April 14, 2024

Introduction
This Privacy Notice (“Notice”) describes how Fair Translation collect, use, disclose and otherwise process your personal information in connection with the management of our business and our relationships with customers, visitors and event attendees.
This Notice explains your rights and choices related to the personal information we collect when:

• You interact with our website www.fairtranslation.com, as well any other websites that we operate and that link to this Notice (our “Sites”)
• You use our platform, including software, mobile application, and other products and services (the “Solutions”)

This Notice does not cover:

• Applicant information. This Notice does not cover information related to our employment recruiting efforts. Please see our Applicant Privacy Statement for that information.
• Third Parties. This Notice does not apply to any products, services, websites, or content that are offered by third parties and/or have their own privacy statement.

FairTranslation determines the purposes for and means of the processing (i.e., we are the data controller) of your personal information as described in this Notice unless expressly specified otherwise.
Personal Information Collection
We may collect the following types of personal information:

• Business contact information, such as your first and last name, professional title, business affiliation, email, and phone number.
• Services account information, such as the Solutions you use, webinars and other events you sign up for, transactions, and business relationship information.
• Communications with us, including questions or inquiries you may send us, and any information that you create, input, submit, post, upload, transmit, store or display on our Sites.
• Information from cookies and other automated technologies, such as information about the devices you use to engage with our Solutions and Sites, and online activity data. For more details about the technologies we use, the categories of information we collect, and how we use this information, please review our Cookie Notice.

We may also obtain personal information from other sources, including:

• Public sources, such as company websites (e.g. Proz, Job Boards) and pages on social media platforms.

How we Use Personal Information
We use personal information for the following purposes:

• Fair Translation. When you visit our Sites, we use personal information to interact with you, provide you relevant marketing data and information, contact you about our Solutions, personalize or customize your experience (based on preferences or geography, for example), conduct research (such as to test the performance and layout of our Sites), and to improve the content and availability of the Sites. If you interact with any publicly accessible blogs, comments sections, or other interactive features on our Sites, we may display any information that you post and that information might be read, collected, and used by others who access it.
• Administering the Solutions. If you subscribe or are exploring a subscription to our Solutions, we use personal information to create and administer your account, manage our business relationship, and communicate with you about the Solutions, including to send you notifications and keep you informed of any updates to the Solutions. We also analyze trends in the purchase and use of our Solutions to understand our customers’ needs and interests, recommend additional Solutions, forecast business needs, and to improve and develop our Solutions. We may accept payments on our Sites using a payment service provider. The information provided to the payment service provider in connection with payment and transactions is handled in accordance with the payment service provider’s terms and privacy policies.
• Newsletters, events, marketing and advertising. If you sign up to receive newsletters or other additional information from us, attend a webinar or live event, or participate in any other offering, we use the information you provide, such as your name, company name, email address, to facilitate your request and to identify business opportunities. Subject to consent where required, we also use personal information to develop and send direct marketing communications, including by email, and to make sales and promoting our Solutions, events, programs or other services that we believe are of interest to you. You can unsubscribe from our marketing communications as described in the Unsubscribe from marketing communications section below. We also use cookies and similar technologies to engage in interest-based advertising. Please review our Cookie Notice for more information.
• Testimonials. Where you permit us to share your experience with our Solutions, we may post testimonials on the Sites that may contain Personal Information. We obtain your consent to post your name along with your testimonial. If you wish to update or delete your testimonial, you can contact us at privacy@fairtranslation.com.
• Compliance and protection. We also use personal information to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities; protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); audit our internal processes for compliance with legal and contractual requirements and internal policies; enforce the terms and conditions that govern our Solutions; and prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.
• At your option. Other than as set out above, you will receive notice when personal information about you might be shared with third parties, and you will have an opportunity to choose not to share that information.

We will only use your personal information as described in this section if we have a valid legal ground for the processing under applicable laws. Our legal grounds for processing include: consent, where you have consented to the use of your personal information (including, where applicable, to receive marketing communications); legitimate interests, such as to promote, develop and improve our Sites and Services, to protect our legal rights, and to establish, exercise, or defend legal claims, provided that such interests are not overridden by your interests or your fundamental rights and freedoms; and legal obligations, including to comply with tax and accounting obligations. We may also process your personal information when necessary to protect your or another individual’s vital interests.
How We Share Personal Information
We share personal information with:

• Service providers. Companies and individuals that provide services on our behalf or help us operate our Services (such as hosting, information technology, customer support, email delivery, and website analytics services). FairTranslation contractually requires all its third-party business partners with whom it shares personal information to take commercially reasonable steps and implement policies to safeguard your personal information, and to not use your personal information for any purpose other than to assist FairTranslation in serving its customers.
• Advertising vendors. Third party advertising companies, including for the interest-based advertising purposes described above, that can collect information on our Sites through cookies and other automated technologies.
• Social media platforms. Our Sites does not include social media features that collect your IP address, which webpage you are visiting on our Sites.
• Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, in the course of the professional services that they render to us.
• Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

FairTranslation does not sell the personal information we collect as “sale”.

Use of Cookies and Web Technologies
FairTanslation Sites, Solutions, and advertisements may use automatic data collection tools such as cookies, embedded web links, and web beacons. Additional details about how we use these technologies, and how you may limit our use of online tracking technologies is described in our Cookie Notice.

Security
FairTranslation maintains (and requires its service providers to maintain) appropriate organizational and technical measures designed to protect against unauthorized access, alteration, disclosure or destruction of personal information, taking into account the nature of the personal information and the processing, and the threats posed. We are constantly working to improve on these safeguards to help keep your personal information secure, however no security procedures or protocols are ever guaranteed to be 100% secure, and as such we do not guarantee the security of any personal information you provide to us or third parties.
International Transfer of Information Collected
FairTranslation is a Kazakhstan-based company which operates globally. When you interact with our Sites, you provide your personal information to us in the Kazakhstan. We transfer the personal information we receive to our affiliates and third parties as described in the How We Share Personal Information section above. When we transfer your personal information we will protect it in accordance with this Notice wherever it is processed by ensuring that an adequate level of protection is provided for the personal information by using one or more of the following approaches:

• We may transfer personal information to countries that have privacy laws that have been recognized by the country from which the data are transferred as providing similar protections for the data (“Adequacy”), including decisions adopted by (1) the European Commission, based on Article 45 of Regulation (EU) 2016/679 (GDPR); and (2) the UK Secretary of State, based on Article 45 of the UK GDPR and Section 17A of the Data Protection Act 2018.
• We may enter into written agreements, such as the European Commission’s Standard Contractual Clauses and the UK Information Commissioner’s Office’s International Data Transfer Addendum, as applicable, and other data transfer agreements, with recipients that require them to provide the same level of protection for the data.
• We may seek your consent for transfers of your personal information for specific purposes.
• We may rely on other transfer mechanisms approved by authorities in the country from which the personal information is transferred.

As part of our compliance with the Principles, FairTranslation commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the U.S. If you are a European Union or Swiss individual with inquiries about our collection, use, and transfer of your personal information under this Notice, you should first contact FairTranslation: Attention Privacy
Office, privacy@fairtranslation.com. Upon receipt of your communication we will investigate and attempt to resolve any complaints or disputes regarding your personal information within 45 days.

Privacy Choices
Unsubscribe from marketing communications. You can unsubscribe from marketing-related communications by following the instructions at the bottom of the emails you receive from us or by contacting us as provided in the Contact Us section below. If you do so, you will continue to receive service-related and other non-marketing communications until you cease using our Services linked to those service updates.
Privacy rights. Depending on your location, you could be entitled to submit the following requests about your personal information:

• Access. Request that we provide you with information about our processing your personal information and give you access to your personal information.
• Deletion. Request that we delete the personal information that we maintain about you.
• Correction. Request that we update or correct inaccuracies in your personal information.
• Transfer. Request that we transfer a machine-readable copy of your personal information to you or a third party that you designate.
• Restriction. Request that we restrict the processing (including sharing) of your personal information.
• Objection. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

To exercise all other choices described above, please contact us at privacy@fairtranslation.com. To avoid security breaches, we will need to authenticate your identity before we respond to the request and to assess whether these rights apply to you. Additionally, applicable law can limit these rights, for example, by prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. While we endeavor to satisfy the requests we receive, if you are unsatisfied with our response, you may have the right to complain to a privacy or data protection regulator in your country.
Children’s Personal Information
Our Solutions are not intended for use by children. If you have reason to believe that a child has provided personal information to us, please contact us at privacy@faitranslation.com. We will use commercially reasonable efforts to delete such personal information.

Retention
We retain personal information for as long as necessary to fulfill the purposes for which we collect it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we process personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Changes to This Notice
If there are any material changes to this Notice, you will be notified by our posting of a prominent notice on our Sites prior to the change becoming effective or as otherwise required by law. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of our Sites constitutes your agreement to be bound by such changes to this Notice.
Contact Us
If you have questions regarding this Notice or about our privacy practices, please contact us by email at privacy@FairTranslation or at:
You may also send your questions or concerns regarding our privacy practices to our data protection officer by email at privacy@sentinelone.com.
English Version Controls
Non-English translations of this Notice are provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls.