CaptionHub Website and Platform Privacy Policy

Neon Creative Technology Limited (“Neon”, “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 a business 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 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, in relation to which you should also refer to your employer’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 how and why we use your data.

About Us

Neon Creative Technology Limited is a limited liability company incorporated in England and Wales.

We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation.

The CEO is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this policy including exercising your legal rights, please contact us at support@captionhub.com.             

Collection and Use of personal data (as data controller)

We collect the following personal data in our capacity as data controller where it is necessary in order for us to provide the Site and the Platform to you or where it is necessary for the purposes of legitimate interests pursued by you or us, as further detailed below. Some of this data will be collected by third parties on our behalf:

•  Account Details: To use the Site or the Platform, you will be required to create an account. This will be used for logging into the Site or the Platform and you will receive email notifications of events taking place inside CaptionHub which you can opt out of at any time. We will also collect data on user subscriptions, upgrades and cancellations and this will be recorded against your account profile to allow us to manage the service we provide to you. If you elect to pay via credit card your credit card details will be processed via a third party securely and in compliance with applicable law, we will not have access to this data. We process this data for our legitimate interests to be able to provide the Site and the Platform to you and, where applicable, your employer, if we have a business account with them. If you do not provide the required information, we will not be able to create an account for you and you will not be able to access the platform.

•  Platform Activity Information: Through your use of the Site or the Platform, we collect and process anonymised information about how users interact with the Site and the Platform. See the ‘Aggregated Data’ section for more information.

•  Marketing Information: As further detailed below.

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

We will also process the following personal data as a processor on behalf of business clients:

•  Video Information: When you upload material to the Site or Platform, for example video, timed text, attachments and so on that is 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 who help us to provide the captioning services to you.

•  Assistance Information: If you submit an enquiry, report a problem with the Site or Platform (usually via online form submission) or respond to a communication from us, 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 user’s interaction with the Platform through screen captures, this allows us to make better design choices for the Platform (for the avoidance of doubt, sensitive information such as passwords and credit card details aren’t collected through this process).

•  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 may display this information publicly or share it with third parties on an anonymised and aggregated basis.

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.

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

For information on third party marketing please see the section titled: ‘Who we share your data with’.

 

Aggregated Data

 As stated above we may share linguist performance information with third parties on an aggregated and anonymised basis. We also collect and retain information about account holders’ usage of the functionality within the Service (“Service Usage Data”). Such anonymised Service Usage Data may be used by us for statistical analysis, for product and service improvement (including the use of the Service Usage data for machine learning), for billing and for monitoring of the account holders’ compliance with the terms of use of the service.

 

Who we share your data with

We may need to share your personal data with selected third parties in the following limited circumstances only:

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.

We will share video information data with various third party service providers who help us to provide the captioning services to you.

Third party service providers for marketing purposes: If you explicitly consent to any marketing from us, certain personal data may be shared with third party service providers we use to help us carry out marketing including, for example, third party marketing automation platforms. We will only use your personal data for our own marketing purposes and won’t share your data to allow third parties to market to you.

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 Neon buys or sells any business or assets, we may disclose your personal data to the prospective buyer or seller of such business or assets. If Neon (or substantially all of its assets) is acquired by a third party, your personal data held by Neon, or within such assets, may be transferred to such third party.

For the avoidance of doubt, we shall not share your Personal Data with third parties wishing to use your personal data for direct marketing, advertising or selling.

 

International transfers

We will not transfer your personal data outside of the European Union, 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 are based in the United States.

Where such transfers are to a county outside the European Union, we rely on one of the European Commission’s adequacy decisions, we will rely on the EU-US Privacy Shield for transfers to the USA where the entity is registered with the EU-US Privacy Shield or we will use reasonable efforts to put in place appropriate safeguards to cover transfers of your personal data including, for example, signing standard contractual clauses/data protection clauses adopted by the European Commission. Please click here for a link to the standard contractual/data protection clauses and click here for more information about the Privacy Shield for US companies.

In the event of such a transfer, where applicable, we will put appropriate safeguards in place to cover transfers of your personal data including, for example, signing standard contractual clauses/data protection clauses adopted by the European Commission, or where applicable, relying on a Privacy Shield certification where the transfer contains a US entity.

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.

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. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting support@captionhub.com.

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 research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

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, including to withdraw your consent where we have stated we are processing your personal data based on your consent, 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.

You also have the right to lodge a complaint with a supervisory authority about the processing of your personal data. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ .

 

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 in order to provide the Services. Please contact support@captionhub.com for a copy of our Security Policy.

 

Third party websites

Throughout our website we may link to other websites owned and operated by certain trusted third parties. These other third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third party websites, please consult their privacy policies as appropriate.

 

Changes to this website privacy policy

This privacy policy was last updated in February 2019. We may change this website policy from time to time and we will notify you of changes that we make to this privacy policy, where applicable.