Policy regarding the processing of personal data

We are committed to protecting your privacy and personal data. Therefore, we use your personal data strictly within the legal limits of the applicable data protection laws.

This policy is provided pursuant to article 13 of Regulation (EU) 2016/679 (hereinafter the "Regulation") by Translated s.r.l., headquartered in Rome (RM), Via Indonesia no. 23, VAT number IT07173521001, email: info@modernmt.com (hereinafter the "Company"), in order to present the purposes and methods with which personal data shall be processed, the categories of the data being processed, the rights granted to parties subject to data processing as well as the methods for exercising them with respect to the ModernMT service.

The following information refers exclusively to the processing of personal data concerning ModernMT customers and parties subject to data processing pursuant to article 4 (1) of the Regulation; however, any personal data potentially contained in documents sent to ModernMT for machine translation with regard to which the customer acts as an independent data controller is excluded under this policy.

1. Categories of personal data processed

ModernMT may process the following categories of personal data (hereinafter also "Data"):

1. personal data, such as given names, last names, dates of birth, sex;
2. contact information, such as addresses, telephone numbers, and email addresses;
3. fiscal data, such as tax codes, VAT numbers, or their equivalents;
4. data related to the use of the service, such as the types of packages purchased, the purchase volume, the frequency with which the service is used, etc.

The provision of the aforementioned data is required in order to enable you to create an account and use the services offered by ModernMT.

ModernMT may also incorporate payment systems provided directly by third parties (e.g. Stripe). For payments made through these systems, third-party providers, as independent data controllers, may process your personal data related to the payment methods used in accordance with the provisions of the separate privacy policy provided directly by these parties.

2. Purpose and legal basis of data processing

2.1 Execution of the contract

The processing of the personal data referenced in points (i), (ii), (iii) and (iv) of paragraph 1 above is performed by ModernMT in order to enable you to access the service and manage your account.

This personal data is, therefore, processed to execute the contract, pursuant to article 6, paragraph 1, subparagraph b) of the Regulation and for compliance with accounting and tax laws pursuant to article 6, paragraph 1, subparagraph c) of the Regulation.

2.2 Sending marketing communications

With your specific consent, ModernMT may process the personal data referenced in points (i) and (ii) of paragraph 1 above to send advertising material or marketing communications, including on behalf of third parties, related to promotions or for market research. Such communications may be sent through the use of automated systems (e.g. email, push notifications).

The consent given may also be withdrawn at any time with regard specifically to automated contact systems by writing to info@modernmt.com.

The data referenced in points (i) and (ii) of paragraph 1 above, acquired in the context of providing ModernMT services, may be used to send marketing communications related to services similar to the ones provided, pursuant to article 130 of Legislative Decree No. 196 of June 30th, 2003 (so-called "Soft spam").

You may, however, object to this processing at any time by following the instructions indicated on each occasion in any communication sent for this purpose, or by writing to info@modernmt.com.

2.3 Disclosure of data to third parties for their own marketing purposes

ModernMT may disclose the data referenced in points (i) and (ii) of paragraph 1 above to third parties that may process it to send their own marketing communications, including by email.

The categories of recipients to which ModernMT may disclose its data include parties working, for example, in the language and interpreting industry. The parties to which ModernMT discloses your personal data shall process this data as independent data controllers in accordance with the provisions of their respective privacy policies; the party subject to data processing must therefore contact them directly to exercise their rights thereof.

This data shall be disclosed to third parties pursuant to article 6, paragraph 1, subparagraph a) of the Regulation based on your independent consent.

Failure to provide consent for the disclosure of data to third parties does not affect the execution of the contract and the provision of services by ModernMT; however, the consent provided may be withdrawn at any time by writing to info@modernmt.com.

3. Processing methods

The personal data referenced in paragraph 1 above shall be processed both manually and electronically in compliance with the provisions of the Regulation, Italian legislation regarding the processing of personal data, and the applicable provisions of the Italian Data Protection Authority.

4. Data retention period

The personal data referenced in paragraph 1 above shall be processed for the period required to offer you the services requested and in any case until the termination of your contractual relationship with ModernMT and the final cancellation of your account.

Your data related to the contract entered into with ModernMT shall also be retained for a time corresponding to the normal limitation period (i.e. 10 years) exclusively in order to comply with legal obligations and for requirements related to the potential protection of ModernMT's rights.

The personal data referenced in points (i) and (ii) of paragraph 1 above shall be processed to send marketing communications until you withdraw your consent. For soft spam, your personal data shall be processed until you exercise your right to object to the processing.

With regard to the disclosure of data to third parties for their own marketing purposes, we notify you that the data may be disclosed until you withdraw your consent, where applicable.

5. Categories of recipients and scope of data movement

In addition to the parties indicated in paragraph 2.3 above, the personal data referenced in paragraph 1 above may be disclosed to third parties that ModernMT uses to carry out certain processing operations. These parties shall be appointed Data Processors pursuant to article 28 of the Regulation and shall receive the proper operating instructions, with particular reference to the adoption of appropriate security measures, in order to guarantee the confidentiality and security of the data. A list of these data processors may be requested from ModernMT by parties subject to data processing by writing to info@modernmt.com.

ModernMT may also disclose your personal data to potential third-party assignees of the contract or the company in order to continue to provide the services requested by you.

Your data shall not be disclosed in any way to any other unspecified parties.

6. Rights of parties subject to data processing

We notify you that you, in your capacity as the party subject to data processing, may exercise the rights provided for in articles 15 to 23 of the Regulation by writing to ModernMT at the following address: info@modernmt.com.

Specifically, you may:

• request and obtain information with regard to the existence of your personal data at the Company and with regard to the processing of personal data put in place by the Company, as well as obtain access to this data;
• request and obtain receipt of your data that is processed by automated means in a structured, commonly used, and machine-readable format; you may also request the transfer of the data to another data controller;
• request and obtain the modification and/or correction of your data if you believe that it is inaccurate or incomplete;
• request and obtain the deletion and/or the limitation of the processing of your data if it is data or information that is not required or is no longer required for the purposes above and in cases otherwise established by law;
• withdraw the consent previously given in the cases established in this policy.

We remind you that you may file a complaint with regard to the processing of your data by contacting the appropriate supervisory authority (in Italy, the Italian Data Protection Authority).

Last updated: December 2023