Scope
– This Privacy Policy applies generally to personal data received by ODB INTERNATIONAL GROUP CO., LTD., www.odbtranslation.com and all of their affiliated and subsidiary entities (collectively, “ODB”, “we”, “us” or “our”) in any format. ODB will ensure all global data handled by its offices conforms to this Privacy Policy. However, the details concerning how we process your personal data is dependent on who you are and what our relationship is to you.
Who are we?
ODB may be a data controller of your personal data (also known as personal information), which means that ODB has control of your personal data and may utilize it for various purposes, including sending your information to data processors we work with. Alternatively, depending on who you are and our relationship to you, ODB may be a data processor or a sub-processor of your personal data.
Your personal data – what is it?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or which is likely to come into the data controller’s possession. The collection, use and processing of your personal data may be subject to various data privacy laws (“applicable privacy laws), including for European citizens or residents (“EU Personal Data”), the EU General Data Protection Regulation (referred to herein as the “GDPR”), and for California residents, the California Consumer Privacy Act (the “CCPA”), and their implementing regulations.
How do we process your personal data?
ODB complies with its obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorized access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
The personal data that you provide (or have previously provided) to ODB may be stored in ODB’s data center in the United States.
Further processing
If we wish to use your personal data for a new purpose not covered by an existing privacy policy, we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
Sale of personal data
We do not sell your personal data.
How long do we keep your personal data?
We will keep your personal data for no longer than reasonably necessary for our ongoing business relationship, for record keeping purposes and in case of any legal claims or complaints.
Onward Transfers and Transfer of Data Abroad
As part of its overall global privacy compliance efforts, ODB has elected to adhere to enforcing the EU Standard Contractual Clauses (Processors) concerning the transfer of personal identifiable data from the European Union, including adhering to the requirements effective under the GDPR.
ODB complies with the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from Switzerland to the United States. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
The term "processing" of personal data includes any operation or set of operations performed upon personal data such as collecting, storing, retrieving, consulting, using, disclosing, disseminating, and otherwise making available the personal data.
This Privacy Policy may change from time to time based on changes made to the EU Standard Contractual Clauses and/or the Swiss – U.S. Privacy Shield Framework. Any changes made necessary will be reflected in an update to this policy and disseminated.
ODB's privacy practices are self-certified and reflect current guidance concerning the optimal manner of reaching data privacy compliance in accordance with current legal and regulatory guidance.
Cookies and Website Privacy Practices
The ODB website uses cookies, tracking pixels and related technologies. Cookies are small data files that are served by our platform and stored on your device. Our site uses cookies dropped by us or third parties for a variety of purposes including to operate and personalize the website. Cookies may also be used to track how you use the site to target ads to you on other websites.
When any clients visit ODB's website, ODB does not track Personal Data, names or email addresses. Instead, ODB only tracks which Internet Service Provider has accessed the site as well as statistics that show the number of site visitors, those requests received and the country origin of those requests. This information is used to improve our site in order to better serve our clients, but this information does not constitute Personal Data.
Opting-out
ODB's cookie provider is a member of the Network Advertising Initiative (NAI) and adheres to the NAI Codes of Conduct.
Your rights and your personal data
Depending on your country and/or state of residence, as well as our relationship to you, you may have the following rights with respect to your personal data:
The right to request a copy of your personal data which ODB holds about you (for European or United Kingdom residents)
The right to know the categories and purposes of personal data that we collect about you (for California residents)
The right to request that ODB corrects any personal data if it is found to be inaccurate or out of date (for European or United Kingdom residents)
The right to request your personal data is erased where it is no longer legally necessary for ODB to retain such data (for European, United Kingdom and California residents)
The right to withdraw your consent to the processing at any time (for European or United Kingdom residents)
The right to request that ODB provide you, as the data subject, with your personal data and where possible, to transmit that data directly to another data controller (for European, United Kingdom or California residents)
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing (for European or United Kingdom residents)
The right to lodge a complaint with governmental agencies or Data Protection Authorities as provided for in the GDPR (for European or United Kingdom residents).
To exercise your rights to data rectification, erasure, portability, access and/or restricted processing, please email service@odb-translation.com.
Notice – ODB treats all material sent to us from our clients, vendors, and employees (collectively, "CVEs") as confidential in accordance with its current confidentiality undertakings with CVEs. Confidentiality provisions are required as part of all of our contracts with all of our clients vendors and employees; each separate entity must sign a confidentiality agreement prior to becoming affiliated or working with ODB.
ODB utilizes a network of over 8,000 freelance vendors to assist in the process of translation. They may receive, as part of the assignment, the name of the client they are working on but no Personal Data about that client, unless such contact information is needed to perform the assignment (such as the cases of onsite interpretation projects, onsite document review, etc.). These freelance vendors may also have access to any Personal Data within the source documents and reference material sent to them for translation. However, in all cases, the freelance vendors are subject to confidentiality undertakings in which such freelance vendors undertake to keep such information confidential and only use such information in accordance with their projects.
All vendors who will be processing Personal Data of EU citizens or residents are required to sign the EU Data Protection Agreement and EU Standard Contractual Clauses. These documents address common requirements concerning Notice, Choice, Onward Transfer, Access, Security, Data Integrity and Enforcement of the Personal Data with respect to the Personal Data. Any EU vendor has the right to terminate its working relationship with ODB and request the deletion of Personal Data pertaining to them. However, as permitted by applicable law, ODB will continue to maintain its historical business records in such a way so that ODB may retain its historical knowledge and relationships in connection with any legal or regulatory inquiries which may later arise. This practice is in the best interests of both parties so that identifying information relating to a particular matter is accessible but sufficiently discrete so that ODB does not accidentally contact them for projects in the future.
Choice – ODB clients have the choice concerning what Personal Data is accessed, used or retained. In order to conduct business with our clients, it is necessary to maintain contact information and specific billing information, but the extent of the information stored can always be discussed with a ODB Client Services Representative. Additionally, if there is a specific concern about the Personal Data found in the information provided (such as source, reference material, etc.), we recommend redacting this information prior to sending it to ODB or discussing alternative solutions with your ODB Client Services Representative. In addition, other steps may be taken which may include the forced anonymization of information and limitation of translation efforts to de-identified data only.
In order to better serve our client's needs and provide further information concerning services, ODB may, from time-to-time, send information on additional services we provide. Should any client decide that this information is not desirable, a client may opt-out of receiving this information by informing their Client Services Representative or by contacting the ODB Data Privacy Officer.
ODB employees have a choice concerning what information is shared with other employees, affiliates and third parties (such as clients). Such information will only be provided pursuant to such employees’ written consent and not used for any other purpose.
Access and Correction – Any individual CVE may request a copy of the Personal Data ODB has collected from ODB Data Privacy Officer in accordance with applicable law, in addition to receiving confirmation of the contents of any Personal Data relating to the individual. Under applicable law, such individual CVE then has the right to correct, amend or delete information when it is inaccurate.
Clients may do so by contacting their Client Services Representative or by contacting the ODB Data Privacy Officer.
Except as may be required by law or during a registrar or regulatory audit, ODB will not provide this data to a third party without the consent of the CVE.
Vendors can do so by contacting service@odb-translation.com, a dedicated e-mail address to which such inquiries can be sent directly.
Employees can do so by contacting the ODB Human Resources department or the ODB Data Privacy Officer.
Data Integrity – ODB is dedicated to ensuring that all data maintained is accurate, updated, and relevant for the use contemplated and will take all required steps to ensure the data is accurate, complete and current. This process is accomplished by regular email and written correspondence with CVEs; however, it is highly recommended that CVEs continue to monitor the information provided to ODB and remain proactive with requesting access to any Personal Data and advising ODB of the need for corrections as needed.
Data Security – ODB has strict physical and logical security procedures to ensure that all digital and paper records are secured (such policy is available for dissemination to clients upon written request to the ODB Data Privacy Officer). These records are accessible only by approved staff. All critical systems (e.g., servers) are accessible only by a small number of authorized staff. ODB's information security is managed internally and is routinely audited to ensure conformity with ODB procedures and recommended industry standards.
Independent Recourses for Privacy Complaints and Contact Information
In compliance with the Privacy Shield Principles, ODB commits to resolve complaints about our collection or use of your personal information. To exercise all relevant rights, queries or complaints, please contact:
Stacey Watanabe
Data Privacy Officer
ODB
service@odb-translation.com
You may file Data Subject Requests or compliance issues via online form
ODB is committed to resolve all complaints in timely manner. If you do not receive timely acknowledgment of your complaint from us (to be acknowledged within 45 days of receipt), or if you are not satisfied with our response, or if contacting us does not resolve your complaint, Swiss residents may refer unresolved Privacy Shield complaints to the Federal Data Protection and Information Commissioner (FDPIC), which serves as the Alternative Dispute Resolution body (ADR) according to the Swiss-US Privacy Shield Framework. The services of this process are provided at no cost to you.
Enforcement
ODB undertakes to verify compliance with its Privacy Policy not less than once per year and in connection with ODB's annual review and internal compliance measures. ODB will use its best commercial efforts to ensure that compliance with this Privacy Policy is maintained and that the Privacy Policy is accurate, comprehensive, and continues to conform to applicable law. We encourage CVEs to raise and discuss any issues or concerns with ODB’s Data Privacy Officer, who address and resolve such complaints regarding the use of data and noncompliance with our Privacy Policy. All issues will be officially documented within the framework of our ISO 9001 certified quality management system.
ODB is committed to cooperate with EU data protection authorities (DPAs) as well as FDPIC, and comply with the advice given by such authorities with regard to human resources data transferred from the EU and/or Switzerland in the context of the employment relationship.
ODB provides information regarding the below through our policies and trainings:
ODB is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC);
The possibility, under certain conditions, for the individual to invoke binding arbitration;
The requirement for your organization to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements;
ODB's liability in cases of onward transfers to third parties;
With respect to complaints related to our Privacy Policy that cannot be resolved through our internal process, we agree to abide by the dispute resolution procedures established by the relevant authorities as designated by applicable governing regulations.
Effective: May 2022