Last Updated: March 2020
iTranslate Medical is designed to limit the collection of personal information during usage. Translations are only available while you are using the application and they remain on the device only and are not stored. We prevent user-generated content from being transmitted to our cloud-based services (except for purposes of improving product performance and functionality) when you collect two basic types of information from users: personal information and non-personal information.
Personal Information may include data that is unique to an individual, like your name, e-mail address and content that individuals create in the application to generate language translations (user-generated content). It can also include information which is not unique to any natural person but which may become associated with the copy of iTranslate Medical that you use. For example, personal information may include: (1) commercial information (for example, the identity of an organization that licenses your copy of iTranslate Medical and authorizes your right to download, access and use the application, and related purchase information and contract terms), or (2) usage data (such as web browser information, server log files, cookie technology, pixel tags or beacons, and other technologies), which we collect to monitor performance and conduct business analytics. Non-Personal Information means information that does not identify you personally and cannot reasonably be associated, reidentified or linked back to you or your household. Examples include usage data that may have started as personal information but which has been stripped of identifiable factors in a way that prevents it from being re-associated, re-identified or linked back to you or others. For more information, see Information Collected by Automated Means.
● Categories of personal information we may collect:
A real name, alias, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers.
B. Personal Records
Name, Email address and username. Some personal information included in this category may overlap with other categories.
C. Commercial information
Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
D. Internet or other similar network activity
Information on a consumers interaction with a website, application, or advertisement. See Information collected by Automated Means below for further details.
E. Geolocation data
Non-precise physical location (inferred from your IP Address).
Some of this information you provide to us and some we collect when you use iTranslate Medical. We also may obtain information about you (including personal information) from our business partners, such as vendors, and others. You may choose not to provide some or all of your personal information to us but doing so may prevent us from providing iTranslate Medical to you or limit our ability to provide you with the level of service that you would otherwise expect from us.
● Information collected from you
The following are examples of the types of information you choose to give us when using iTranslate Medical:
o If you contact our support team, we collect the information you give us during the interaction.
o In the event you purchase products or services directly from us, we, or a third party on our behalf, we may collect payment card and other payment information, solely as required to process payment for such purchase. If you pay for iTranslate Medical directly through our website, you authorize us to have our payment processor collect this information.
Automated Information includes information such as:
● IP address
● Operating system used (for example: iOS)
● Device Information
● Time zone
● Identifiers associated with cookies or other technologies that may uniquely identify your device or browser
● Dates and times of access
● Subscription information
This Automated Information is generally used for the following purposes:
o for the technical provision of iTranslate Medical in order to be able to provide you with a functioning user-friendly experience.
o to provide you with a secure experience and to take measures to protect our website and mobile applications from cyber risks.
o to uncover insights about your use of our website and mobile applications in order to improve iTranslate Medical and its features, including developing new products and features.
o to facilitate your access to our website or mobile application.
o to customize iTranslate Medical for you.
o to help us better understand our current and potential customers so that we may market iTranslate Medical accordingly.
o events and usage data is captured for our internal business analytics in order to understand how our users interact with our mobile applications and use iTranslate Medical. For example, we may capture when a user visits a screen, taps a button, permits notifications, upgrades, or otherwise interacts with the app.
o Monitoring and analyzing the effectiveness of our communications (including by identifying when emails sent to you have been received and read).
● Information collected from integrated services.
We may obtain information, including personal information from third parties and sources that we integrate into iTranslate Medical either for the provision of iTranslate Medical or to facilitate your access to iTranslate Medical such as described below.
In addition to the purposes described above, we may use the information we collect for a variety of purposes, such as the following:
● Performing Our Services
o Maintaining or servicing accounts, providing customer service, operating our website and mobile applications; processing or fulfilling orders and transactions, verifying user information, processing payments.
o Communicating about the products and services we offer, and responding to requests, inquiries, comments, and suggestions.
● Internal Research
o Understanding and evaluating how iTranslate Medical and its features perform with our users.
o Uncovering insights about usage in order to improve iTranslate Medical and provide customers with enhanced features as well as inform our development of new features and products.
o Development of customized or personalized experiences for iTranslate Medical.
● Auditing Interactions with Consumers
o Measuring usage of our websites and mobile applications.
o Measuring our marketing activity (e.g., measuring how a user was acquired).
o To provide you with a secure experience and to take measures to protect our website and mobile applications from cyber risks.
o Protecting against, identifying, investigating, preventing, and responding to fraud, illegal activity (such as incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities, including by enforcing the terms and conditions that govern iTranslate Medical.
o Identification and repair of impairments to intended, existing functionality of iTranslate Medical.
o Understanding our customer in order to more effectively market iTranslate Medical.
● Quality and Safety Maintenance and Verification
o Activities related to improving the quality of iTranslate Medical, including upgrade or enhancement of iTranslate Medical.
o Verification or maintenance of the quality or safety of iTranslate Medical.
o Tracking and responding to quality and safety matters.
o Protecting our rights and property.
● Complying with legal or regulatory requirements, judicial process, industry standards and our company policies, please see our Medical Terms of Service> .
● Other purposes that may be described at the time you choose to provide personal information to us.
To perform the above functions, we may match information collected from you through different means or at different times, including both personal information and Automated Information, and use such information along with information obtained from other sources. We may also aggregate and/or de-identify any information that we collect, such that the information no longer identifies any specific individual. We may use, disclose and otherwise process such information for our own legitimate business purposes including historical and statistical analysis and business planning without restriction.
iTranslate is part of the IAC Group family of businesses. If we have access to it, we share your personal information and non-personal information with other parts of IAC for legitimate business purposes, including:
to assist us in technical processing operations, such as data hosting and maintenance, finance, legal and accounting assistance, securing our data and systems and fighting against spam, abuse, fraud, infringement and other wrongdoings; and
for corporate audit, analysis and consolidated reporting as well as compliance with applicable laws.
We consider all data that we collect to be confidential. We use third party service providers, including corporate affiliates, to assist us in delivering iTranslate Medical to our customers. We share data with these third parties, to the extent necessary for them to provide these services. These companies are acting on our behalf and are required, by contract with us, to keep our data confidential and are only authorized to use it for specific purposes. We always seek your approval before exchanging personal information with third party services that link your accounts with them to your iTranslate Medical account.
Following is more information about the specific categories of third party service providers with which we may share personal information, and reasons for sharing that information:
● Customer Communications and Insights Platforms. We may share email, app usage and interactions with our third-party customer communications platform provider for the following business purposes: performing services that allow us to communicate with you and administer your account as well as track your usage for our internal analytics.
● Internal Business Insights Platforms. Our third-party internal business analytics platform provides us with the tools to help us understand app usage and interactions and uncover insights that allow us to improve our product and features. We may share or make available unique user identifiers, IDFA, device id, IP address and app usage and events (but we do not share translation related information) with these providers for the following business purposes: performing services that allow us to (i) monitor and understand usage in order to enhance existing Services or develop new products and features and (ii) better understand our customers in order to market our products more effectively.
● Measurement and Attribution. These service providers offer tools that allow us to measure and attribute the source of new subscription sign ups and that allow us to uncover insights about usage and app events. We may use unique user identifiers made available to us from these third-party providers to help us measure the effectiveness of our ads (e.g., where and how a user is acquired) and to uncover information about how our customers are using our apps in order to improve their quality and safety.
● Payment processors. If you purchase iTranslate Medical outside of the Apple or Google stores, we will process your payment through our third-party provider. When you pay in this manner, you authorize and direct us to process your payment through our payment processor. An example of this is our payment partner, Stripe (https://stripe.com).
In addition, we may disclose and/or share your information to comply with legal or regulatory requirements (including to comply with a court order, judicial subpoena or other subpoena or warrant), industry standards, judicial process, and our company policies, as well as to protect against, identify, investigate, prevent and respond to fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile applications), adverse event reporting, and claims and other liabilities.
We also reserve the right to disclose your information (i) when we believe in good faith that disclosure is appropriate or necessary to take precautions against liability, (ii) to protect our rights or property or the legal and property rights of others and (iii) investigate and defend third party claims or allegations against us.
Some web browsers may transmit "do-not-track" signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, our sites do not currently process or respond to "do-not-track" (DNT) settings in your web browser. If and when a final standard is established and accepted, we will reassess how to respond to these signals.
Certain third parties, such as ad networks, web analytics companies and social media and networking platforms, collect information about your online activities over time and across websites. These third parties may not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings.
As a resident of the EEA, you may have some or all of the following rights in relation to how we use your personal information:
● Access: you may request access to your personal information and receive copies of it;
● Correction: you may have inaccurate/incomplete personal information corrected and updated;
● Object to, or Limit or Restrict, Use of Data: you can ask us to stop using all or some of your personal information or to limit our use of it;
● Deletion: in certain circumstances, you can request a right "to be forgotten" (this is a right to have your information deleted or our use of your data restricted). We will honor such requests unless we have to retain this information to comply with a legal obligation or unless we have an overriding interest to retain it;
● Portability: in certain circumstances, exercise the right to data portability (this is a right to obtain a transferable version of your personal information to transfer to another provider); and
● Consent Management: where we rely on consent to process your personal data, you may withdraw consent at any time. You do not have to provide a reason for your withdrawal where processing is based on consent.
For your protection, we may require proof of identity and verification before we can answer the above requests.
In this section, we identify the legal grounds on which we rely to process personal information.
In some cases, we have a legitimate interest to process the personal information that we collect, such as to develop, administer and support our products and services; to operate, evaluate and improve our business; to facilitate and manage engagement programs; to promote research; to support our recruitment activities; or to facilitate a Corporate Transaction (including a sale of assets or merger or acquisition).
In other cases, we process personal information to fulfill our contracts with business partners, such as third parties that distribute our products.
It may be also necessary for us to process personal information to establish, exercise or defend against fraud, illegal activity, and claims and other liabilities, including by enforcing the terms and conditions that govern the iTranslate Medical services we provide.
Our processing of certain information may be necessary to comply with our legal obligations, and for reasons of public interest, such as with respect to adverse event and product safety reporting.
We may also process personal information as specifically permitted by applicable legal requirements.
If we rely on consent for the processing of your personal information, we will seek such consent at the time we collect your personal information.
Specifically, we may transfer personal information from the European Economic Area to:
● Countries that the European Commissions has deemed to adequately safeguard personal information,
● Pursuant to the recipients compliance with standard contractual clauses (also known as Model Clauses), EU-US Privacy Shield, or Binding Corporate Rules,
● Pursuant to the consent of the individual to whom the personal information pertains, or
● As otherwise permitted by applicable EEA requirements.
You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:
● The categories of personal information we have collected about you.
● The categories of sources from which we collected your personal information.
● The business or commercial purposes for our collecting or selling your personal information.
● The categories of third parties to whom we have shared your personal information.
● The specific pieces of personal information we have collected about you.
● A list of the categories of personal information disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
● A list of the categories of personal information sold about you in the prior 12 months, or that no sale occurred. If we sold your personal information, we will explain:
● The categories of your personal information we have sold.
● The categories of third parties to which we sold personal information, by categories of personal information sold for each third party.
You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your personal information that we have collected in the period that is 12 months prior to the request date and are maintaining.
Data Deletion Rights
Except to the extent we have a basis for retention under CCPA, you may request that we delete your personal information that we have collected directly from you and are maintaining. Note also that we are not required to delete your personal information that we did not collect directly from you.
Exercising Your Rights
To make a request for access, portability or deletion according to your rights under CCPA, click here or mail your request for the attention of the Privacy / Legal Department to iTranslate GmbH, 330 West 34th St., 5th Floor, New York, NY 10001. California Consumers may exercise these rights via an authorized agent who meets the agency requirements of the CCPA. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Any request you submit to us is subject to an identification and residency verification process (Verifiable Consumer Request). The Verifiable Consumer Request must:
● Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
● Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Some personal information we maintain about Consumers is not sufficiently associated with enough personal information about the Consumer for us to be able to verify that it is a particular Consumers personal information (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA, we do not include that personal information in response to Verifiable Consumer Requests. If we cannot comply with a request, we will explain the reasons in our response.
We will make commercially reasonable efforts to identify Consumer personal information that we collect, process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.
We do not sell personal information that we collect from you, in accordance with the definition of sell in the CCPA, and will treat personal information we collect from you as subject to a do not sell request. There is not yet a consensus as to whether third party cookies and tracking devices associated with our websites and mobile apps may constitute a sale of your personal information as defined by the CCPA.
We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable data. In addition, we may offer you financial incentives for the collection, sale and retention and use of your personal information as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive will be explained and described in its program terms. We may add or change incentive programs and/or their terms by posting notice on the program descriptions and terms linked to above so check them regularly.
California's "Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses' practices related to disclosing personal information to third parties for the third parties' direct marketing purposes. Alternatively, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties' direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. As discussed above, if we share Personal Information with third parties for their marketing purposes you will be able to elect for us not to do so by submitting your request here (please include your name, mailing address, and email address).
Mobile platforms have permission systems for specific types of device data and notifications, such as camera and microphone as well as push notifications. Where applicable, you can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.
You can stop all information collection by the app by deactivating your account (where applicable) by following the instructions on iTranslate Medicals Settings screen or uninstalling the app using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you reinstall the application on the same mobile device, we may be able to re-associate this identifier to your previous account.
If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving commercial email from us, and any other promotional communications that we may send to you from time to time, by sending your request to us by the applicable mobile application support email. Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may receive promotional communications from us that you have opted-out from during that period. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive transactional or administrative messages from us regarding iTranslate Medical.
If you choose to opt-in, some of our apps may collect your devices precise real-time location, and in such cases, you may be able to opt out from further allowing us to have access to such location data by managing your location preferences in the app and/or on your device.
Under Nevada law, Nevada residents may opt out of the sale of certain covered information (as defined under Nevada law) collected by operators of websites or online services. We currently do not sell covered information, as sale is defined by Nevada law, and we do not have plans to sell this information. However, if you would like to be notified if we decide in the future to sell personal information covered by the Act, please contact us. You are responsible for updating any change in your email address by the same method and we are not obligated to cross-reference other emails you may have otherwise provided us for other purposes. We will maintain this information and contact you if our practices change.
User-generated content is not transmitted from your device to iTranslate Medicals cloud-based services. If you are a consumer that has used iTranslate Medical on a device controlled by another person, your personal information is governed by that persons data retention policies. Except as provided below, we may retain your personal information for the longer of three (3) years after we become aware that you have ceased using iTranslate Medical or for so long as necessary to fulfill any contractual obligation governing the information or our legal and regulatory obligations. However, we may not know if you have stopped using iTranslate Medical so we encourage you to contact us if you are no longer using iTranslate Medical. We may retain other information that is not personally identifiable for backups, archiving, prevention of fraud and abuse, analytics, or where we otherwise reasonably believe that we have a legitimate reason to do so.
We use various efforts intended to safeguard the security and integrity of personal information collected through iTranslate Medical. Despite these measures, however, we cannot and do not guarantee that information will be absolutely safe from interception or intrusion during transmission or while stored on our system, or otherwise, and you collect personal information with iTranslate Medical at your own risk.
If you correspond with us by e-mail or using Web forms available through iTranslate Medical, you should be aware that your transmission might not be secure from access by unauthorized parties. We have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission. If you create an account as part of using iTranslate Medical, you are responsible for maintaining the confidentiality of your account password and for any activity that occurs under your account. Please notify us of any unauthorized use of your password or account.
If we believe that the security of any personal information in our care may have been compromised, we may seek to notify you. If we have your email address, we may notify you by e-mail to the most recent e-mail address you have provided us in your account profile. Please keep your email address in your account up to date. You can change that e-mail address anytime in your account profile. If you receive a notice from us, you can print it to retain a copy of it. To receive these notices, you must check your email account using your computer or mobile device and email application software. We may also post a conspicuous notice on our site or notify you through the mobile application. You consent to our use of email, text message and/or notification through the app as a means of such notification. If you prefer for us to use the postal service to notify you in this situation, please let us know by submitting your request here. You can make this election any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request. You may also use this email address to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your personal information.
For your convenience and information, we may provide links to websites and other third-party content that is not owned or operated by us. The websites and third-party content to which we link may have separate privacy notices or policies. We are not responsible for the privacy practices of any entity that it does not own or control. We encourage you to review the privacy policies of such third parties before providing them with any personal information.
We do not knowingly market to or collect information from children under the age of 18 years old (or older if required in an applicable jurisdiction to comply with applicable laws) without their parents consent. If you are not over 18 years old (or older if required in an applicable jurisdiction to comply with applicable laws) then DO NOT DOWNLOAD OR USE iTRANSLATE MEDICAL without your parents consent. If you believe that we may have personal information from or about a child under the age of 18 years old, please contact us here. Note that we'll attempt to delete the account of any child under the age of 18 that's reported to us as soon as possible. You are responsible for any and all account activity conducted by a minor on your account.
For our European users, our Data Protection Officer is responsible for ensuring your rights are respected and to review and oversee how we collect and use your personal information. They can be reached here.
If you are a resident of California, please contact us here.
Our support team can be contacted at firstname.lastname@example.org.
Without prejudice to any other rights you may have, if you are located in the EEA, you also have the right to file a complaint against iTranslate with the Austrian Data Protection Commissioner ("DPC"), which is iTranslates Lead Supervisory Authority. The DPCs contact details are:
AUSTRIA / EUROPE
Telephone: +43 1 531 15 / 202525
Fax: +43 1 531 15 / 202690
If you live in the EEA, you may also file a complaint with your local data protection regulator.
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