RWS PRIVACY NOTICE
This Privacy Notice explains why and how RWS Holdings PLC and its subsidiaries (“RWS” or “we” together or individually as applicable), subsidiaries as defined in section 1159 of the UK Companies Act 2006, processes the personal data we receive over our websites, through Applications and software, through our online services, when we provide services such as support, when we license our products, when we handle enquires about our products and services and any other means, such as, for example, when we obtain your data at a trade show. These are all the situations where RWS is the Data Controller.
RWS also offers some language Online Translation Services. When providing these services RWS is a Data Processor.
The RWS Group is an international group of companies which operate together to provide our products and services. This Privacy Notice applies to all companies in the RWS Group. Details of the individual companies are available at RWS Companies.
RWS’s objective when processing any personal data is safeguarding the individual’s privacy. This Privacy Notice is designed to provide transparency on the extent to which we process your data and how we process your personal data, to enable you to exercise the control available to you.
RWS complies with applicable law at the locations where the processing takes place. This includes but is not limited to the UK Data Protection Act 2018, General Data Protection Regulation in the European Union and the California Consumer Privacy Act in California, so far as they apply to our activity. Our obligations and your rights under this legislation is explained in this Notice.
1. Applicability and Acceptance
This Privacy Notice applies in all our interactions with you when we collect and process your Personal Data as a Data Controller:
- When you first visit a RWS website a Privacy message appears informing you RWS will process your personal data. By continuing to use the RWS website you have agreed to RWS processing your personal data and have agreed to the terms of this Privacy Notice, a link to which is provided on the RWS website.
- In your activity on our websites such as when you complete a contact form, or complete a registration form for a Webinar or enter a competition or when you download documents or media files, or you share your personal data from other social applications, services or websites. We will notify you we are collecting your personal data and we will provide you a link to this Privacy Notice. When you provide your personal data or otherwise continue with an activity that is confirmation that you have read and understood this Privacy Notice.
- On our websites you are able to sign up to use various services we offer and you are able to purchase software. To utilise these services you may have to open a user account and/or acquire an ID. When using these services for the first time a Privacy message will appear and you will be asked to acknowledge you understand our use of your personal data.
- Any activities more fully explained in the Notice below or other activity generally.
In this Privacy Notice at Section 4 we explain when RWS is a data processor processing any personal data you provide.
This Privacy Notice does not apply to our shareholder’s personal data, our employees or job applicant’s personal data or our processing when RWS is engaged as a Data Processor or Sub-Data Processor by our customers under standalone Data Processing Agreements.
Children under the age of 13 may visit our websites to use our Online Translation Services.
Children you must ask your parent or guardian's permission before you give any personal data or information to us by entering it into forms on our website, or entering it into one of our translation services. Personal information is your name, address, age, telephone numbers, email address and other information which is special to you. If you do not have your parent or guardian's permission you are not allowed to provide us with personal information.
All other RWS websites are not intended for children and RWS does not intentionally collect personal data from children. If we discover we have collected personal data from a child we will delete the information as soon as possible. If you have any concerns or believe a child has provided us with personal data please contact firstname.lastname@example.org.
3. Personal Data
Personal data is data you would recognise such as your name, date of birth and address but also any data from which you can be personally identified.
This list describes the types of data we collect from you and process:
- email address, phone number, telephone number, title/role and IP address to enable us to interact with you in a sales process or when we are providing support;
- data we use to verify your identity username, passwords and answers to any security questions;
- depending on the services you use: financial information, such as bank account details, Payment Card Details, billing and other information you provide to purchase a product or services and content you generate or that relates to your account; and
The above list is not exhaustive but gives you a general picture. If we have to ask you to provide more personal data we will explain why when we ask for it.
We may receive information about you from other sources:
- We work with third parties, (for example, payment services providers, credit agencies, sub-contractors in technical services and marketing companies or organisations) and may receive personal data from them about you.
- Through marketing initiatives we may receive your personal data from a business or social contact. We may receive your personal data from organisations providing company employee contact details for business to business information.
- Our Partners which could include Resellers or entities we enter into OEM agreements with, will collect personal data from their customers which they pass to RWS to enable RWS to license software to their customers and for RWS to provide support and maintenance.
4. Why we collect your Personal Data and the lawful basis for our processing?
RWS processes your personal data as a Data Controller either to perform our contractual obligations with you or for legitimate interests associated with the delivery of our business, including sale of products and provision of services (both free of charge and charged). We may also specifically ask for your consent for processing of your personal data in some cases. The table below describes our processing and explains the lawful basis we rely upon to process your data:
|To provide you with marketing information on products and services that you request from us and provide further information we consider appropriate. This information can be provided by Live Chat or instant messaging services and other communication methods as described below.||RWS considers this is necessary for our legitimate interest of responding to your enquiry and providing details of our products and services.|
|To provide you with operational information on products and services which we provide to you.||RWS considers this is necessary for our legitimate interest of providing you with necessary information on the use of our products and services.|
|To receive your personal data from a business or social contact who considers you may be interested in our products or services, or an organisation providing business contacts data.||RWS considers this is necessary for our legitimate interest of contacting you to enquire if you would be interested in receiving details of our products and services.|
|To enable you to partake in RWS Communities activity or subscribe to our blogs.||RWS will ask for your consent to process your personal data for this purpose. You can withdraw your consent at any time.|
|To enable you to partake in activity on our websites.||RWS considers this is necessary for our legitimate interest of enabling you to benefit from additional services we offer. When this occurs you will be informed and can decline such offer or withdraw at any time.|
|To enable you to partake in Certification programmes on our websites, including publication of your certification.||RWS will ask for your consent to process your personal data for this purpose. You can withdraw your consent at any time.|
|To provide you with access to various platforms or services, either as a consumer or employee of a RWs customer.||RWS considers this is necessary for our legitimate interest of providing access to the platform or service including ensuring the security.|
|If you enter into a contract with RWS to receive products or services to enable RWS to fulfil our obligations to you, bill you and process the payment.||RWS will process your personal data which is necessary to perform the contract including the provision of support and maintenance if applicable.|
|When you enter into a specific support and maintenance agreement with RWS. RWS has the autonomy to determine the manner in which personal data is processed and is responsible for controlling how such personal data is processed in order to fulfil its obligations under the agreement.||If RWS has a contract with you to provide support and maintenance we will process such personal data as is necessary to perform the contract.|
|If you enter into a contract with RWS to provide products or services to RWS to fulfil our obligations to you, pay you and process the payment.||RWS will process such personal data as is necessary to perform the contract.|
|Provide an enhanced and personalised user experience when visiting our websites to ensure that content from our site is fully accessible and presented effectively for your computer and you.||RWS considers this is necessary for our legitimate interest of providing you with enhanced and personalised service to provide you with pertinent information.|
|Provide you with information by post, telephone, fax, SMS or by email about other goods and services we offer that are similar to those that you have already purchased or enquired about.||RWS relies upon our right to direct market to you in these circumstances. We provide you with the option to unsubscribe from this service at any time.|
|Administer your user account and keep you informed about changes or developments to the websites.||RWS considers this is necessary for our legitimate interest of responding to your enquiry and providing details of changes to our websites.|
|Administer any correspondence with you or complaints you make.||RWS considers this is necessary for our legitimate interest of responding to your correspondence or complaint.|
|Investigation of any security or personal data incidents. Investigation of any inappropriate, illegal or fraudulent use of our products or services.||RWS considers this is necessary for our legitimate interest of protecting both our business and the data of customers for which we are responsible. In certain circumstances such processing maybe to comply with a legal obligation to which RWS is subject or to protect the vital interests of data subjects or natural persons.|
|Receive personal data of users of our software from Partners etc. for the purpose of licensing our software and/or providing support and maintenance||Where RWS enters into a contract directly with the end user RWS will process such personal data as is necessary to perform the contract. If RWS does not have a direct relationship with the end user then RWS considers we have a legitimate interest in processing the user’s personal data to enable their use of our software and protection of RWS’s intellectual property.|
RWS uses the personal data we automatically collect to:
- Enable you to participate in interactive features of our sites;
- Ensure that content is presented in the most effective manner for you and for your computer;
- Maintain the security of our sites and services;
- Deliver relevant advertising to you about our products and services and measure the effectiveness of our marketing; and
- Administer our sites through data analysis, testing and support.
RWS considers this automatic processing of your data to be lawful and consistent with our legitimate interest to administer our site and provide you with relevant information about our products and services.
5. Links to Other Sites
6. If you use our Online Translation Services
7. If your use of our Products or interaction with RWS is as an employee or consultant of a RWS customer
If you use RWS products licensed to your employer, or organisation you are engaged by, or use an email address provided by the organisation you will be identified in our records as affiliated with that organisation. Similarly if your organisation obtains services from RWS such as support and maintenance or localisation services and you are a point of contact for your employer, your records will be affiliated with that organisation. Your use of the products or services will be subject to that organisation’s policies and the contract between your organisation and RWS. Other users in your organisation or authorised third parties may monitor some or all of your activity with the products and services, configure the product including security and privacy settings and access any data you enter. All privacy questions in respect of the products and services licensed to your organisation ought to be directed to the organisation.
If we have a contract to provide support and maintenance to an organisation of which you are an employee, or you are engaged by such company as a consultant, the organisation can provide your personal data so far as necessary for us to interact with you for the purposes of the services we are providing. We consider we have a legitimate interest in processing your data for this purpose.
In the event of any conflict between this Privacy Notice and any contract or Data Processing Agreement (“Agreements”) between RWS and a customer the terms of the Agreements will prevail.
8. Who will have access to your Personal Data and who do we share it with?
Within the RWS Holdings plc companies:
Your personal data will be processed by personnel in the RWS Group companies to complete the purposes for which we collect your data and to fulfil our obligations as a Data Controller. Details of the individual companies are available at RWS Companies.
Outside the RWS companies:
We may share your personal data with these third parties:
- Partners etc. appointed in countries in which RWS does not have offices, who sell our products. If we identify you are logging into our website from such a country we will pass your personal data to our Partner etc. to provide you with an ability to obtain information about our products;
- Industry or solution specialist Partners etc. appointed by RWS to sell our products in an industry sector or as a total solution. If we identify you are involved in or interested in an industry sector or in a total solution offering we will pass your personal data to our Reseller or OEM partner who may contact you to provide you with details etc. about our products and their services;
- Organisations such as agents or sub-contractors with which we engage to perform functions on our behalf, such as sending customer communications, analysing data, providing marketing assistance, processing payments and providing customer service. These organisations will have access to personal data needed to perform their functions, but may not use it for any other purposes;
- Internet telephony service providers, hosting centre providers or providers of SAAS such as AWS or Microsoft or any other provider of IT services or applications ancillary to the Service which RWS offers or use in the ordinary course of our business;
- If RWS sells any business or assets, we may disclose your personal data to the prospective buyer of such business or assets and your personal data may be one of the transferred assets. The buyer will process your personal data for the purposes of the acquisition and their business;
- To any other business entity into which RWS enters into a joint venture or other arrangement;
- To address security or technical issues;
- If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, or in order to enforce or apply our legal rights. This includes exchanging information with other companies and organisations for the purposes of fraud protection or credit risk reduction; and
- Law enforcement or regulatory agencies, if required to do so by law, or by an order of a Court.
We will not otherwise share or distribute any of the information you provide to us without your consent.
We will not sell, trade or rent personal data to unaffiliated third parties except if we have obtained your express permission. Our site may contain links to other websites that are outside our control and are not covered by this Privacy Notice. If you access other websites using the links provided, the operators of those websites may collect information from you which will be used by them in accordance with their applicable policies, which may differ from ours.
9. International Transfers
The Personal Data that we collect from you may be transferred to, and stored at, a destination outside the country you are resident in or the country in which you provided it to us. It may be processed by staff operating in another country who work for RWS or for one of our suppliers. By submitting your information, you agree to this transfer, storing and or processing. We will take all steps reasonably necessary to ensure that your information is processed securely.
In particular for citizens of the European Union (“EU”), European Economic Area ("EEA") and United Kingdom (“UK”). The Personal Data that we collect from you may be transferred to, and stored at, a destination outside the EU, EEA or UK. It may also be processed by staff operating outside the EU, EEA and UK who work for us or for one of our suppliers. By submitting your information, you agree to this transfer, storing and or processing. We will take all steps reasonably necessary to ensure that your information is processed securely and appropriate safeguards are in place including acceptable transfer mechanisms.
RWS is aware of the Court of Justice of the European Union decision known as “Schrems II”. Transfers of personal data from EEA, Switzerland and UK continue to take place under the EU Standard Contractual Clause framework. RWS continues to monitor developments.
For citizens outside the EU, EEA and UK applicable laws may have similar requirements for data transfer between countries. Where applicable RWS complies with such applicable laws.
A copy of the applicable documentation ensuring the necessary safeguards, where required, can be obtained from RWS using the Contact details below.
10. How long do we keep your data?
We will retain your information for various different periods of time, depending upon our relationship with you and the purposes for which we have collected your data. We will only retain personal data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.
However, if you wish to have your personal data removed from our databases, you can make a request using the Contact details below. All requests will be considered in accordance with the circumstances set out in Section 11 and the applicable law.
We may retain minimal items of your personal data for recording of opt-out purposes including when you have requested the deletion of your personal data.
11. Your rights
You are in control of the personal data RWS processes and you can:
- Withdraw your consent if RWS has obtained your consent to processing your personal data at any time;
- Request confirmation your personal data is being processed and a copy of the personal data being processed. RWS will respond to any request to the extent required by law and may charge a reasonable fee as provided by applicable law;
- Obtain rectification of any inaccurate personal data;
- Obtain the erasure of any personal data as provided by applicable law and RWS will erase unless required or entitled to preserve the personal data;
- Request RWS to temporarily restrict its processing of your personal data while we are investigating a complaint you have;
- Object to processing by RWS as provided by applicable law including profiling of you;
- Object to your personal data being used for direct marketing services to you.
- in certain circumstances, to receive your personal data, which you have provided to us, in a structured, commonly-used and machine-readable format and the right to transmit that data to another data controller without hindrance, or to have that personal data transmitted to another data controller, where technically feasible;
- to be informed about any use of your personal data to make automated decisions about you, and to obtain meaningful information about the logic involved, as well as the significance and the envisaged consequences of this processing; and
- to lodge a complaint about the way in which your personal data is being used to a supervisory authority.
If you believe that personal data we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it or you want RWS to stop processing your personal data you can inform us of your request by either:
- Using the Preference Centres available at https://info.sdl.com/preferences.html. you will be able to change your own preferences and details in respect of marketing communications.
- Contacting your normal contact at RWS.
- Emailing your request to email@example.com
We will comply with all lawful requests but can refuse such requests in certain circumstances which you will be informed of if they apply.
There are some circumstances where RWS may be a Joint Controller of your personal data with another Data Controller, such as, for example, where we are working with a Partner etc.. Where RWS is a Joint Controller we will be responsible for the personal data we hold and process. In respect of the personal data RWS holds you can exercise the rights we have explained above, such as requesting deletion etc., by asking RWS using the contract details below. If you wish to exercise your rights against the other Joint Controller you may do so by contacting them.
12. How RWS protects your information
- RWS ensures that its Privacy Notice is in compliance with all applicable privacy laws and regulations.
- Certain RWS companies in the USA comply with the EU-US Privacy Shield and Swiss-US Privacy Shield as set by the U.S Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries, Switzerland and United Kingdom. RWS Life Sciences Inc. and SDL INC. have certified that they adhere to the EU-US and Swiss-US Privacy Shield Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement. To learn more about the EU-US and Swiss-US Privacy Shield program and to view their certifications, please visit https://www.privacyshield.gov/list. Please see our specific Privacy Shield notices
- RWS and its subcontractors will maintain appropriate security procedures and practices to safeguard the product and your data against unauthorized access and to maintain the confidentiality of your data in accordance with the applicable law. We employ strict physical, electronic and administrative security measures to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage both on-line and off-line. The data is encrypted when in transit between your device and the RWS system and our products are hosted in third party data centres with industry leading security.
- The Internet is an inherently open and insecure means of communication, any data a user transmits over the Internet may be susceptible to interception and alteration. RWS makes no guarantee regarding, and assumes no liability for, the security and integrity of any data you transmit over the Internet, including any data transmitted via any server designated as "secure". You should not have an expectation of privacy in any content, including accounts of files transmitted through the internet.
No website can be completely secure. If you have concerns your rws.com account may have been compromised please contact RWS using the Contact information below.
13. California Consumer Privacy Act
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/privacy-laws.
As the RWS companies are an international group of companies it is necessary for us to have the ability be able to process personal data in our offices throughout the world. Consequently, any personal data we collect may be disclosed for our business purposes to those of our worldwide companies as required. All processing, wherever it takes place, is undertaken utilising appropriate security and organisational measures. We may engage third party organisations to perform specific processing activities on behalf of a RWS company. Personal data is not sold to such organisations and we ensure appropriate security and organisational measures are utilised.
RWS confirms we do not sell any personal data we collect to third parties.
We have explained in section11 above how you can exercise your rights and in section 17 below we explain how you can contact us. In addition to the rights in Section11 above a California resident may also:
- Request disclosure of personal information sold or disclosed for a business purpose.
- Not face discrimination for exercising a right under the CCPA.
- Opt out of the sale of personal information, (as explained above RWS does no sell personal information).
14. Changes to our Privacy Notice
15. Governing Law and Jurisdiction
If you are unhappy with the way RWS is processing your personal data please contact either the centralised privacy response (firstname.lastname@example.org). You may wish to contact an individual RWS company but please be aware all responses are handled centrally through email@example.com.
In the EU and EEA countries and other countries you have the right to lodge a complaint with the relevant Supervisory Authority responsible for overseeing the processing of personal data. In the list of RWS Companies are details of the relevant Supervisory Authorities for each of our companies.
If you have any questions, comments or concerns about the Privacy Notice, please contact our centralised privacy response contact as follows:
Email at: firstname.lastname@example.org
RWS Holdings Limited
Chalfont St Peter
FAO: Privacy Officer (Legal Department)
T: +44 (0) 1753 480 200
F: +44 (0) 1753 480 280
For all California Consumer Privacy Act enquires and Consumer Rights Requests:
Please either email to email@example.com or phone: +1 888 351 2210
18. EU and UK Representatives
The RWS Group has appointed the following Representatives:
U.K. Representative for all E.U. located RWS organisations within the RWS Group offering goods or services within the U.K.:
RWS Holdings Limited
Chalfont St Peter
FAO: Privacy Officer (Legal Department)
E.U. Representative for all U.K. located RWS organisations within the RWS Group offering goods or services within the E.U.:
Moravia IT s.r.o.
Postal Code 602 00, Brno,
FAO: Nada Matusikova
RWS Holdings plc is a company registered in England with registered number 03002645 of Europa House, Chiltern Park, Chiltern Hill, Chalfont St Peter, SL9 9FG, England. Details of all our subsidiary companies is available at RWS Companies and RWScontact details.
Last updated: 12 April 2021