This is the privacy statement (hereinafter: “Privacy Statement”) of Concorde Group B.V. and its affiliated group companies: Airplane Holding B.V., Concorde Holding B.V., Concorde TEC B.V., Bosch & Bosch Translations and Copy B.V., Burrough B.V., LiveWords B.V., Interlanguage Europe B.V., Balance B.V., Metamorfose Vertalingen B.V. and Walker Language Consultancy B.V. (hereinafter: “Livewords” or “we/us”). In this Privacy Statement we explain how we, in our capacity as ‘controller’, handle the personal data of (representatives and employees of) customers and suppliers, and of other persons with whom we have contact, whether or not via our website https://livewords.com. The word “you” means anyone, wherever located, who falls within the scope of this Privacy Statement. We handle the personal data of data subjects with care and, of course, comply with all legal provisions in this area, in particular the General Data Protection Regulation (the “GDPR”).
1. Scope and application
Livewords collects personal data when you use our mobile applications, websites, other online products and services, including Livewords Go and Livewords Flow (collectively, the “Services”) and via other interactions and communications you have with us. Personal data means any information relating to an identified or identifiable natural person.
To the extent that you use our translation tools, including Livewords Flow, we act as ‘processor’ within the meaning of the GDPR. These services may be subject to additional conditions and additional privacy information, which will then be reported separately as part of the relevant service.
If you are registered with us as an interpreter and/or translator, we will process your personal data which you that you provide to us with the aim of finding suitable assignments for you.
2. Information collection
2.1 Information provided to us by you
We collect information that you provide directly to us, such as when you create or modify your account, request on-demand services, contact the Client Service Desk and/or otherwise communicate with us. This information includes: name, email address, telephone number, postal address, payment method, invoices and any other information provided by you.
If you are an interpreter and / or translator, we will process your personal data required for assignment and execution of assignments. In addition to the above information, these can also be: diplomas, language competences, VAR statement (old) or comparable future self-employment certificate or model contract(s) approved by the Dutch tax authorities, passport copies, and invoices sent to you.
2.2 When you use our Services, we collect information about you in the following general categories:
Information about transactions: We collect transaction data relating to the use of our Services, among which your use of Livewords Go, including the language, the subject or topic of the conversation requested, the date and time of the conversation, the amount charged and the duration of the conversation.
User and preference information: We collect information about how you use our Services, among which Livewords Go, how visitors to the https://livewords.com website contact our services, as well as any preferences indicated and settings selected. In some cases, we do this by using cookies, pixel tags and similar technologies that create and store unique identifiers.
Device information: We may collect information about your (mobile or other) device including, for example, the hardware model, operating system and version, file names and versions, preferred language, unique device identifier, advertising identifiers, serial numbers, device motion information and mobile network information.
Telephone conversation: Livewords enables communication between you and Livewords’ interpreters. In connection with enabling this services, we receive telephone conversation data, including the date and time of the telephone conversation, the telephone numbers of the parties and the substantive nature of the telephone conversations. We log the telephone conversation data of each telephone conversation so that they can be made available to the relevant users at a later time and at the request of the relevant users. We store the telephone conversation data of all conversations in principle for a period not exceeding 30 days, or for as long as the storing of the conversation date is required to process orders or invoice orders, after which period the telephone conversation data are destroyed.
Log information: When you contact one of our applications we can among other things collect server logs, which may include information such as the IP address of the device used, access dates and times, app features or pages viewed, app crashes and other system activities, browser type and third-party websites or services you used before you contacted Livewords.
If your employer uses one of our Services, among which Livewords Go, via a commercial user agreement, we may receive information about you from your employer. Your employer is responsible for informing you about the information it shares with us, if applicable.
When you request interpreting conversations via Livewords Go, or via one of our other applications, you will afterwards be given the opportunity to give a user rating.
2.3 We may use the information we collect about you for the following purposes:
- to maintain and improve our applications, among which Livewords Go, including, for example, enabling payments, sending receipts, providing products and services (and sending related information). This is done to perform an agreement to which you are a party;
- develop new features, provide customer service to users and security features, verify users and send product updates and administrative messages; perform internal work, including, for example, to prevent fraud and abuse. This is done on the basis of our legitimate interests and to perform an agreement to which you are a party;
- to solve software bugs and operational problems; to analyse data, to test and investigate; and to monitor and analyse trends in use and activity. This is done on the basis of Livewords’ legitimate interest;
- to send you messages that we think may be of interest to you, including information about Livewords’ products, services, promotions, news and events, where permitted and in accordance with applicable law. This is done on the basis of Livewords’ legitimate interest or with your consent;
- to personalise and improve the Services, including to provide or recommend features, content, social connections, referrals and advertisements. This is done on the basis of Livewords’ legitimate interest.
If your personal data have been processed on the basis of consent, you can revoke this consent at any time.
Livewords’ legitimate interests comprise marketing, advertising, communication, research and analysis of its own products or services, determining in which products and services individuals are likely to be most interested, IT management and security, business administration, legal affairs, internal management, sharing information with parties affiliated with us.
3. Information sharing
We may share the information we collect about you as described in this Privacy Statement or as described at the time of collection or exchange, including as follows:
Via our Services
- with interpreters, to enable them to provide the Services you require. For example, we may share your name, subject of conversation, estimated duration of conversation and average user rating given;
- with partners selected by Livewords who offer our applications, among which Livewords Go, under their own label to their customers or participants;
- with third parties, to provide you with a service you have requested from us or a third party via a partnership or promotional offer, such in performance of the relevant agreement;
- with the general public, if you submit content to a public forum, such as blog comments, social media posts or other features of our Services that can be seen by the general public, if required with your consent;
- with third parties with whom we may share information about you, for example, other applications or websites that integrate with our API or Services, or third parties with an API or service with which we integrate; and
- with your employer (or similar entity) and necessary third parties engaged by us or your employer (e.g., a cost control service provider) if you use applications of Livewords, among which Livewords Go, under a commercial user agreement.
With parent company Acolad
Since mid-2019, Livewords is part of the Acolad group (“Acolad“) (https://www.acolad.com). Your personal data can be shared with departments of Acolad, i.e. companies in the Acolad group, for example if a certain activity is carried out centrally or jointly within Acolad.
If you are registered with us as an interpreter and/or translator, then your data may also be shared with Acolad because of the legitimate interest of Acolad to have insight into the total available capacity. It is possible that you will be approached by other companies within the Acolad group if you are available for an assignment. If you do not want this, you can object to this. This can be done via the Livewords resources department, or via the Acolad data protection officer (email@example.com).
Amongst other service providers Livewords makes use of IT service providers including Advisor, XTRF, Microsoft and Amazon Web services. They are (sub)processors of the personal data.
Livewords uses external interpreters and/or translators for translation and interpreting assignments.
Acolad uses the Salesforce CRM system. Your data is therefore shared with Salesforce.
Other important exchange
We may share your information:
- with subsidiaries and affiliated entities of Livewords that provide services or perform data processing on our behalf, or for data centralisation and/or logistic purposes;
- with freelance translators engaged by us if we have been commissioned to translate a document containing personal data;
- with vendors, consultants, marketing partners and other service providers who need access to such information to perform work on our behalf as processor;
- in response to a request for information by a competent authority if we believe disclosure is in accordance with, or otherwise required by, applicable law, regulations or legal procedure;
- with law enforcement officials, government bodies or other third parties if we believe your actions are not in accordance with our user agreements, service conditions or service policies, or to protect the rights, the property, or the safety of Livewords or others;
- with third parties, such as supervisory authorities and other bodies, to comply with statutory obligations;
- in connection with or during negotiations about mergers, sales of company assets, consolidations or restructurings, financing or acquisitions of all or part of our company by or in another company, where Livewords will endeavour, if your data are provided to the acquiring company, to inform you of this, for example by means of a message on the website or an advertisement in a national newspaper, such because of our legitimate interests;
- for purposes of sending a newsletter and/or if we inform you in any other way and you consent to the exchange, if required with your consent; and
- in an aggregated and/or anonymous form that cannot reasonably be used to identify you.
Your data are shared with third parties only for the purposes stated in this Privacy Statement, and only to the extent permitted pursuant to applicable laws and regulations and this Privacy Statement.
Third parties to whom we transfer your data are responsible for compliance with the Privacy legislation, unless they act as processors. The provision of the Services may require the transfer of personal data to countries that may or may not be members of the European Union and may not ensure an appropriate level of protection. In such cases, we will take all necessary measures to ensure that the data are transferred in a lawful way.
4. Analysis and advertising services provided by others
5. Account information
You can correct your account information at any time by logging into your (application) account. If you wish to cancel your account, please email us at firstname.lastname@example.org. In some cases, Livewords may retain certain information about you as required by law or for legitimate business purposes to the extent permitted by law. For example, if you have an outstanding credit or outstanding debt in your account or if we believe you have committed fraud or violated our (general) terms and conditions, we may try to resolve the matter before we delete your information.
6. Your rights
Livewords will comply with individual requests regarding the rights ensuing from legislation. You have the following rights with regard to your personal data:
- right of access to your personal data;
- right to rectification or improvement of your data;
- right to be forgotten;
- right to restriction of the processing of your data;
- right to data portability;
- the right to object to direct marketing and processing that takes place because of our legitimate interests.
In order to exercise the above rights, you can submit a request to us. Our contact details can be found at the bottom of this Privacy Statement. Livewords has also appointed a Data Protection Officer who has been registered with the Dutch Data Protection Authority. You can contact this officer via email@example.com. We are also obliged to remind you that, if you see reason to do so, you have the right to submit a complaint to the Dutch Data Protection Authority.
7. Promotional messaging
You can choose not to receive promotional messages from us by following the instructions in those messages. If you choose this option, we may still send you non-promotional messages, such as messages about your account, about Services you have requested, or about our ongoing business relationships.
Cookies and advertising
8. Appropriate technical and organisational measures
Livewords will take appropriate technical and organisational measures to protect your personal data against loss, destruction, damage, modification, disclosure and against any form of unlawful processing. One of the measures taken is that Livewords has drawn up an information security policy in accordance with ISO 27001.
9. Retention period
Livewords stores your personal data for the period that is reasonably necessary for the proper performance of the Services it offers and facilitates. Livewords does not retain personal data any longer than necessary for the purposes for which they were obtained, unless Livewords is legally obliged to retain your personal data for a longer period of time.
10. Changes to this Privacy Statement
We may change this Privacy Statement from time to time. If we make significant changes to the way we treat your personal information, or to the Privacy Statement, we will notify you of such changes via the Services or via other means such as e-mail. Your continued use of the Services after this notification constitutes your consent to these changes. We encourage you to review this Privacy Statement regularly for the latest information on our privacy practices.
This Privacy Statement was last amended on 1 November 2019.
11. Applicable law
This Privacy Statement is governed by Dutch law. Any disputes will be submitted to the competent court in Amsterdam.
How to contact us
If you have any questions about this Privacy Statement, please contact us at firstname.lastname@example.org or write to us:
P.O. Box 140
1180 AC Amstelveen