CaptionHub Website and Platform Privacy Policy

CaptionHub Ltd (“CaptionHub”, “us”, “our” and “we”) respects and values your privacy and is committed to protecting your personal data. This privacy policy tells you how we look after your personal data when you visit our CaptionHub website (the “Site”) or when you use the CaptionHub platform (the “Platform”) as an authorised end user in relation to a business account.

In some limited circumstances we are the controller of your personal information, as outlined in the “Collection and Use of your personal data” section below – in this case we are the party responsible for your personal information.

In other circumstances we are acting as a processor of your personal data, also outlined in the “Collection and Use of your personal data” section, i.e. where we process your data on the instructions of your employer or a company that you are engaged by or volunteer for, in relation to which you should also refer to that third party organisation’s privacy policy.

This privacy policy also details your privacy rights and how the law protects you.

It is important that you read this privacy policy together with our cookies policy https://app.captionhub.com/page/cookies, so you are fully aware of how and why we use your data.

About us

CaptionHub Ltd is a limited liability company incorporated in England and Wales. 

If you have any questions about this policy including exercising your legal rights, please contact us at support@captionhub.com.  

Our EU Representative

We have also appointed IT Governance Europe Limited to act as our EU Representative. If you wish to exercise your rights under the EU GDPR, or are located within the EU and have any queries in relation to you rights and privacy matters generally please email our EU Representative at eurep@itgovernance.eu or post your request or query to:  

EU Representative, IT Governance Europe, Third Floor, The Boyne Tower, Bull Ring, Lagavooren, Drogheda, Co. Louth, A92 F682. 

When contacting our Representative please ensure you include our company name in any correspondence. 

If you are located within the EU you can also contact us directly with any queries you may have. 

Collection and Use of your personal data (as a data processor)

When you are using either our Site or Platform as an authorised end user through a customer account, we will be acting as a processor on behalf of that customer. Our business customers will be the controller of your personal data and will be responsible for determining the lawful basis for collecting and processing your personal data – you should refer to the relevant customer’s privacy policy for more details. This is likely to be your employer or alternatively a company that you are engaged by or volunteer for, where you use our Site or Platform in the course of your employment or engagement.

The information that we collect and process about you in our capacity as a data processor is as follows:

• Account Details: To use the Site or the Platform, you will be required to create an account by providing your username and email address. This will be used for logging into the Site or the Platform. You will also receive email notifications for actions taking place inside CaptionHub which are generated as part of our Site and Platform functionality for example to notify you that your video has finished encoding. You can however stop these notifications being sent directly to your email address within your account settings. We will also collect data on our customer’s user subscriptions, upgrades and cancellations and this will be recorded against your individual account profile to allow us to manage the service we provide to you. 
• Video Information: When you upload material to the Site or Platform, for example video, timed text and attachments, that are likely to contain personal data of those featured in the video, we will process this to the extent necessary to provide you with the captioning services and will share the data with various third party service providers to the extent that this is necessary for us to provide the captioning services requested by you.
• Assistance Information: If you submit an enquiry or respond to a communication from us in relation to your use of the Site or Platform or report a problem with the Site or Platform (usually via online form submission), we may be provided with certain personal data such as your name and email address, and we will receive the information contained in the correspondence (which will contain your personal data that you provide to us). 
• Platform Performance Information: We constantly monitor the Site and Platform for performance, and we are proactively warned if a user encounters an error. We cross reference the error with the user, to allow us to recreate the issue, and to allow us to make any fixes as quickly as possible. We also capture our users’ interaction with the Platform through screen captures, this allows us to make better design choices for developing and improving the Platform for our customers (for the avoidance of doubt, sensitive information such as passwords and credit card details are never recorded or collected through this process).
• Service Usage Information: Through your use of the Site or the Platform, we collect and process information about how users interact with the Site and the Platform. This enables us to monitor the account holders’ compliance with the terms of use of the service. We will also anonymise and aggregate this information for certain purposes – after which it is no longer personal data. See the ‘Aggregated Data’ section for more information.
• Linguist Performance Information: We also track how much has changed in between translations, and how much time a user has spent being assigned to a particular set of captions. We monitor how many linguists are assigned to a particular project, time taken on a project and statistics relating to the video being translated, such as the word count and duration. We collect and process this information to enable us to develop our services on behalf of and for the benefit of our customers. Sometimes this information will not relate to a specific user and will not be personal information, however sometimes it will be. If we ever share Linguistic Performance Information, for example display it publicly or share it with third parties, we will always do so on an anonymised and aggregated basis. See the ‘Aggregated Data’ section for more information.

Aggregated Data

As stated above we may share Linguist Performance Information with third parties or display it publicly on an aggregated and anonymised basis – once this information has been anonymised it no longer constitutes personal data.

We also collect and retain Service Usage Information. Such anonymised Service Usage Information may be used by us for statistical analysis and for product and service improvement (including the use of the Service Usage Information for machine learning).

Collection and use of your personal data (as data controller)

When we collect or process your personal information other than in connection with your use of the Site or Platform as an authorised end user, we will be collecting or processing your personal data in our capacity as data controller. 

We will collect this from you either directly, such as when you contact us to enquire about our products and services or otherwise to purchase our products and services, or indirectly, by monitoring your browsing activity if you visit our Site to see information about our business and services (see our cookies policy for more information). The information that we collect as a data controller is as follows: 

• Identity and Contact Data: In order to communicate with you and respond to enquiries regarding our business, Site and services, as well as to deal with you as a point of contact on behalf of a prospective or existing customer, we may collect and process your name, email address and telephone number. We do this where it is necessary for performance of a contract with you, or in relation to steps taken prior to entering into a contract with you, or where it is necessary for our legitimate interests in running and developing our business.
• Financial Data: In most cases our customers will pay for services using business cards, however if you elect to pay for our services via a personal payment card or personal bank account, these details will be processed securely via our selected third party payment processor. This information is processed where it is necessary for performance of a contract with you.
• Technical Data: We may also collect your internet protocol (IP) address, your browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use when you access our Site to see information about our business and services, separately from when you log-in to use the Site or Platform as an authorised end user of our services. We collect this information to administer and protect our business and Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), as well as for data analytics to improve our Site, customer relationships and experiences. This is necessary for our legitimate interests to keep our Site updated and relevant, to provide administration and IT services, for network security and to prevent fraud.
• Marketing Information: We may collect and use your name and email address to send you marketing communications and make suggestions and recommendations about products and services that may be of interest to you, as well as record your preferences in receiving these marketing communications from us. We will send marketing communications on the basis of consent, or alternatively where it is necessary for our legitimate interests in growing and promoting our business. See the ‘Direct Marketing’ section for more information.

Our Site is not intended for use by children and we do not knowingly collect or use personal data relating to children.

We do not routinely collect and process special category personal data.

Direct Marketing

You may provide us with your name and email address and other personal data if you sign up to receive marketing communications from us or to request a Platform demonstration.

We have a legitimate interest in marketing to business users to help promote the services that we offer, and will also send marketing communications to other individuals if they have chosen to receive these by signing up on our Site. 

You will always have the option to opt-out of our marketing by clicking the ‘unsubscribe’ button on our emails or contacting us directly. 

We will only use your personal data for our own marketing purposes and will not share your personal data to allow third parties to market to you.

Who we share your personal data with

When we are acting as either a controller or a processor we may need to share your personal data with selected third party service providers, as follows:

Third party service providers: This may include providers of certain systems and services that we use to host, administer and maintain the Site and the Platform, which may be located outside of the UK and EEA, for example in the United States (see “International transfers” below for more information).

Note that we will share Video Information with various third party service providers who help us to provide the captioning services to you. Some of these will be sub-processors acting on our behalf and others will be third parties that you have elected for us to share your Video Information with, in order for that third party to independently provide services to you. A list of our sub-processors can be found here.

To comply with legal or regulatory requests: If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, we may share your personal data with a regulator or law enforcement agency.

Prospective buyers or sellers: In the event that CaptionHub buys or sells any business or assets, we may disclose your personal data to the prospective buyer or seller of such business or assets. Usually, data will be anonymised but this may not always be possible. The recipient of the data will be bound by confidentiality obligations. If CaptionHub (or substantially all of its assets) is acquired by a third party, your personal data held by CaptionHub, or within such assets, may be transferred to such third party.

Third party service providers to assist with our marketing: In our capacity as a data controller only, we engage third party service providers to help us carry out marketing including, for example, third party marketing automation platforms. These third party service providers may also be located outside of the UK and EEA, for example in the United States (see “International transfers” below for more information).

We also utilise YouTube’s API services, meaning that if you use our YouTube connector we will be sharing your personal data with YouTube (as well as receiving personal data from them) so that you can access YouTube video content via the Platform. When accessing YouTube via the Platform you will be required to accept YouTube’s Terms of Service and Google's Privacy Policy. You can revoke the API Client's access to user data via the Google Security Settings.

If you would like further information on the third parties that we may share your personal information with, please contact us at support@captionhub.com.

International transfers

We will not transfer your personal data outside of the UK and EEA, except to selected third parties that we have instructed to help us provide the Site and Platform to you, for example some of our marketing and CRM software providers and hosting and service functionality providers are based in the United States. 

Where such transfers are to a county outside the UK and EEA, we ensure that a sufficient degree of protection is afforded to it by putting in place appropriate safeguards to cover transfers of your personal data including, for example, signing approved standard contractual clauses or data transfer agreements. 

We may also rely on an applicable adequacy decision (confirmation that the destination country provides an adequate level of protection for personal data) – this is the basis on which we transfer personal data between the UK and EEA. 

If you would like further information and/or would like to see a copy of the safeguard we are relying on, please contact us at support@captionhub.com.

Cookies and other tracking technologies

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our Site or Platform. Cookies help us recognise you and your device and store some information about your preferences or past actions.

For further information about cookies and our use of cookies, please see our cookies policy at https://app.captionhub.com/page/cookies.

Period for which your personal data will be stored

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. You can request details of retention periods for different aspects of your personal data from us by contacting support@captionhub.com. Retention information is also available at https://www.captionhub.com/data-retention-policy.

In some circumstances you can ask us to delete your data: see “Your Rights” below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for product development, research or statistical purposes in which case we may use this information indefinitely without further notice to you as it no longer constitutes personal data.

Your rights

As a result of us processing your personal data, you have a right to:

• access personal data held about you;
• request us to make any changes to your personal data if it is inaccurate or incomplete;
• request your personal data is erased where we do not have a compelling reason to continue to process such data in certain circumstances;
• receive your personal data provided to us as a data controller in a structured, commonly used and machine-readable format where our processing of the data is carried out by automated means and is based on: (i) your consent; (ii) our necessity for performance of a contract to which you are a party; or (iii) steps taken at your request prior to entering into a contract with us;
• object to, or restrict, our processing of your personal data in certain circumstances;
• if we use your personal data for direct marketing, ask us to stop and we will comply with your request;
• if we use your personal data on the basis of having a legitimate interest, object to our use of it for those purposes, giving an explanation of your particular situation, and we will consider your objection; and
• to object to, and not be subject to a decision which is based solely on, automated processing (including profiling), which produces legal effects or could significantly affect you.

To exercise any of your rights set out above please contact us at support@captionhub.com. 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Security

We have put in place safeguards to prevent your personal data from being lost, used or accessed in an unauthorised way. We limit access to your personal data to those employees, agents or contractors who have a business need to know the  information, in order to provide our products and services. Please contact support@captionhub.com for a copy of our Security White Paper.

How to complain

Please contact us or our EU Representative if you have any query or concern about our use of your personal data (see contact details at the start of this policy). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner or any relevant European data protection supervisory authority. 

The UK’s Information Commissioner’s Office may be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113

Changes to this website privacy policy

This privacy policy was last updated in November 2022. We may change this website policy from time to time to make sure it is up to date and accurate and we will notify you of changes that we make to this privacy policy, where applicable.