Personal Data about you:
- Name and contact information. We may collect your first and last name, email address, company name, your title, CRM provider, company size, phone number, country of residence, and other similar contact information when you contact us, sign up for email lists, promotions, or marketing blogs or newsletters by completing forms on our website www.phrasee.co, complete surveys on our site or as carried out by us or our approved third parties, participate in user forums, participate in research opportunities, register for events, trainings or certifications, and/or interact with us at an event. This may also include information you provide at the time of registering to use our site or signing up for our Services at https://awesome.phrasee.co/. We also use this information to manage our relationship with you.
- Your image and voice. If you attend a Phrasee hosted or sponsored event, we may capture your image and/or voice in any video, photograph or audio recording taken at the event.
- Account information. We may collect information that you upload to, or share through, our Websites or by using our Services, including profile information or any personal information in data that you upload.
- Support. If you contact us for customer or technical support, we may keep a record of that correspondence or conversation.
- Payment Information. We collect Personal Data necessary to process your payment, such as your bank routing number and account number, if you sign up for services with us or register for events or trainings that require payment. We do not accept credit card payments.
- Data related to employment. We may collect Personal Data when you express an interest in employment opportunities at Phrasee by applying through our careers page at https://phrasee.co/about/careers/. The Personal Data we collect from you will be made apparent at the time you are submitting your application. If you are a current, former, or prospective Phrasee employee, please click here to view our Employment Privacy Notice: phrasee.co/legal/employment-privacy.
All Personal Data that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such Personal Data. Please note, if you do not provide us with Personal Data where required, we may not be able to provide you with the products or services you have requested.
b. The Personal Data we collect from other sources:
We may collect Personal Data about you, including first and last name, employer, title, and business contact information, from other sources such as public databases, social media platforms, third-party event hosts and other third parties that you interact with and that Phrasee may engage from time to time, where such Personal Data is publicly available and where we are otherwise have permission to collect such Personal Data.
c. The Personal Data we collect through your use of the Platform and Services:
With respect to use of our Platform and Services, this Personal Data may include the business email address you use to log in to the Services, and other device and usage information, including your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information such as traffic data, location data, weblogs and other communication data and the resources that you access. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
d. The Personal Data we collect to assist you:
If you contact our Phrasee Support or Customer Success teams, your name and contact information will be recorded [on an internally-generated ticket.] We keep this Personal Data for a limited period to track recurring issues and improve our processes and products.
2. How do we use your Personal Data?
We may use your Personal Data for a variety of business purposes as described below. We process your Personal Data for these purposes in reliance on our legitimate business interests, to enter into or perform a contract with you, with your consent, for vital interests, and/or for compliance with our legal obligations. Our purposes for collecting your Personal Data include:
- To provide you with products and services you have requested from us.
- To send you Services-related and administrative information. We may use your Personal Data to send you information related to the Services and/or information about changes to our terms, conditions, and policies.
- To provide you support. We may use your Personal Data to provide you with requested information or technical support, facilitate resolution of any issues, or to diagnose problems with the Services or Platform.
- To fulfill and manage your orders. We may use your Personal Data to fulfill and manage your orders, registrations, and payments made through our Websites.
- To track your trainings and event attendance. We may use your Personal Data to track your trainings and attendance at Phrasee events.
- To administer promotions or contests. We may use your Personal Data to administer promotions or contests that you elect to participate in.
- To request feedback. We may use your Personal Data to request feedback about your use of our Services and Websites.
- To study how our Services are used.
- To protect our Websites and Platform. We may use your Personal Data as part of our efforts to keep our Websites and Platform safe and secure (e.g. through fraud monitoring and prevention).
- To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may be required to inspect the Personal Data we hold to determine how to respond.
- To evaluate your employment candidacy. If you apply for employment with Phrasee, we will use the Personal Data provided in your application to evaluate your candidacy in accordance with our Employment Privacy Notice.
- For other business purposes. We may use your Personal Data for other business purposes, such as the provision of administration and IT services, updating network security, performing data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, informing marketing strategy, and to evaluate and improve our Websites, Services, Platform and your Phrasee experience.
3. What Sensitive Personal Data do we collect?
Unless you are an employee of Phrasee, we do not intentionally collect from you any Sensitive Personal Data. “Sensitive Personal Data” means the various categories of Personal Data that have been identified by applicable data privacy laws as requiring special treatment and can include data relating to ethnic origin or race, marital status, political opinions or affiliations, ideological views or activities, trade union membership, religious or philosophical beliefs, physical or mental health, sexual orientation or sex life, genetic data, biometric data, national identifier (including social security number), government benefits, or administrative or criminal proceedings or records. We suggest that you do not provide us with sensitive Personal Data.
4. What about the Customer Data stored within the Platform?
5. When and with whom do we share your personal information?
We only share and disclose your Personal Data in the following circumstances:
- Service Providers, Vendors, Contractors, and other Third Parties. We may share your Personal Data with third-party vendors, contractors and service providers who perform services for us or on our behalf, and who need to process such Personal Data to do that work. Examples of such services include payment processing, data analysis, email delivery, and hosting services. Third-party data processors that we engage have contractual obligations to us, including obligations to keep Personal Data confidential and process it only for the purposes for which we share it with them. At your request, we will let you know if any third parties have processed your Personal Data as part of an engagement with us.
- Vital interests and legal rights. We may disclose your Personal Data when we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
- Compliance with laws. We may disclose your Personal Data when we are legally required to do so to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Business transfers. We may share or transfer your Personal Data in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Protection of assets. We may use or disclose your Personal Data if we reasonably determine that such use or disclosure is necessary to protect our rights, operations, or users.
- Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
- With your consent. We may disclose your Personal Data for any other purpose with your consent.
6. How do we secure your Personal Data?
The security of your Personal Data is very important to us. We have implemented industry-standard technical and organizational security measures designed to protect the security of any Personal Data we collect and process (both during transmission and once we receive it), as well as to prevent unlawful access and accidental loss or damage. We also routinely verify that our employees are aware of and compliant with their data privacy and security obligations.
Of course, the security of your Personal Data also depends on you; where you have credentials for access to certain parts of our Websites, Platform or Services, you are responsible for keeping such credentials confidential. We cannot guarantee the absolute security of data that is electronically stored or transmitted over the internet, and there is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If we learn of a security breach, we may notify you or others consistent with applicable data protection law. For more information, please visit our information security page at https://phrasee.co/support/legal/infosec.
8. Email tracking
a. Unsubscribing: Emails we send you include tracking whether the user has opened and clicked on the email, and what traffic the email sends our site. If you want to ensure that none of your email activity is tracked, then you should opt out of Phrasee’s emails which you can do on any unsubscribe link contained within that email.
We use this software to see where errors or user confusion happens in the platform, to provide customer support, and to personalise your user experience. For more information regarding this service, please visit: https://www.intercom.com/legal/privacy.
10. Social Media Buttons
On the blog pages of the Websites are social buttons. These enable users to share or bookmark the blog post or pages. There are buttons for: Twitter, LinkedIn, Facebook, and a number of other social media services provided by the ‘sharethis’ service. In order to implement these buttons, and connect them to the relevant social networks and external sites, there are scripts from domains outside of Phrasee. If you click on these buttons, those third-party companies will be registering the information.
11. Customer Testimonials & Quotes
We may publish customer testimonials and quotes on our site or in other marketing materials, which may contain some Personal Data. Prior to publication, Phrasee obtains consent from each customer and the featured individuals. These customers and individuals may withdraw their consent at any time. If you are featured in a customer testimonial or quote and wish to withdraw your consent, please send an email with your request to your Customer Success contact or to email@example.com.
12. Is your Personal Data transferred internationally?
Our headquarters is located in the UK, our servers are located in Ireland, and we have subsidiary companies in the U.S. (Phrasee USA Inc.) and Canada (Phrasee (Canada) Limited). By providing us with your Personal Data or otherwise engaging with us through our Websites, Platform or Services, your Personal Data may be transferred to, stored, and processed by us in these locations, or to our affiliates elsewhere in the world, and by those third parties with whom we may share your Personal Data as described above.
If you would like to obtain details of the safeguards we have put in place, please contact us at firstname.lastname@example.org.
13. How long do we keep your Personal Data?
14. Do we collect Personal Data relating to children?
We do not knowingly solicit data from or market to anyone under 18 years of age. By using the Services, you represent that you are at least 18 years of age. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from anyone under age 18, please contact us at email@example.com.
15. What happens when I click a link to visit another site?
16. What are your rights?
a. Privacy rights: With respect to your Personal Data, you have the right to:
- request that we not process, or stop processing, your Personal Data;
- review the Personal Data that we have about you;
- request a correction of any errors in or update of the Personal Data that we have about you;
- request that your Personal Data will not be used to contact you for direct marketing purposes;
- request that your Personal Data will not be used for profiling purposes;
- request that your Personal Data will not be used to contact you at all;
- request that your Personal Data be transferred or exported to another organisation, or deleted from our records; or
- at any time, withdraw any permission you have given us to process your Personal Data.
b. Withdrawing consent: If we are relying on your consent to process your Personal Data and if required under applicable data protection laws, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before your withdrawal of consent. We will let you know if we are seeking to rely on your consent at the time of collection.
c. Opting out of email marketing: You can unsubscribe from our marketing email lists at any time by clicking on the unsubscribe link or following the unsubscribe instructions in the emails that we send. You will be removed from the marketing email lists; however, we may still need to send you emails that are necessary for non-marketing related purposes.
d. Account Termination: You can at any time review or change the information in your Phrasee account, or terminate your account. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
e. Contacting us: To exercise any of the above rights with respect to your Personal Data or to make a complaint, please contact us at firstname.lastname@example.org. We will not discriminate against you for seeking to exercise any of your privacy rights under any applicable data protection laws and we will consider and act upon any request in accordance with applicable data protection laws. When contacting us, please provide sufficient information that allows us to reasonably verify you as the person from whom we collected Personal Data, and describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to it; we cannot respond to your request if we cannot verify your identity or your authority to make the request. We may ask you to provide additional information to verify your identity.
f. Submit a complaint: If you still have any unresolved issues or wish to submit a complaint after you have contacted us, you may contact your local authority, as applicable. For example, if you live in the European Economic Area, Switzerland, or the United Kingdom, you may contact your local Data Protection Authority for more information (http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html) or if you live in Australia, you may contact the Office of the Australian Information Commissioner (https://www.oaic.gov.au/privacy/privacy-complaints/).
17. Do California residents have specific privacy rights?
a. CCPA: Phrasee does not generally sell Personal Data to third parties for monetary consideration. As described in our Cookie Policies, Phrasee may share information about your devices with third parties in order to understand how you interact with the Websites and deliver relevant ads. Such information sharing may be considered a “sale” under the California Consumer Privacy Act of 2018. If you are a California resident, you can opt out of such sales by any of the following actions:
i. To update your cookie preferences, including a Do Not Sell My Personal Information option, review your Cookies Settings.
ii. Contacting Phrasee via email at email@example.com.
Please note that you must provide enough information to enable us to process your request.
b. “Shine the Light”: California Civil Code Section 1798.83, also known as the ”Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal 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 us using the contact information provided below.
18. Do we make updates to this policy?
Attention: In-House Counsel
82 St John Street
London, United Kingdom, EC1M 4JN