This Privacy Policy explains how VoiceBoxer ApS (“We”, “Us”) processes your personal information.

1) DATA CONTROLLER (or OWNER)

The entity responsible for the processing of your personal information (except as otherwise provided herein, such as in the case of Platform Users, as defined below) is:

VoiceBoxer

Njalsgade 76

2300 Copenhagen S, Denmark

[email protected]

Note:  When a client or sales prospect tries, purchases, uses, or subscribes to VoiceBoxer products and services, such client (or its end-client, as provided in any agreemen(s) between a client and VoiceBoxer) is the Data Controller (or Owner) of such data and VoiceBoxer is the Data Processor in connection with data obtained for the purposes of the delivery and performance of such products and services.  If you use a VoiceBoxer product or service in connection with an event created, requested, or hosted by a VoiceBoxer client, such client shall be the Data Controller (or Owner) of such personal data, and such client can access and process your data, including interaction data, diagnostic data, and the contents of your communications on the VoiceBoxer platform during use of such products and services.  Information may be obtained from clients and users of a VoiceBoxer product or service in connection with an event created, requested, or hosted by a VoiceBoxer client (“Platform Users”).  In connection therewith, VoiceBoxer collects data to provide the product and/or service (including uses compatible with providing the service), provide the best experiences with those products and services, operate our business, and communicate with such client and Platform Users. In the event of a conflict between this privacy statement and the terms of any agreement(s) between a client and VoiceBoxer for use of its products and services, the terms of those agreement(s) will control.

 

2) CATEGORIES OF PERSONAL DATA

We may collect the following categories of personal data about you (each, a “User”):

  • Platform Users: First name, last name, email address, company, live-event specific data (cookies, IP address, OS/browser, chat messages, language of choice, recording)
  • Website users: cookies
  • Prospects, leads/client contacts: First name, last name, email address, job title, company, country, city, phone number, social media handle
  • Vendors: First name, last name, email address, phone number, company, country, CV, language combinations, invoicing data

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using VoiceBoxer.

Unless specified otherwise, all Data requested by VoiceBoxer is mandatory and failure to provide this Data may make it impossible for VoiceBoxer to provide its services. In cases where VoiceBoxer specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools – by VoiceBoxer or by the owners of third-party services used by VoiceBoxer serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through VoiceBoxer and confirm that they have the third party’s consent to provide the Data to the Owner.

 

3) USE OF PERSONAL INFORMATION

Personal Data is collected for the following purposes for all Users (unless otherwise stated) and using the following services and sub-processors, which may not be core to our expertise but critical to our clients and Platform Users having a quality experience:

Analytics

Google Analytics

 

Platform/User database

Compose

Amazon Web Services

 

Managing contacts and sending messages

MailChimp

Mandrill

 

Managing support and contact requests

LiveChat Inc.

Inline Manual

Slack

Skype

 

CRM/ERP/Accounting (for Users other than Platform Users)

WordPress

Zoho CRM

Zoho Creator

E-conomic

RocketReach

 

4) LEGAL BASIS

We may process your personal data described above based on the following legal bases:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof.  In the case of Platform Users, by voluntarily registering and using the VoiceBoxer platform, any such Platform Users consent to process personal data in the performance and delivery of services and products for any client (or its end-client, as provided in any agreemen(s) between a client and VoiceBoxer),
  • Processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

 

5) SHARING OF YOUR PERSONAL INFORMATION

We may share your personal information with:

  • Vendors that We work with to assist our company (meaning interpreters, service providers, technical support, supply services, and financial institutions);
  • Public authorities.
  • In the case of Platform Users, Personal Data may be shared with the Data Controller or Owner for purposes including evidence of attendance, attribution of statements, and other purposes relevant to the provision of VoiceBoxer products or services.

 

6) TRANSFERS TO COUNTRIES OUTSIDE THE EU/EEA

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located. Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own.

The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.

  • Data transfer abroad based on consent

If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.

In such cases, the Owner shall inform Users appropriately and collect their explicit consent.

  • Data transfer abroad based on standard contractual clauses

If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by VoiceBoxer as Data Processor to the Data Controller or Owner according to clauses in the agreement(s) between VoiceBoxer and its client, if located outside the EU.

This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.

  • Other legal basis for Data transfer abroad

If no other legal basis applies, Personal Data shall be transferred from the EU to third countries only if at least one of the following conditions is met:

  • the transfer is necessary for the performance of a contract between the User and the Owner or of pre-contractual measures taken at the User’s request;
  • the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the User between the Owner and another natural or legal person;
  • the transfer is necessary for important reasons of public interest;
  • the transfer is necessary for establishment, exercise or defence of legal claims;
  • the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent. In such cases, the Owner shall inform the User about the legal bases the transfer is based on via VoiceBoxer.

Users can inquire with the Owner to learn which legal basis applies to which specific service.

 

7) RETENTION OF YOUR PERSONAL INFORMATION

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:

  • Personal Data collected from Platform Users for purposes related to the performance of a contract between VoiceBoxer as Data Processor and the client as Data Controller or Owner shall be retained until such contract has been fully performed or as otherwise instructed by the client as Data Controller or Owner in accordance with the terms of such contract;
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

 

8) AUTOMATED DECISIONS

Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User (other than Platform Users), is taken solely by technological means, without any human intervention. VoiceBoxer may use the User’s Personal Data (other than the Personal Data of Platform Users) to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. VoiceBoxer adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.

 

Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.

 

The rationale behind the automated decision making is:

  • to enable or otherwise improve the decision-making process;
  • to grant Users fair and unbiased treatment based on consistent and uniform criteria;
  • to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
  • to reduce the risk of User’s failure to meet their obligation under a contract.

 

9) ADDITIONAL INFORMATION

In addition to the information contained in this privacy policy, VoiceBoxer may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

For operation and maintenance purposes, VoiceBoxer and any third-party services may collect files that record interaction with VoiceBoxer platform use or other Personal Data (such as the IP Address) for this purpose.

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the end of this document.

 

10) SECURITY MEASURES

We take the following measures to protect Personal Data:

  • Access Control: User authorizations are restricted to tasks and only to such individuals with a specific purpose for such authorization.
  • Encryption: The VoiceBoxer platform and use thereof is encrypted end-to-end to protect user data during use.
  • Transmission control: We use TLS to provide privacy and data integrity between our services and the User.
  • Confidentiality: Information and access thereto is password-protected and only available to authorized users.
  • Recoverability: Backups that are regularly checked for successful recovery
  • Evaluation: We review annually (and as needed) the technical and organizational measures to confirm effectiveness and feasibility of data security measures.

 

11) YOUR RIGHTS

In general, you have the following rights:

  • You have the right to request access to and rectification or erasure of your personal data.
  • You also have the right to object to the processing of your personal data and have the processing of your personal data restricted.
  • In particular, you have an unconditional right to object to the processing of your personal data for direct marketing purposes.
  • If processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. Your withdrawal will not affect the lawfulness of the processing carried out before you withdrew your consent.
  • You have the right to receive your personal information in a structured, commonly used and machine-readable format (data portability).
  • You may always lodge a complaint with a data protection supervisory authority, e.g. The Data Protection Agency

 

There may be conditions or limitations on these rights. It is therefore not certain for example you have the right of data portability in the specific case – this depends on the specific circumstances of the processing activity.

 

If you have questions about this Privacy Policy, please email us at [email protected]

 

Last updated: 23/05/2019

 

 

DEFINITIONS

 

“Personal Data (or Data)” means any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

 

“Usage Data means” information collected automatically through VoiceBoxer (or third-party services employed in VoiceBoxer), which can include: the IP addresses or domain names of the computers utilized by the Users who use VoiceBoxer, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

 

“User” means the individual using VoiceBoxer who, unless otherwise specified, coincides with the Data Subject.

 

“Platform User” means any individual using a VoiceBoxer product or service, or attending or participating in an event on the VoiceBoxer platform hosted or created by or for a client (or end-client) of VoiceBoxer and who otherwise may not have engagement or interaction with VoiceBoxer.

 

“Data Subject” means the natural person to whom the Personal Data refers.

 

“Data Processor (or Data Supervisor)” means the natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

 

“Data Controller (or Owner)” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of VoiceBoxer. The Data Controller, unless otherwise specified, is VoiceBoxer.

 

“VoiceBoxer platform” means the products or services offered by VoiceBoxer for access to and provision of remote interpretation services, including but not limited to, the web application and other mobile applications for the access to and provision of such services.

 

“Service” means a service provided by VoiceBoxer as described in the relative terms (if available) and on this site/application.

 

“European Union (or EU)” means all references made within this document to the European Union include all current member states to the European Union and the European Economic Area, unless otherwise specified.

 

“Cookies” means a small piece of data stored in the User’s device.

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