Website Privacy Notice
Translate Plus Limited,
with registered address as 1st Floor, 2 Television Centre, 101 Wood
Lane, London, England W12 7FR(“we,” “us,” or “our”) offers translation and
related language services. Our trading name is Publicis Production. This Privacy
Notice sets out how we collect, use, share, and protect any information we
collect through our platform, Flow Plus (“Website”). This Privacy Notice also explains the
measures we take to safeguard your information and describes how you may
contact us regarding our privacy practices.
If you are a linguist,
information concerning our privacy practices with respect to your personal data
can be found in the Linguist Privacy Policy.
If you are a client,
this Platform Privacy Notice applies to you.
Any data collected through this Website, including
personal data (as defined under applicable data protection laws, referred to
collectively as “Personal Data”), will only be used for the purposes set out in
this Privacy Notice. Notwithstanding, we may use information that does not
identify you (including information that has been aggregated or de-identified)
for any purpose except as prohibited by applicable law. When data
is collected on this Website, Translate Plus Limited is acting as a data
controller.
Please read this Privacy
Notice thoroughly. If you disagree with the way personal information will be
used, please do not use this Website.
We may include links to other websites, including social media
platforms. This Privacy Notice only covers this Website and does not apply to
the data practices of other websites. We encourage you to read the privacy
notices available on other websites you visit.
SUMMARY
I. What
Personal Data do we collect and process through the Website? 1
II. Purpose
of data collection and legal basis 2
III. With
whom do we share Personal Data? 3
IV. Your
rights and choices regarding your Personal Data 4
VIII. Use of cookies, other tracking technology, social media and
social media plug-ins 10
IX. Notification
of changes 11
I.
What Personal Data
do we collect and process through the Website?
The following table describes the categories of
Personal Data we collect.
|
Category of Personal Data |
List of Personal Data
processed |
|
Contact Information and Identifiers |
First name, last name, translate plus username, contact ID number,
e-mail address, telephone number (landline and mobile), fax number |
|
Geolocation
data |
Location information
from your device or IP address |
|
Your verbatim communications to us or shared on the public areas of
our site |
Information that you directly send us by
using the brief box functionality on this Website |
|
Professional details |
Company name, job title, department |
Categories of the sources of Personal Data we may
collect:
We
may collect the Personal Data outlined above from the following categories of
sources:
·
Directly from you, for
example, when you send us your questions or comments using the query form or
make usage of your privacy rights.
·
From publicly available
sources, data brokers, partners (e.g., that offer co-branded
services, sell or distribute our products, or engage in joint marketing
activities), advertising networks, internet service providers, data analytics
providers, operating systems and social networks.
·
Indirectly from you by using log files and other means to
automatically collect information about the use of our Website.
II.
Purpose of data collection and legal basis
The following table provides information about our
purposes and legal basis for collecting your Personal Data:
|
Our Purposes
for collecting and using your Personal Data |
Basis for
processing |
|
To read and respond to your queries to us, sent
using our online query form |
Depending on your
request, we will rely on our legitimate interest or the performance of
pre-contractual measures to respond to individuals’ queries |
|
When you contact us through the data access
request form |
We rely on our legal
obligation to provide you a process to exercise your rights |
|
To contact you where you
have indicated you wish to receive news from us |
For visitors from the
European Union, we rely on your consent, where you indicate that you want to
receive marketing material from us |
|
Operating our Website,
for example,
operating, analyzing, improving, and securing our Website |
For visitors
from the European Union, we rely on your consent to obtain your Personal Data
through cookies For visitors from other
geographies, we rely on our legitimate interest to improve our services and
develop new products |
|
Marketing services, for example: ·
Analyzing
and optimizing our (or our service providers’) proprietary databases or
helping us identify and mitigate potential fraud ·
Providing
“verification” or data “hygiene” services, which is how companies update
and/or “clean” their databases by either verifying or removing or correcting
old, incorrect or outdated information |
For visitors
from the European Union, we rely on your consent to use your Personal Data
for marketing services |
|
·
Other internal purposes, such as: internal research,
internal operations, auditing, detecting security incidents, debugging,
short-term and transient use, quality control, and legal compliance |
Our
legitimate interest to support our internal operations and conduct research |
|
·
To provide access to Translate Plus’s services and platform |
Our performance of a contract, or where
applicable, legitimate interests |
|
·
To administer and manage user accounts and provide user support |
Our performance of a contract, or where
applicable, legitimate interests |
|
·
To look into any complaints or questions you may raise |
Our performance of a contract and legitimate
interests to support you and resolve any complaints or questions you may
raise |
|
·
To invoice you for any translation services you request |
Our performance of a contract or our legal
obligation |
|
·
To update you of any changes or improvements in the technology products
|
Our performance of a contract, or where
applicable, legitimate interests |
As indicated below, vendors
and other parties may act as our service providers, or in certain contexts
independently decide how to process your information. We encourage you to
familiarize yourself with and consult their privacy policies and terms of use.
III.
With whom do we share
Personal Data?
We will share your
Personal Data for various business purposes, with other entities of the
Publicis Groupe.
We
also may share any of the Personal Data we collect for the following purposes
Sharing
for Legal Purposes: In addition, we may share Personal Data with other parties in order
to: (a) comply with legal process or a regulatory investigation (e.g.
regulatory authorities’ investigation, subpoena, or court order); (b) enforce
our Terms of Service, this Privacy Notice, or other contracts with you,
including investigation of potential violations thereof; (c) respond to claims
that any content violates the rights of other parties; and/or (d) protect the
rights, property or personal safety of us, our platform, our customers, our
agents and affiliates, its users and/or the public. We likewise may provide
information to other companies and organizations (including law enforcement)
for fraud protection, spam/malware prevention and similar purposes.
Sharing
In Event of a Corporate Transaction: We may also share Personal Data in the event of a
major corporate transaction, including for example a merger, investment,
acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of
some or all of our assets, or for purposes of due diligence connected with any
such transaction.
Aggregate, Deidentified, or Anonymised
Information: We may aggregate, de-identify and/or anonymise any
information collected so that such information can no longer be linked to you
or your device (“Aggregate/De-Identified Information”). We may use
Aggregate/De-Identified Information for any purpose, including without
limitation for research and marketing purposes, and may also share such data
with any other party, including advertisers, promotional partners, and
sponsors, in our discretion, unless otherwise prohibited by applicable law.
IV.
Your rights and
choices regarding your Personal Data
Please use this LINK if you want to make use of any of your below
mentioned legal rights.
The fields marked with an asterisk on the forms are
required for us to process and respond to your request. If you do not provide
this Personal Data, [Name of agency] will not be able to process and respond to
your request.
1.
Where you are resident of the EU
Subject to certain exceptions and the jurisdiction in
which you live, if you are a resident of the EU, the GDPR provides you with
specific rights regarding your Personal Data. This subsection describes your
rights and explains how to exercise those rights regarding Personal Data that
we hold about you. These rights include:
- The right of access:
You can access
all Personal Data we hold about you, know the origin of this Personal Data and
obtain a copy in an understandable format.
You may also use your right
to access your Personal Data to control the exactness of the data and have them
rectified or deleted. You have no justification to provide to exercise your
right to access;
- The right
to rectification:
In order to avoid
that inaccurate or incomplete Personal Data relating to you is process or
shared, you can ask us to rectify them;
- The right
to erasure:
You may request
the erasure or deletion of the Personal Data we hold on you. This is not an
absolute right since we may have to keep your Personal Data for legal or
legitimate reasons. You may, for example, exercise your right to deletion in
the following cases:
o
if
you have withdrawn your consent to the processing (see below);
o
if
you legitimately objected to the processing of your data (see below);
o
when
data is not or is no longer necessary for the purposes for which it was
initially collected or processed;
o
the
data is processed unlawfully (e.g., publishing hacked data);
- The right
to object to the processing of your Personal Data:
When we process
your Personal Data based on our legitimate interest (to determine to which
processing this applies, please refer to Section II of this Privacy Notice),
you may at any time object to the processing of your Personal Data for reasons
relating to your personal situation. We may nevertheless, on a case-by-case
basis, reject such a request by pointing out the legitimate and imperious
reasons justifying the processing of this data which prevail on your interests,
rights and freedoms, or when this data is necessary to establish, exercise or
defend a right before a Court.
- The right
to restrict processing:
The right to limit
the processing completes your other
rights. This right means that the
data processing relating to you and that we are performing is limited, so that
we may keep this data, but we cannot use it or process it in any other manner.
This right applies in specific circumstances, i.e.:
o
if
you challenge the exactness of your Personal Data. The processing is then
limited for a period of time so that the agency may verify the exactness of the
Personal Data;
o
if
the processing is unlawful and you object to the erasure of your Personal Data
and request instead that its use be limited;
o
if
we do not need the Personal Data for the purposes mentioned above in Section I
anymore, but you still need it to establish, exercise or defend rights before a
Court; and
o
in
the cases where you objected to the processing which is based on the legitimate
interests of the agency, you may ask to limit the processing for the time
necessary for us to verify if we can accept your objection request (i.e., the
time necessary to verify whether the legitimate reasons of the agency prevail
over yours).
·
Right to object to data
processing for direct marketing purpose
You may
unsubscribe or object, at any time and without any justification, to the
reception of direct marketing communications. Simply either (i) click on the
link in the footer of the communications you receive from us; or (ii) use the
hyperlink above; or (iii) send us an email at the email
address set out in the “Further Information” section below with the word
unsubscribe in the subject field of the email.
- The right
to data portability:
You may request to
retrieve the Personal Data you provided
us with, in a structured, commonly used, and machine-readable format, for
personal use or to share them with a third party of your choice.
This right only applies to Personal Data you
provided us with, directly or indirectly, and which was processed through
automated means, if this processing is based on your consent or the performance
of a contract. Please check the list of our Personal Data processing activities’
legal grounds (in Section II of this Privacy Notice) to know whether our
processing is based on the performance of a contract or on consent.
- The right
to withdraw your consent to the processing of your Personal Data at any
time:
You may read
Section II of this Privacy Notice in order to identify the purposes for which
the processing of your Personal Data is based on your consent.
If you are unsatisfied
with the way we process your Personal Data or if your request has been rejected,
you may also lodge a formal complaint with your local competent data protection
authority.
Personal Data will
be stored in accordance with our applicable data retention requirements and
corporate policies. The retention period for Personal Data varies depending on
the type of Personal Data and the purposes of processing it.
We will respond without undue delay and in any event within one month
from the date we receive your request. This timeframe can be extended by two
months to take the complexity of the request, or the number of requests
received into account. In this case, we will inform you within one month from
receiving your request, specifying the reasons for extending the response
timeframe.
1.2
Information from our clients
If Personal Data
about you has been processed by us as a processor on behalf of a client and you
wish to exercise any rights you have with such Personal Data, please inquire
with our client directly. If you wish to make your request directly to us,
please provide the name of our client on whose behalf we processed your
Personal Data. We will refer your request to that client and will support them
to the extent required by applicable law in responding to your request.
2.
Where you are a California resident
Your
California Rights and Choices
California residents, under the
California Consumer Privacy Act of 2018 (“CCPA”), have specific rights with
regard to their Personal Data. This section describes how to exercise those
rights and our process for handling those requests. (To the extent
permitted by applicable law, we may charge a reasonable fee to comply with your
request.)
2.1
Information from our clients
We also acknowledge that you may have rights under
the CCPA in connection with the Personal Data we process on behalf of our
clients. If Personal Data about you has been processed by us as a service
provider on behalf of a client and you wish to exercise any of the rights
described below, please provide the name of our client on whose behalf we
processed your Personal Data. We will refer your request to that client and
will support them to the extent required by applicable law in responding to
your request.
2.2
Right to request access to your Personal Data
California residents have the right to request that we disclose what
categories of Personal Data that we collect, use, disclose, or sell about them.
In particular, California residents may request:
·
the specific pieces of Personal
Data that we have collected about you;
·
the categories of Personal Data
we have collected about you;
·
the categories of sources from
which the Personal Data was collected;
·
the categories of Personal Data
about you we disclosed for a business purpose or sold;
·
the categories of third parties
to whom the Personal Data was disclosed for a business purpose or sold; and
·
the business or commercial
purpose for collecting or selling the Personal Data.
2.3
Right to request deletion of your Personal Data
You
may also request that we delete any Personal Data that we collected from you.
However, we may retain Personal Data for certain important purposes, as set out
by law. When we receive and verify your request to delete your Personal Data we
will proceed to delete the data unless an exception applies.
2.4
Right to nondiscrimination.
We
will not deny, charge different prices for, or provide a different level of
quality of goods or services if you choose to exercise these CCPA rights.
2.5
Right to
Opt-out of the sale of your Personal Data.
We do not sell any Personal Data as the term ‘sell’ is used in the CCPA.
2.6
Shine the
Light
Customers who are residents of California may
request (i) a list of the categories of Personal Data disclosed by us to third
parties during the immediately preceding calendar year for those third parties’
own direct marketing purposes; and (ii) a list of the categories of third
parties to whom we disclosed such information. To exercise a request, please
write us at the email or postal address set out in the “Further Information”
section below and specify that you are making a “California Shine the Light Request.”
2.7
How to exercise
your CCPA privacy rights
California residents may exercise their CCPA privacy rights by sending
an email to privacyofficer@publicisgroupe.com.
For security purposes (and as required under California law), we will verify
your identity – in part by requesting certain information from you – when you
request to exercise your California privacy rights. For instance, if you request categories or
specific pieces of Personal Data we have collected about you, you may need to
confirm your possession of an identifier (such as an email address) or to
provide a piece of identification that confirms you are the person you claim to
be.
If we are unable to complete your request fully for
any reason, we will provide you additional information about the reasons why we
could not comply with your request.
You may also designate an agent to make requests to
exercise your rights under CCPA as described above. We will take steps both to
verify the identity of the person seeking to exercise their rights as listed
above, and to verify that your agent has been authorized to make a request on
your behalf through providing us with a signed written authorization or a copy
of a power of attorney.
3.
Where you are a Nevada Resident
Nevada law (NRS 603A.340) requires each business to
establish a designated request address where Nevada consumers may submit
requests directing the business not to sell certain kinds of Personal Data that
the business has collected or will collect about the consumer. A sale under
Nevada law is the exchange of Personal Data for monetary consideration by the
business to a third party for the third party to license or sell the Personal
Data to other third parties. If you are a Nevada consumer and wish to submit a
request relating to our compliance with Nevada law, please contact us as at privacyofficer@publicisgroupe.com.
4.
Your general rights as a US resident regarding
to data collection
Your browser settings may allow you to automatically
transmit a “Do Not Track” signal to online services you visit. Note, however,
there is no industry consensus as to what site and app operators should do with
regard to these signals. Accordingly, unless and until the law is interpreted
to require us to do so, we do not monitor or take action with respect to “Do
Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
You can opt-out
of receiving promotional
emails from us
at any time
by following the
instructions as provided in
emails to click on the unsubscribe link,
or emailing us at the email address set
out in the “Further Information” section below with the word unsubscribe in the
subject field of the email. Please note that you cannot opt-out of
non-promotional emails, such as those about transactions, servicing, or our
ongoing business relations.
The Website is intended for general audiences and is
not directed at children. We do not knowingly collect Personal Data (as defined
by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If
you are a parent or guardian and believe we have collected Personal Data in
violation of COPPA, contacts us at privacyofficer@publicisgroupe.com. We will remove the Personal Data in accordance with COPPA. We do not
knowingly “sell,” as that term is defined under the CCPA, the Personal Data of
minors under 16 years old who are California residents.
We use a variety of
methods, such as firewalls, intrusion detection software and manual security
procedures, designed to secure your data against loss or damage and to help
protect the accuracy and security of information and to prevent unauthorized
access or improper use. Nevertheless, transmission via the internet is not
completely secure and we cannot guarantee the security of information about
you. If you think that the Website or any Personal Data is not secure or that
there has been unauthorized access to the Website or your Personal Data, please
contact privacyofficer@publicisgroupe.comimmediately.
Due to the
international nature of our business, your Personal Data may be transferred
outside the European Union.
Your Personal Data may
be transferred to the US or any country which is not considered to have the
same level of data protection as in the EU. However, we ensure all data
transfers comply with applicable legal requirements by executing standard
contractual clauses. Should you wish to know more about how your Personal Data
is protected or wish to request a copy of the contractual protections please
contact privacyofficer@publicisgroupe.com.
VIII.
Use of cookies,
other tracking technology, social media and social media plug-ins
Cookies are small pieces of text or code sent
to your device when you visit the Website. Cookies are used to optimize the viewing experience, count visitors to a webpage, troubleshoot any problems, keep websites secure, and better serve content. The following
cookies are used on the Website:
·
Functional and required cookies are
always used to allow our hosting platform, to securely serve this Website to
you.
·
Analytics and performance cookies
are used on the Website to view site traffic, activity, and other analytics
data.
Overall, cookies
help us provide you with a better Website, by enabling us to monitor which
pages you find useful and which you do not. You can choose to accept or decline
cookies.
For more information about the cookies
dropped on your device, please review the Cookie Notice.
We have no control over how social media
platforms use your Personal Data and they may independently collect information
about you when you leave our Website. The information collected and stored by those
parties remains subject to their own policies and practices, including what
information they share with us, your rights and choices on their services and
devices, and whether they store information in the U.S. or elsewhere. We encourage you to read the privacy notices
on the various social media platforms you use.
Find out more about how these social media
platforms use your Personal Data:
·
Facebook
·
Twitter
·
YouTube (Google’s
general privacy policy)
·
LinkedIn
Any changes to this Privacy Notice will be promptly communicated on
this page and you should check back to see whether there are any changes.
Continued use of the Website after a change in the Privacy Notice indicates
your acknowledgement and acceptance of the use of Personal Data in accordance
with the amended Privacy Notice.
If you wish to save this text, please mark the entire statement (e.g.
with your mouse) and copy-paste by pushing ctrl-c.
This Privacy Notice has been designed to be accessible to people with
disabilities. If you experience any difficulties accessing the information
here, please contact us at privacyofficer@publicisgroupe.com.
If you consider that we are not complying with this Privacy Notice, if
you have any questions in relation to this Privacy Notice, or have questions
about your rights and choices, please contact privacyofficer@publicisgroupe.com. Data subjects in Europe may also lodge a formal complaint with their
competent data protection authority.
If you have any questions about Translate Plus's data practices or you
wish to exercise your rights or know about the contractual protections in
place, please contact the Publicis Chief Data Privacy Officer on privacyofficer@publicisgroupe.com.
.
For UK data subjects: If
you wish to make a complaint because you consider in relation to your personal
data there is a breach of UK GDPR, please email privacyofficer@publicisresources.com
with the subject line ‘Complaint’.
Updated: 25 May 2026