Privacy statement

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 of users of the Livewords services and systems, for example if you visit our website, work as an interpreter/translator for Livewords or use the services of Livewords. Personal data means any information relating to an identified or identifiable natural person.

Livewords has the following processing activities where personal data of individuals not employed by Livewords are processed. These activities are described in this privacy statement.

  1. Offering website and portals
  2. Performing interpreter- and translation services
  3. Keeping records of (freelance) interpreters/translators
  4. Storing client data and maintaining client relations
  5. Processing personal data in translation documents
  6. Finance and invoicing
  7. Recruitment and selection
  8. Improving our services
  9. Marketing activities
  10. Consulting RBTV

In chapter two, for every activity is described what personal data is collected and on which lawful basis this is based. In chapters three trough nine we explain whom the personal data is shared with, how the data are protected, which privacy rights you have, and how you can contact us regarding the execution of these rights.

Collection of personal data

2.1 Offering the website and portal

Livewords offers a public websites and portals such as the interpreter/translator portal. We collect personal data you provide us, for example when you create or edit your account, request on-demand services, contact our Client Service Desk and or communicate with us in any other way. This personal data consists of name, phone number, email, and other personal data you disclose.

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.

The lawful basis for this processing activity is the legitimate interests pursued by Livewords.

2.2 Offering interpreter- and translation services:

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.

Telephone conversation: Livewords enables communication between you and Livewords’ interpreters. In connection with enabling these 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.

The lawful basis for this processing activity is the legitimate interests pursued by Livewords.

2.3 Keeping records of (freelance) interpreters/translators

To establish and monitor the relation with suppliers and clients, Livewords processes information needed to provide interpreters/translators with the right assignments and to assure our planning and payment are up to date. For this reason we ask interpreters/translators for a set of personal data in the sign up process. The following personal data is concerned:

These personal data may also be used for communication purposes, for sending (non-commercial) newsletters, and information of and invitations for (non-commercial) trainings and events.

The lawful basis for this processing activity is the establishment and performance of a contract between Livewords and the interpreters/translators.

2.4 Storing client data and maintaining client relations

Livewords stores information on contact persons of clients. This includes the names, email addresses and phone numbers provided by the client. It is your employer’s responsibility to inform you on the information they share with us.

The lawful basis for this processing activity is the legitimate interests pursued by Livewords to maintain a client relation.

2.5 Processing personal data in translation documents

Livewords translates documents on behalf of clients. If personal data are included in these documents, they might be are processed for the purpose of performing the translation or for estimating the costs of translation. The following types of data may appear in documents to be translated:

The lawful basis for this processing activity is the legitimate interests pursued by Livewords to fulfil the contract it has with a client that ordered translation services.

2.6 Finance and invoicing

Livewords may use said Personal Data and the bank details of its suppliers and service providers for the processing and payment of the invoices they issue.

With a view to invoicing the services rendered to its clients and the accounting, Livewords may collect and process the following personal data:

The lawful basis for this processing activity is the legitimate interests pursued by Livewords to monitor the payment of services and to comply with its legal accounting obligations.

2.7 Recruitment and selection

When you apply for a job at Livewords, Livewords processes various personal data about you as an applicant. Livewords collects and process personal data in the recruitment process that you have provided to us through personal contact (by telephone, post, e-mail or via an online form) or after we contact you directly. Livewords may also search for information about you on recruitment sites or corporate social networks, but only to the extent such information is necessary to assess your suitability for the position.

The following personal data are processed for this:

Personal data categories

A) Identification data

Examples:

B) Contact data (private and business)

Examples:

C) Professional data

Examples:

 

Only those involved in the hiring process have access to a candidate’s data. These are:

The application procedure ends with an offer or a rejection. In the event of a rejection or if the candidate declines the offer, the candidate’s data will be deleted within one week. Livewords does not store candidate resumes, unless this has been explicitly agreed with the candidate. If we expect to want to invite the candidate at a later date, the data will be kept for a maximum of one year after the candidate’s permission.

The lawful basis for this processing activity is the establishment of a contract between Livewords and the applicant.

2.8 Improving our services

Livewords uses information from the services provided to further improve the service. This concerns the following information:

The lawful basis for this processing activity is the establishment of a contract between Livewords and the applicant.

2.9 Marketing activities

Livewords uses email newsletters and other marketing channels to keep in touch with customers and come into contact with potential customers.

You can choose not to receive commercial messages from us by following the instructions in those messages. If you choose this, we can still send you non-commercial messages, such as messages about your account and services you have requested.

The lawful basis for this processing activity is consent to approach you for marketing activities. You may revoke this consent at any moment.

2.10 Consulting RBTV

The RBTV is a public register of sworn-in interpreters and translators. Livewords regularly consults this registry to check whether there are newly registered interpreters and translators, with the aim of approaching these people and ask to register with Livewords. To determine which registrations are new, Livewords keeps track which interpreters / translators were already known during a previous check.

The lawful basis for this processing activity is the legitimate interests pursued by Livewords to be in contact with sufficient qualified interpreters and translators.

3. Whom your personal data are shared with

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:

With parent company Acolad

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 (dpo@acolad.com).

Livewords also uses services centrally purchased by Acolad, for example for translation automation. For services provided by Acolad to Livewords, processing agreements are signed.

With sub-processors

Livewords uses IT service providers among which Advisor, XTRF, Microsoft and Amazon Web Services. They are (sub-) processors of the personal data.

With translation and toll assets, Livewords uses external interpreters and / or translators.

Acolad uses the Salesforce CRM system for managing contact details of clients. Personal data of contact contacts from clients are processed by Salesforce.

From autumn 2021, Livewords will use Workable as an Applicant Tracking System. Data from applicants will then be processed by Workable.

Third parties to whom we pass on your data are responsible for compliance with privacy legislation, unless they act as a processor. It may be possible that the provision of the services is necessary to forward personal data to countries that are not members of the European Union and do not guarantee appropriate level of protection. In these cases we take all necessary measures to pass the data legally.

4. Use of cookies

We may allow others to provide public measurement and analysis services to us, to place advertisements about us on the internet and to follow the performance of these advertisements and report it. These entities can use cookies, web beacons, SDKs and other technologies to identify your device when you visit our site and uses our services, as well as when you visit other online sites and services. Our website has a cookie statement: (https://livewords.com/en/cookiebeleid-eu/).

If non-functional cookies are used in a portal, this is reported in a separate cookie statement that can be found in said portal at the bottom of the main page.

5. Suitable technical and organisational protection measures

Livewords is responsible for taking appropriate technical and organizational measures to secure your personal data against loss, destruction, damage, change, disclosure and against any form of unlawful processing. Livewords has a certified management system for information security (ISMS) in accordance with ISO 27001. Livewords also holds awareness training of employees, conducts processor agreements with suppliers and tests the security of IT systems regularly.

6. Your privacy rights

Livewords will comply with individual requests regarding the rights ensuing from legislation. You have the following rights with regard to your personal data:

You can correct your account information at any time by logging in to your (application) account. If you want to cancel your account, email us at support@livewords.com. In some cases, Livewords may save 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 open debt on your account or if we think you have committed fraud or violate our (general) conditions, we can try to solve the issue before we remove your information.

To exercise the above rights, you can submit a request from us. Our contact details can be found at the bottom of this privacy statement. Livewords has also appointed a Data Protection officer (Data Protection Officer) whom has been registered with the personal data authority. You can access the DPO via dpo@livewords.com, and approach them with any complaints. You also have the right to submit a complaint to the Supervisory Authority, which in our case is the Autoriteit Persoonsgegevens.

7. 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.

8. 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 July 30, 2021.

9. Contact details

If you have any questions about this Privacy Statement, please contact us at support@livewords.com or write to us:

Livewords
P.O. Box 140
1180 AC Amstelveen

Complaints may be sent directly to our DPO: dpo@livewords.com