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.
Neon Creative Technology Limited 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 email@example.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 firstname.lastname@example.org 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)
The information that we collect and process about you in our capacity as a data processor is as follows:
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:
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.
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 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. Usually, data will be anonymised but this may not always be possible. The recipient of the data will be bound by confidentiality obligations. 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.
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).
If you would like further information on the third parties that we may share your personal information with, please contact us at email@example.com.
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 firstname.lastname@example.org.
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.
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 email@example.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.
As a result of us processing your personal data, you have a right to:
To exercise any of your rights set out above please contact us at firstname.lastname@example.org.
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.
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 email@example.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