Data Protection

INTERPRETER PRIVACY NOTICE

I. General Information

Interactio, Ltd ("we") is committed to protecting Your privacy and Your data. Transparency and data protection are very important for our business. This Privacy Notice describes how we process and use the personal data that we receive from You, when having contractual relationships related to Conference Interpreting Management Services.

If You have additional questions regarding our processing of Your data, You can contact our data protection officer here: dpo@interactio.io.

Who we are:

Interactio UAB, Company code 303303137, Address Paupio str. 50-136, LT-11341 City: Vilnius. Country: Lithuania. Data protection officer contact: dpo@interactio.io.

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II. What Personal Data do we process?

Your contact information is your name, surname, address, and phone number. Your Interpreting working languages A, B, C, technical information about your devices and network, qualification documents ( educational diplomas, details about affiliations, certificates that you hold), personal development experience, your interpreting experience, and test results. Information about signed documents and their expiration dates, During interpreting services we will collect your voice recordings ( if voice recordings were ordered). Technical information from your device ( OS version, Browser type, Browser version, IP address) and stream of the event ( Session ID, RTP session ID, RTSP URL (local IP), Event ID, Topic ID, Stream ID) for troubleshooting and identification reasons.

Why do we need this data and what is the legal basis for processing?

The list of data collection, storage, and processing purposes can be found in Table I at the end of this document.

All data is stored in European Union data centers.

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III. With whom we share your data?

Processing activities by other Data controllers are governed by GDPR requirements.

With Lithuanian Republic State tax inspectorate we will send information about made payments;
With SEB BANK we will share your bank account name, surname and earned income; They provide money transfer services.

IV. What third-party processors do we use to process your data?

Processing activities by third-party processors is governed by a Data Processing Agreement or other specific terms agreed upon by Interactio and third-party processors.

The list of data processing entities involved in the process of collecting and accessing your data is shown below:

Amazon Web Services (Europe) - hosing and data storage of the SIDP platform.
Digital Ocean (Europe) - media service hosting services.
Shortlist Project Inc. (Europe) - managing Interpreter profiles and manage interpreter requests and assignments.
Directo (Europe) - financial management system.
Google Inc. (Europe) - email system used for communication purposes.
Atlassian (Europe) - meeting management system used to ensure that all needed tasks are done on time and according to agreed quality.

Linearis (Europe) - conference events organizers, hired by Interactio and acting as data processors.

Zoho (Europe) - incident and request management system.

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V. Your Rights to Your Data

Right to obtain information on the processing of personal data;
Right of access;
Right to rectification;
Right to erasure (right to be forgotten);
Right to restriction of processing;
Notification obligation regarding rectification or erasure of personal data or restriction of processing;
Right to data portability;
Right not to be subjected to automated decision-making without a legal basis.

If you have any questions regarding your data processing, please contact Interactio's data protection officer via Email dpo@interactio.io.

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VI. Your right to complain

If you have a complaint about our use of your information, we would prefer you to contact us directly in the first instance so that we can address your complaint. However, you can also use your right to file a complaint with a supervisory authority (contacts of supervisory authorities in the European Union:

https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

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VII. Updates to this Notice

We regularly review and, if appropriate, update this policy periodically, as our services and use of personal data evolve. If we want to make use of your data in a way that we haven't previously identified or mentioned above, we will contact you beforehand to provide extensive information and, if necessary, ask for your consent.

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Document version 2.0

Last Updated: Apr-15, 2024

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TABLES

Table I. Data collection, storage, and processing purpose list

Purpose

Legal Basis

Data Categories

Data Retention

PURPOSE FOR THE DATA
ACCESS

DATA LOCATION

For communication and entering in contact with a Interprter

To enter into the contract with the interpreter GDPR Clause 6 (B)

Name, surname, email address, and phone number.

Information is gathered until the Interpreter's profile undergoes evaluation for compliance with the requirements. Information related to positive evaluation is retained until the contract's conclusion, while negative is removed from the profile unless the interpreter provides consent for data storage.

To evaluate Interpreter professional profile

To enter into the contract with the interpreter GDPR Clause 6 (B)

Name, surname, email address and phone number, A-B-C languages, rates, education, accreditation, affiliation and years of experience

To evaluate Interpreter qualifications and experience in simultaneous conference interpreting

To enter into the contract with the interpreter GDPR Clause 6 (B)

Contact information (name, surname, address, and phone number), working languages A-B-C, qualification documents (relevant diplomas mentioning language combination, graduation date, and institutional stamp, optionally: ECTS credits/for EU-based universities), training and professional courses certificates), proof of accreditation (e.g. attestation letters with official signature, screenshots from directory), proof of affiliation (link so associations’ website), links to professional websites (own website, LinkedIn if provided)

To sign and manage all necessary documents (Agreement, NDA, etc.)

To enter into the contract with the interpreter GDPR Clause 6 (B)

Legal name, official domicile address, date of birth, email and phone number

The information is processed for 2 years after the end of the contract

To evaluate Interpreter technical capabilities to provide simultaneous interpreting services

To enter into the contract with the interpreter GDPR Clause 6 (B)

Technical information about your hardware (headset and backup headset, optionally microphone and headphones, computer and backup computer with specifications), software (browser and its update), main and backup Internet connection source and specifications (download, upload, jitter, ping)

The information is processed for 2 years after the end of the contract

To evaluate Interpreter competencies

To enter into the contract with the interpreter GDPR Clause 6 (B)

Diplomas (information about education in conference interpreting), certificates, post-event feedback, technical QA test results, equipment and software specifications, list of events interpreted by an interpreter on Interactio, proof of accreditation and affiliation, CPD certificates

The information is processed for 2 years after the end of the contract

To organize the event and collect all needed data

To maintain contract and to organize an event GDPR Clause 6 (B)

Email, first and last name, event information phone number (title, date and time, client name, topic and requirements, language combinations, event environment)

The information is processed for 3 years after the end of the contract

To ensure secure authentication and authorization by connecting to the Interactio SIDP platform

It's our legitimate interest to secure access to Interactio SIDP GDPR Article 6 (1) (F)

Name, phone number, email, password, and technical information related to your device.

6 months after signing into the system.

To troubleshoot incidents and manage requests from Interpreter

It's our legitimate interest to organize and manage events and requests that are related to you or requests from you Article 6 (1) (F)

Name, surname, details provided

2 years after the request or incident is solved.

To keep evidence that event was organized according to the rules

It's our legitimate interest to organize and manage events and requests that are related to you or requests from you Article 6 (1) (F)

Name, surname, details provided

2 years after end of the event

To receive and analyze feedback after the event

It's part of the contract to get information about event quality, booth partner interpretation quality GDPR Article 6 (1) (B)

Feedback information, date, first and last name, email address, event title, and language combination.

1 year after feedback was collected

To pay invoices

To meet contractual obligations with you GDPR Article 6 (1) (B)

Bank account number (IBAN), bank name, SWIFT code, bank address, total amount, PO number, event details (date, language combination), legal name and (if applicable) name of the company, professional domicile, contact details (email address and/or phone number)

10 years after the invoice was issued

To meet financial obligations by keeping purchase orders and information related to it.

To fulfill legal requirements (GDPR Article 6 (1) (C)). Under the Lithuania Republic Law we shall process information related with payments and signed contracts;

Purchase order and information about the total amount paid

10 years after the invoice was issued

Processor: Digital Ocean

Data type: Personal data contained incommunications customers send or receive remote simultaneousinterpretation (RSI) platform “Interactio”

Purpose: To provide media streamingfunctionality in remote simultaneous interpretation (RSI) platform“Interactio”