1. Introduction

Lingua Custodia applies Artificial Intelligence to financial linguistics to develop specialised machine translation engines. We therefore have to deal with a lot of data, mainly linguistic data related to the financial domain.

Lingua Custodia also collects certain personal data including the information collected and/or stored by our subcontractors or clients, the protection of these data follows the GDPR guidelines, this regulation is an integral part of our data protection strategy.

2. Purpose

The purpose of this policy is to describe in a transparent manner how and with what purpose Lingua Custodia collects and processes personal data.

Lingua Custodia is strongly dedicated to respecting the privacy of its customers and focuses a lot of resources and effort on the processing of data in compliance with applicable laws and regulations, and in particular Law No. 78-17 of January 6, 1978 relating to data processing, files and freedoms.

Lingua Custodia is committed to a continuous process of compliance with the General Data Protection Regulation of 27 April 2016 which enters into force on 25 May 2018.

3. Scope

This policy applies to all Lingua Custodia systems and applications  as well as all subcontracting companies that Lingua Custodia may use for the execution of its services.

4. Policy

4.1 Purpose of the Collected Data

Lingua Custodia generally collects personal data (name, first name, email address, phone, name of the company and function) in the following cases:

• For the registration of client users or employees who are authorized to perform or request translations through Lingua Custodia client interface
• In our Client Relationship Management tool, to record and log all our customer activities, contacts, business opportunities and their progress, possibly emails exchanged with customers, meeting notes and reminders
• Via on-line subscription to our Newsletter
• When the translation requests we receive from our clients contain personal data

All personal data collected is neither sold nor rented to third parties for marketing purposes.

4.2 Policy for Sharing Personal Data

The personal data collected are generally intended for Lingua Custodia’s commercial and accounting departments; they may also be transmitted to subcontracting companies that Lingua Custodia may use in the performance of its services. All the companies or subcontractors with whom we work have adhered to the new European regulations.

In this context, personal data may be transferred to a EU or non-EU country. Lingua Custodia implements guarantees ensuring the protection and security of this data, in compliance with the new GDPR regulations.

If Lingua Custodia or all or part of its assets are acquired by a third party, the data in our possession will, where applicable, be transferred to the new owner.

On simple request, we can provide you with a list of the countries where we keep your data and those where they may occasionally transit.

Apart from these assumptions, the disclosure of personal data to third parties may only occur in the case of a request by the legally competent authorities, on judicial requisition, or in the context of a legal dispute.

4.3 Data Retention Period

The personal data we hold will be deleted after different set periods depending on the type of data processed.

• For customer users: the data is deleted automatically after termination of the contractual relationship.
• For others: the personal data of inactive persons (who do not respond to any solicitation despite having accepted to receive our communications) for more than three (3) years or 36 months will be permanently deleted in our databases.

4.4 User Rights

In accordance with the regulations in force, a user has the following rights:

• right of access and rectification of data of a personal nature;
• right to withdraw consent at any time;
• the right to limit the processing of data
• right to object to the processing of personal data;
• the right to the portability of data provided by users, where such data are subject to automated processing based on their consent or a contract

Any user wishing to do so can exercise their rights by sending

• an email to: privacy@linguacustodia.com
• or by mail to: Lingua Custodia, 1 Place Charles De Gaulle 78180 Montigny-le-Bretonneux

4.5 Security

Lingua Custodia has implemented all appropriate technical and organisational measures to guarantee a level of security appropriate to the risks, in particular: to prevent the data from being distorted or damaged or from unauthorised third parties having access to it.

5. Definitions and Terms

• GDPR : The General Data Protection Regulation, which aims to define a global legal framework for the protection of personal data of all European citizens.
• Processing Manager: The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of processing personal data; it is the interlocutor of the supervisory authorities and the persons concerned, on all matters relating to the processing of personal data (Art.58).
• Subcontractor : is a natural or legal person, public authority, agency or other body that processes personal data on behalf of the data controller, so they act only on instruction of the first and does not use the data in question for their own account.
• Consent : it is imperative that the data subject agrees in a clear and unambiguous manner, so that the controller must be able to prove that the consent has been validly given.
• Data Portability : the new regulation requires (Art.20 of the GDPR) that the data subject person can make a request for portability of his/her personal data, so that it is transmitted directly from one controller to another, when this is technically possible.